The URL can be used to link to this page

Home My WebLink About09-4408Constance P. Brunt, Esquire Supreme Court ID 829933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbru nt(&CP Bru ntLaw. com Attorney for Plaintiff MARY MCGILL LOPER, Plaintiff V. WAYNE C. LOPER, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAWN NO. 09 - H408 0,;"a I-,. : 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 by the court. A judgment may also 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 at One Courthouse Square, Carlisle, PA 17013-3387. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 c p b ru nt(D_C P B ru ntLaw. com Attorney for Plaintiff MARY MCGILL LOPER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. del- y Kok ?. T WAYNE C. LOPER, 11, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, MARY MCGILL LOPER, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, WAYNE C. LOPER, II, upon the grounds hereinafter set forth. 1. Plaintiff is MARY MCGILL LOPER, an adult individual who currently resides at 432 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant is WAYNE C. LOPER, II, an adult individual who currently resides at 922 Indiana Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 30, '1992, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. 2 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. Respectfully submitted, DATE: 612 9 0 CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbru nt(W-C P B ru ntLaw. corn Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce 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: to MARY MC ILL LOPER, Plaintiff ALL--C- c-' - r 7 _TAIRY 2009 & - I f 'r 1: 14 Ci1r}`S f s'TY r" L-.,'' 4 338.50 Pt' ATrl CAOr 1466 pj# aa.74US Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpruntPCPBruntLaw com Attorney for Plaintiff MARY MCGILL LOPER, Plaintiff V. WAYNE C. LOPER, II, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 09-4408 cnu mm : IN DIVORCE ACCEPTANCE OF SERVICE I, DAVID F. TAMANINI, ESQUIRE, attorney for the Defendant, WAYNE C. LOPER, II, in the above-captioned divorce action, hereby accept service of the Complaint in Divorce filed on July 1, 2009, in the Court of Common Pleas of Cumberland County, Pennsylvania, and certify that I am authorized to do so. Date: .2 O d DAVID F. TA INI, ESQUIRE Supreme Court ID # 27775 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112-9507 (717) 232-7200 FAX (717) 232-0255 dfta-TamaniniLaw com Attorney for Defendant THF 280 JUL 10 F i 5 . IF $ LU!9°1`'7 1,3 1".''' (': 22 Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cobruntDCPBruntLaw.com Attorney for Plaintiff MARY MCGILL LOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. NO. 09-4408 CIVIL TERM WAYNE C. LOPER, 11, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 1, 2009. 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. 1 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. DATE: Ib??)O MARY M GILL LOPER, Plaint' . -, i 'ii'i'! n 7•, r p t ^,'! ( rt , .? t l i e , ? . t ?a it 4 A i E F 5 7"?. i} ?, Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cobrun BruntLaw com Attorney for Plaintiff MARY MCGILL LOPER, Plaintiff V. WAYNE C. LOPER, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4408 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301 (C) AND §3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree In Divorce without notice. 2. 1 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. 1 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 Waiver of Notice 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: ib)s)aoin -M'jJjJ 1,0 A MARY MC ILL LOPER, Plaints -2- ~1-~ ~it..l..~~~~~~~xv ~1~- ~~~ ~~i~~i~~~~~~~~ za~o a~~ 27 ~~ is rt1M8ER~.~:1~0 COU~T'c' PEt~t~S'l~_~r~.~=1! ~~ Constance P. Brunt, F~quire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cabrunt~lCPBruntLaw.com Attorney for Plaintiff MARY MCGILL LOPER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO. 09-4408 CIVIL TERM WAYNE C. LOPER, II, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 1, 2009. 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. r . 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: (U - IS -/O WAYNE~C. LOPE, I1, Defendant i t- ~;~ T~~~ ~ ~~ ~~ !~~ ~~ c~ ~`~ r~'~ Z01 ~Q~~27 P~~ ~: ~;,., ~'tl ~~~f~S ~~~ r Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cabrunt®lCPBruntLaw.com Attorney for Plairrtiff MARY MCGILL LOPER,. Plaintiff v. WAYNE C. LOPER, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-4408 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) AND §3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree In 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. r' v I verify that the statements made in this Waiver of Notice 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: /O - /8- /a LOPE , WAYN Defendant -2- c Or Tl;{~ P~0 ~~{t7~~t~ ~-,~ . .r, , ~JfO ~~T 27 pp1 1: CU ~~~~I'AI~~CI~G'f~U~~?"',' Constance P. Brunt, Esquire Supreme Court ID #129933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717)232-7200 FAX (717) 232-0255 cpbrunt6iCPBruntLaw.com Attorney for Plaintiff MARY MCGILL LOPER, Plaintiff v. WAYNE C. LOPER, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-4408 CIVIL TERM 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). 2. Date and manner of service of the Complaint: July 6, 2009, by Acceptance of Service filed on July 10, 2009. c 3. Complete either paragraph (a) or (b). a. Date of execution of the Affidavit of Consent required by 3301 (c) of the Divorce Code: By Plaintiff on October 5, 2010; and by Defendant on October 18, 2010. b. (1) Date of execution of the Affidavit required by 3301(d) of the Divorce Code: N/A. (2) Date of filing and service of the Plaintiff s Affidavit upon the Respondent: N/A. 4. Related claims pending: NONE. 5. Complete either (a) or (b}. a. Date and manner of service of the Notice Of Intention To File Praecipe To Transmit Record, a copy of which is attached: N/A. b. Date Plaintiffs Waiver Of Notice in 3301 (c) Divorce Code was filed with the Prothonotary: October 13, 2010. Date Defendant's Waiver Of Notice in 3301 (c) Divorce Code was filed with the Prothonotary: October 27, 2010. Respectfully submitted, DATE: ~~zG~d CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbrunt CPBruntLaw.com Attorney for Plaintiff MARY MCGILL LOPER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. WAYNE C. LOPER, 11, NO. 09-4408 CIVIL TERM Defendant DIVORCE DECREE AND NOW, ~ 2'=' z... ~ s , it is ordered and decreed that MARY MCGILL LOPER. Plaintiff, and WAYNE C. LOPER. II. ,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. By the Court: A J. Prothonotary led `~ '~~~~ rr-o~ F ~o ~ ~~. ~p~~~d`~ ~f 1 ~a~~ Mary McGill Loper Plaintiff V. Wayne C. Loper II Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO: 09-4408 CIVIL TERM IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 2nd day of November, 2010 hereby elects to resume the prior surname of Mary McGill, and gives this written notice pursuant to the provisions of 54 P.S. 704. Date C Signature Signature ofQname bei unid -r COMMONWEALTH OF PENNSYLVANIA corgi 'ter r?-z ? co • SS. - CZ) COUNTY OF CUMBERLAND 3 AZ 00 On the . day of l 1UL'? fi , 2010, beforee, e+Nary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand an COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumberland County My Commission Expires August 20, 2013 Ca SA-