HomeMy WebLinkAbout10-1197FILED--C; T"E
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Karen W. Miller, Esquire 2Q 10 F? 22e' $
Attorney I.D. No. 200037
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
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(717) 232-7661
(717) 232-2766 (fax)
Attorney for Barry A. Cupp
BARRY A. CUPP, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. jQ- 1lgJ Civil Term
SUSAN K. CUPP, 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 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, Cumberland County Court House, One Courthouse Square, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
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 17113
(717) 249-3166
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BARRY A. CUPP, IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. Civil Term
SUSAN K. CUPP, CIVIL ACTION - LAW
Defendant IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the Court require
you and your spouse to attend marriage counseling prior to a divorce being handed down by the
Court. A list of professional marriage counselors is available at the Domestic Relations Office,
13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
a
Karen W. Miller, Esquire
Attorney I.D. No. 200037
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
Attorney for Barry A. Cupp
BARRY A. CUPP,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
SUSAN K. CUPP,
Defendant.
No. 6- /15 7 CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Barry A. Cupp, an adult individual who resides at 825 Flintlock Ridge
Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is Susan K. Cupp, an adult individual who resides at 498 Nursery Drive
South, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
3. Plaintiff and Defendant have been bona fide residents of 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 October 5, 1996, in Dillsburg,
Cumberland County, Pennsylvania.
5. There have been no prior actions in divorce or annulment between the parties.
6. The Defendant is not a member of the armed forces of the United States or any of its
allies.
7. The Plaintiff avers that the marriage is irretrievably broken.
8. 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. The Plaintiff does
not desire counseling.
COUNT I - EQUITABLE DISTRIBUTION
9. Paragraphs 1 through 8 above are incorporated herein by reference.
10. During the marriage, Plaintiff and Defendant have acquired various items of marital
property, both real and personal, which are subject to equitable distribution under Section 3502 of
the Divorce Code.
WHEREFORE, Plaintiff requests Your Honorable Court to:
A. Enter a Decree in Divorce;
B. Equitably distribute all property, both personal and real, owned by the parties; and
C. Grant such further relief as the Court may deem equitable and just.
Respectfully submitted,
Date:
By: aku
aren W. Miller, Esquire
Attorney I. D. # 200037
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110-1533
(717) 232-7661
Attorney for Plaintiff, Barry A. Cupp
06500-0021156515
VERIFICATION
I, Barry A. Cupp, verify that the averments made in this Complaint are true and correct
to the best of my knowledge, information and belief. 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: , -"-d' &a a r / 10 / o
?: 6? (?) r, -. ??
B A. Cupp
Karen W. Miller, Esquire
Attorney I.D. No. 200037
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
Attorney for Barry A. Cupp
BARRY A. CUPP,
vs.
FILED-OFFCE
OF THE PROTHONOTARY
2010 MAR -4 PM 3: 08
CUM sT 7JUNTY
PENNXLV,Nv1A,
: IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN K. CUPP,
Defendant
No. 10-1197 Civil Term
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint, filed on February 22, 2010, on behalf of
Defendant, Susan K. Cupp, and certify that I am authorized to do
y sgbmitted,
By:
Barbara e-Sullivan, Esquire
Attorney I.D. #32317
549 Bridge Street
New Cumberland, PA 17070
06500-002/159476
Karen W. Miller, Esquire
Attorney I.D. No. 200037
Caldwell & Kearns, P.C.
3631 North Front Street
Harrisburg, PA 17110
(717) 232-7661
(717) 232-2766 (fax)
Attorney for Barry A. Cupp
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Cl A Ai `Y
BARRY A. CUPP,
vs.
IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN K. CUPP,
Defendant
No. 10-1197 Civil Term
CIVIL ACTION -LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint, filed on February 22, 2010, on behalf of
Defendant, Susan K. Cupp, and certify that I am authorized to do so.
tted,
Date: ! By:
Barbara Style-Sullivan, Esq
Attorney I.D. #32317
549 Bridge Street
New Cumberland, PA 17070
06500-002/159476