The URL can be used to link to this page

Home My WebLink About09-8797Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 NEVIN JEFFREY DEPPEN, Plaintiff V. Attorneys for Plaintiff IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PENNSYLVANIA NO. 011v%il-Teirm, CIVIL ACTION - LAW LESLIE D. DEPPEN, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS IN DIVORCE 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 pages 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 the Cumberland County Courthouse, 1 Courthouse Square, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 NEVIN JEFFREY DEPPEN, Plaintiff V. LESLIE D. DEPPEN, Defendant Attorneys for Plaintiff I IN THE COURT OF COMMON PLE?S CUMBERLAND COUNTY, PENNSYLV NIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, NEVIN JEFFREY DEPPEN, by and through his attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, LESLIE D. DEPPEN: 1. The Plaintiff is NEVIN JEFFREY DEPPEN, an adult individual, residing at 409 Carlo Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is LESLIE D. DEPPEN, an adult individual, residing at 1301 Warwick Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant were married on April 1, 1995, in Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. i 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Wife left the marital residence on August 31, 2006 and has not returned. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of marriage counseling and he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a Decree of Divorce under Section 3301(c) or 3301(d)_9jAbe_Divorce Code. SON, Dt)':FIE, STEWART & WEIDNER Melissa Peel Greevy :386006 M VERIFICATION I, NEVIN JEFFREY DEPPEN, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. JA, _ ?& Date: 12-r 16 (off( ` NEVIN JEFF D PPE 386006 ARY z49 C, EC 22 F; i: v ?°i?IyfiVYti * 35a . Cc po AT" l a(04 /39-3m I? a35?a Johnson, Duffle, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 NEVIN JEFFREY DEPPEN, Plaintiff V. LESLIE D. DEPPEN, Defendant AFFIDAVIT IN DIVORCE NEVIN JEFFREY DEPPEN, being duly sworn according to law, deposes and says: 1. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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: 6 q 4 NEVIN JE Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. - 8741 i yi t CIVIL ACTION - LAW 1ARY 20, 09 DEC, C 2 Pi i 12: %-53 I'i \: Johnson, Duffie, Stewart & Weidner By: Melissa Peel Greevy I.D. No. 77950 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 tJF 7 c? OTARY 1010 JAN -6 PM 1 31 Attorneys for Plai i r,. . t%3N? PCI? NSYLVAhj-? NEVIN JEFFREY DEPPEN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 09-8797 CIVIL TERM V. CIVIL ACTION - LAW LESLIE D. DEPPEN, IN DIVORCE Defendant RETURN OF SERVICE AND NOW, this 5th day of January, 2010, the undersigned does hereby certify that on January 2, 2010, the Divorce Complaint filed December 22, 2009 in the above captioned action was served upon Defendant, LESLIE D. DEPPEN, via certified mail return receipt requested, restricted delivery, addressed to 1301 Warwick Road, Camp Hill, Pennsylvania 17011, the Return Receipt and Tracking Search from USPS.COM evidencing service upon Defendant is attached hereto as Exhibit A. JOHNSON,PUFFIE, STEWART & WEIDNER Melissa Peel Greevy I.D. No. 77950 Johnson, Duffie, Stewa & Weidner 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing Return of Service upon all parties or counsel of record by depositing a copy of same in the United States Mail at Lemoyne, Pennsylvania, with first-class postage prepaid on the day of January, 2010, addressed to the following: Leslie D. Deppen 1301 Warwick Road Camp Hill, PA 17011 JOHNSON, DUFFIE, STEWART & WEIDNER lissa Peel Greevy :387670 USPS -Track & Confirm Page 1 of 1 UNMED STATES A POS11ALSERViCEt Kome. I Hoip I Sip In Track & .Confirm FAQe Track & Confirm Search Results Label/Receipt Number: 7007 2680 0001 8067 9795 Service(s): Certified MaiITM Status: Delivered Your item was delivered at 12:25 PM on January 2, 2010 in CAMP HILL, PA 17011. Detailed Results: • Delivered, January 02, 2010,12:25 pm, CAMP HILL, PA 17011 • Notice Left, December 24, 2009, 3:25 pm, CAMP HILL, PA 17011 • Arrival at Unit, December 23, 2009,4:27 pm, LEMOYNE, PA 17043 Notification Options Go> Track 8a Confirm by email Get current event information or updates for your item sent to you or others by email. r Go> site Map Customer Service Forms Gov't Services Careers Privacy Policy Terms of Use Business Customer Gateway Copyright(D 2009 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA Complete items • 'tern rint yR estrictefd 2 peive y-Also oomplete so that our name and addre is desired. to Attach this we s on can return the t the reverse or on the from to the baccard the 7 Art,-Ad ffspacepermits mail , Piece, rased to: Ctrs . ?,? ? ? lea , ? 7p// t '? Si9na-? aC B Received by (PhNec; _---------- Track & Confirm Enter Label/Receipt Number. 9 Agent D ?s delivery address d• C' Date of Delivery Brant from nevi 1 ? D Y ff YES, enter delivery, add mss below: Q No 3. 7Ype R 8 ertiftw Mail nesy 2' Article Nu O IRegW0r9d O ? Mall m ?r ? u eshIcted Frarrsferbpnr setw, f ?0 4 R Deliv C.O.D PS R?j? for Me?handlse ern' 3817, Febn,a?Y2opq 07 268D 000.1 $0 ?a8,?? !7 y? ?¦ -_ - - DO"'estic Return 6 7 c7 7 95 _ -- Receipt http://trkcnfrml.smi.usps.com/ - 102595-02-M.1540 1/5/2010