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HomeMy WebLinkAbout08-20360 DORIS M. SIPE : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. OB- ADUP Civil -Ter (?^ ROBERT W. SIPE : CIVIL ACTION - LAW Defendant : 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 may proceed without you and a decree of divorce or annulment may be entered against you for any other 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 DORIS M. SIPE Plaintiff VS. ROBERT W. SIPE Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 6?--?0'3G : CIVIL ACTION - LAW : IN DIVORCE COUNTI COMPLAINT FOR DIVORCE UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, Doris M. Sipe, by her Attorneyy, Mark A. Mateya, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth. Plaintiff is Doris M. Sipe, an adult individual who currently resides at 13 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania 17013. 2. All legal papers may be served on Plaintiff by service on her Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, PA 17007. 3. Defendant is Robert W. Sipe, an adult individual who currently resides at 1 West Penn St., Carlisle, Cumberland County, Pennsylvania 17013. 4. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on Feb. 19, 1983, in Carlisle, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. Neither the Plaintiff nor the Defendant are members of the armed services of the United States or any of its allies. 9. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 10. Plaintiff and Defendant are the owners of various items of real property, personal property, furniture and household furnishings that may be subject to equitable distribution by this Court. 11. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits which may be subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distributing all property owned by the parties hereto; C. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of hearing on this Complaint, Plaintiff respectfully requests that pursuant to §304(a)(1) and (4) and §401(b) of the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; e. For such further relief as the Court may determine equitable and just. Respectfully submitted, Dated By: Mark A. Mateya Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff VERIFICATION I, Doris M. Sipe, verify that the facts set forth in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. DATED:-5 2,2,0 Doris M. Sipe O C` O O f" AM DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 16th day of April, 2008, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: 1. A Complaint for Divorce was filed to the above term and number on March 31, 2008. 2. On April 9, 2008, a certified copy of the Complaint in Divorce was sent to the Defendant via certified mail, restricted delivery, return receipt requested pursuant to Pa. R.C.P. 1920.4. See the Receipt attached hereto as Exhibit "A" and incorporated herein by reference. 3. On April 1, 2008, a certified copy of the Complaint was set to the Defendant via first class mail, postage prepaid. A copy of the Certificate of Mailing is attached hereto as Exhibit "B" and is incorporated herein by reference. f. - .,i 4. On or about April 14, 2008, undersigned counsel for Plaintiff received the return receipt card signed by the Defendant on April 10, 2008. Said receipt is attached hereto as Exhibit "A" and is incorporated herein by reference. Respectfully submitted, PA . Mk ?C ateya, quire Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff U.S. Postal Service-?. CERTIFIED MAIL..... RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) u rn ru Postage $ ?? p certified Fee ?s y O p Return Redept Fee (Endorsement Required) r. r . . , ? 4 ? C3 O Ln Restricted Delivery Fee (Endorsement Requtred) J c? d , Q? 0 Total Postage & Fees ' /?' v J m p ° to S? Pc =f ? -- ? . -- ---- ..... .............. - - or PO Box No. ?..l ? f ,.. ?.. t r ' ? R 7 C)/3 :11 rl ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. A. X 8. Received by ( Name)' - .t ? C, 0 Agent 0 Addressee D. Is delivery address different from kern 1? U Y8s If YES, enter delivery address below: 0 No l Gvesf ?nn ? IMe- f I S ??r r •,l ? 7 d/ 3 3. ioe Type pCertlHed Mail 0 Express Mail Registered 0 Return Receipt for Merchandise 0 Insured Mau 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number -- - . ------- - -- _ - Mansferfromservicek6o 7003 0500 0004 2330 3819 PS form 3811, February 2004 Domestic Retum Receipt 102595-M-M-1540 1. Article Addressed to: U.S. POSTAL SERVICE CERTIFICATE OF MAILINU MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: ?O.w ? (' 0.1 o "moo x a -7 _ One piece of ordinary mail addressed to: R ob?fi w . S ? ,P ? WZS? ?Q.(ln `J Il v?? Gc\? she , (apt o PS Form 3817, Mar. 1989 V T ?o 4 Y v 4 w 0 o :D r- C C2 i, A z in ? ?.. c... V00 N o? b Z ?D L" C) T) V ) M D x3 .=-a F-t T NO r; .. GT . , DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was filed on March 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ert W. Sipe ?? .?- Defendant DATED: ) ` / I:-,(. -CC/ I INI) ?- - r l 8qy _ DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $ 3301(c) OF THE DIVORCE CODE I . I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. DATE 3-1 ct -61 ert W. Sipe, Z?t/-? Defendant i .? '"?'. ,S ~ V t ?1 ? • .tom ?4.J 3 ? • ?rP ? y c DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was filed on March 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATED: Doris M. Sipe Plaintiff (-", ` ? ` . ? _ _ ??? :?.? '?.: r ?, cy - "' i •t : ? .- ?;, ; ? ; -.. ? ?=: to ;.1 DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. s DATE -3: 2 q A 64f/.L Doris M. Sipe Plaintiff G? S T -71 HI , v DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 ( c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on or about April 9, 2008. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff March 23, 2009 ; by Defendant March 19, 2009 (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff s affidavit upon the Defendant: 4. Related claims pending: None 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff s Waiver of Notice in §3301( c) Divorce was filed with the prothonotary: simultaneously herewith. Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: Simultaneously herewith Plaintiff has filed a Waiver of the Notice of Intention to Request Entry of A Divorce Decree. LL?--? Mark A. Mateya, squire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff d`?J ??.? ?. 'il .--t :%? ?`?r -' ?? - C+ ?- . .., ' ). - ? ?? ?.} .. ? l'Si a_y { ? ??} -- DORIS M. SIPE, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT W. SIPE, DEFENDANT 08-2036 CIVIL TERM ORDER OF COURT AND NOW, this T I day of March, 2009, the request for the entry of a final decree in divorce, IS DENIED.' Mark A. Mateya, Esquire For Plaintiff :sal nn I. P? ' Based on a "guardian" signing the affidavit of consent, there is nothing in the record to reflect whether Robert Sipe is a minor or an incapacitated person and thus was properly sued and served individually. There is nothing in the record to establish whether service of the complaint by certified mail which was signed by a Colleen A. Christopher was proper service. There is nothing in the record to reflect that John Sipe, who signed defendant's affidavit of consent as guardian for Robert W. Sipe, is a proper person to sign the affidavit. CL ?LLJ as_ C, DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was filed on March 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATED: -Ar o ':exo, Doris M. Sipe Plaintiff RLED -'::%, C'E OF THE OPOII-lrWOTARY 2009 JUN 12 AM 8: 5 3 PENNSYLVANIA DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE fl 3oris Sipe Plaintiff OF THE PFf,,T' lNOTiPY 2009 JUN 12 AM 8: 53 ,t S IN RE: ROBERT W. SIPE, An Alleged Incapacitated Person No. B 4S'- cP-v 3& c N: i -le-r- : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. Q21'o?- Ilri( ORPHANS' COURT DIVISION FINAL DECREE n o _ 00 ?o NOW, this 4 f4v day of , 2008, based upon the evbt c-) received and the record, this Court finds by clear and convincing evidence that RO W.N r.? J SIPE is, and therefore is adjudged, a totally incapacitated person. Jo c_ :, C: 77 #i:Pr6n totaW The Court finds that ROBERT W. SIPE suffers from dementia, which cor impairs his capacity to receive and evaluate information effectively and to make and communicate decisions concerning the management of his financial affairs or to meet essential requirements for his physical health and safety. These judicial determinations have taken into consideration the matters required by 20 Pa. C.S.A. Accordingly: To Lvl?.o *`,G.wt • Sr~ +, is hereby appointed Guardian of the Estate of ROBERT W. SIPE and shall have au ority and responsibility to manage and use the incapacitated person's property for his benefit in accordance with 20 Pa. C.S.A. 5536(a). The Guardian of the Estate of ROBERT W. SIPE shall take control of the incapacitated person's property and assure that it is adequately protected against loss; shall invest said property in investments suitable to the incapacitated person's circumstances; shall pursue the incapacitated persons's outstanding claims; shall if necessary seek an accounting from such one or more persons as have controlled the incapacitated person's property; shall establish a budget and shall file a report with the Clerk of the Court about assets, investments, receipts and disbursements, as required by 20 Pa. C.S.A. §5521( c), within twelve months of this Decree and annually thereafter. The Guardian shall file an inventory with the Court in accordance with 20 Pa. C.S.A. §§5521 and 5142 within three months of this Decree. According to 20 Pa. C.S.A. §5536(a) the Guardian of the Estate of ROBERT W. SIPE is authorized to spend income for the aforesaid purposes without the Court's written approval. The Guardian of the Estate of ROBERT W. SIPE shall not be required to post a bond. Any existing general power of attorney, limited power of attorney and/or health care power of attorney executed by the said ROBERT W. SIPE is hereby specifically revoked and rendered null and void. The said ROBERT W. SIPE has the right to appeal this Decree to the Superior Court of Pennsylvania within thirty (30) days of this Decree. I The aforementioned judicial determinations have taken into consideration the matters required by 20 Pa. C.S.A. 5512.1. The findings of fact and conclusions of law have been made of record at the evidentiary hearing. BY THE J. A TRUE COPY FROM RECAR" in Test?Y ' 1 her 0 W1 Se Mpi hand OW " 6*1 Gault at CPA 04 20Q`1 ^i.rk d Court ?M••l +d Oounw RLED--COFI OF THE € RC ° HO OTARY 2009 JUN 12 Ark 8: 54 DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, John A. Sipe, Sr., Guardian for Robert W. Sipe, Defendant herein, hereby accept service of a true and correct copy of the Complaint in divorce dated March 31, 2008. kj-)-AxC - WITNESS Jo . Sipe, Sr., Guardian for Robert W. Sipe Date: C5-?Z ?l b q Date: 2 a /01 FLED-OFFICE OF THE PROT'HrNOTA,RY 2009 JUN 12 A 8: 53 cum 'IIJNTY RENNSYLVANIA DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF JOHN A. SIPE, SR. I, John A. Sipe, Sr., Guardian for Robert W. Sipe, Defendant herein, hereby verify that I have first hand knowledge that Robert W. Sipe, Defendant to the above-referenced divorce matter received a certified copy of the divorce complaint and that Robert W. Sipe was aware of the divorce proceedings. I, John A. Sipe, Sr., verify that the facts set forth in the above are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. fij'.? k ??k WITNESS r ?. J Sipe, Sr., Guardian for Robert W. Sipe Date: 5 Z R 0 Date: Z? d? FILED-O'F CE OF THE f THOWC)TARY. 2009 JUN 12 AEI 8: 52 CUM k-i,),UNTY RPE' NS` NI- RA DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was filed on March 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATED: z Jo . Sipe, Sr. Guardian for Robert W. Sipe Defendant RLED-OffiCE OF THE POTFiC NOTAPY 2009 JUN 12 AM S: 52 O NNS'!LVAINIIA DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I . I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE 2-4 6 R Jo . Sipe, Sr. Guardian for Robert W. Sipe Defendant RLED--OFRCE OF Tf PROTHONOTAW 2009 JUN } 2 AM 8: 52 U6 ?. UN I PEN 1 v ? I VA1i'iA. i % DORIS M. SIPE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-2036 CIVIL TERM ROBERT W. SIPE, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 ( c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on or about April 9, 2008. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff March 23, 2009 ; by Defendant May 29, 2009 (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in §3301( c) Divorce was filed with the prothonotary: simultaneously herewith. t ? Date defendant's Waiver of Notice in §3341( c) Divorce was filed with the prothonotary: Simultaneously herewith Plaintiff has filed a Waiver of the Notice of Intention to Request Entry of A Divorce Decree. L?-P: Mark A. Mateya, Esquire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff FILED--D?FiCE OF THIS P-RrOTHONI OTAR'Y 2009 JUN 12 AM 8: 5 5 CUmptw iwa"ji 'l, +y PEN 1,1?>x !A Doris M. Sipe V. Robert W. Sipe IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-2036 DIVORCE DECREE AND NOW, KQ-- tZ , it is ordered and decreed that Doris M. Sipe plaintiff, and Robert W. Sipe defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None • Attest: J. Pro onotary +• •. .T,?,1 ?P. ?? ?l ?.,?? l