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Home My WebLink About03-6360TRACY M. RUPP, JEFFREY L. RUPP, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 0 3 '/,- 3/~ 0 CIVIL TERM : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013 {717) 249-3166 TRACY M. RUPP, JEFFREY L. RUPP, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. oJ- (,~ ~,o CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Tracy M. Rupp, an adult individual currently residing at 420 North College Street, Carlisle, Cumberland County, Pennsylvania. Defendant is Jeffrey L. Rupp, an adult individual currently residing at 67 Mountain Street, Mount Holly, Cumberland County, Pennsylvania. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on August 30, 1986, in Carlisle, Cumberland County, Pennsylvania. There have been no other prior actions for divorce or annulment between the parties. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiffdoes not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. COUNT II INDIGNITIES 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent injured spouse, as to make her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (a) (6). COUNT III EQUITABLE DISTRIBUTION 13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full text. 14. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 15. Plaintiff and Defendant are joint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 16. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. COUNT IV ALIMONY, ALIMONY PENDENTE LITE, AND COUNSEL FEES 17. Paragraphs 1 through 16 are incorporated herein by reference as if set forth in their full text. 18. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 19. Plaintiff is without sufficient property and otherwise unable to sufficiently support herself financially. 20. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, as well as alimony, and alimony pendente lite for the Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay for Plaintiffs counsel fees, expenses, and costs as well as providing for payment of an appropriate alimony and alimony pendente lite to Plaintiff. Respectfully submitted, ~E~____~t~n eyfffr Plat'n t/j~ quire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. T~RA~M~. 'RUP~amtiff TRACY M. RUPP, JEFFREY L. RUPP, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. cQ ~ - d~g~:v CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this /~_~ 'day of December, 2003, comes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, Tracy M. Rupp, and states that a true and attested copy of a Complaint in Divorce was forwarded to Jeffrey L. Rupp, at 67 Mountain Street, Mt. Holly, PA 17065, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on December 9, 2003. '~t.~ f o ~ P l ad'n t iff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to befor~me thi,s ~ day of [)~fJ ~/~[X C ,2003 NOTARYVP~IC NOTARIAL ,SEAL KRRfSA,I. L~HId~, NOTARY RUBtJ~ G4RI,J,ILE 1~4~). CUMBERLAND 0011~ MY COMMISSION EXPIRES AUG. 1~5.2007 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reveme ~o that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Sig um E~J~_by~ Pdn~llf~rame) J C. Date of Delive~ D. Isdelive~yaddm~sdiffemntt~rniteml? [] Yss If YES, enter deiive~, address below: [] No 2. Article Number PS Form 3811, August 2001 Dorne~th= Return Receipt 3. Service Type j~Cer~ifled Mail r-I Express Mall [] Registered ~"Retum Receipt for Merchandise [] Insured Mail ~] C.O.D. 4. Restricted Deliver? (Ex/fa Fee) ~Yes 102595-01 -Mq3ssl TRACY M. RUPP, Plaintiff VS. JEFFREY L. RUPP, Defendant : IN THE COURT (DF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -- LAW : : NO. 03-6360 CIVIL TERM : IN DIVORCE TO THE PROTHONOTARY: PRAECIPE Please mark the above-captioned divorce action as withdrawn andd~contmue · Respectfully submitted, Date squire ~-~i4-~rney for Plaintiff GPdFFIE & ASSOCIATES 200 North Hanover Street Carlisle:, PA 17013 (717) 243-5551 (800) 347-5552