HomeMy WebLinkAbout10-2467T.
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P. Richard Wagner, Esquire
PA Supreme Court I.D. #23103
Mancke, Wagner, & Spreha
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax(717)234-7080
Attorney For Plaintiff
ANGELA SIPES, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. NO: p a4tv7 (21 Vi l -Term
CIVIL ACTION - LAW
JAMIE SIPES,
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 in divorce or annulment may be entered against you
by the Court. A judgment may also be entered against you for another 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 Courthouse, 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 BAR ASSOCIATION 435x.. oo P 0 All-/
2 LIBERTY AVENUE ev", ta08gA'D99
Carlisle, PA 17013
(717) 249-3166 2 ayo N83
P. Richard Wagner, Esquire
PA Supreme Court I.D. #23103
Mancke, Wagner, & Spreha
2233 North Front Street
Harrisburg, PA 17110
Telephone (717) 234-7051
Fax (717) 234-7080
Attorney For Plaintiff
ANGELA SIPES, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
V. : NO:
JAMIE SIPES,
: CIVIL ACTION - LAW
IN DIVORCE
Defendant.
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, Angela Sipes, by and through her attorneys, Mancke,
Wagner & Spreha, and files the following Complaint in Divorce:
1. The Plaintiff, Angela Sipes, is an adult individual currently residing at 222 Spring
Lane, Enola, Cumberland County, Pennsylvania.
2. The Defendant, Jamie Sipes, having as an address c/o Linda Hann, 31710 Great Cove
Road, Fort Littleton, Fulton County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months prior to the filing of this Complaint.
4. Plaintiff and Defendant are husband and wife having been married on June 21, 2008,
in Middletown, Dauphin County, Pennsylvania.
5. There were no children born unto the marriage.
6. There have been no prior actions of divorce or annulment between the parties in this or
any other jurisdiction.
7. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States
or any of its Allies.
8. Plaintiff has been advised of the availability of counseling and that she has the right to
request that the Court require both parties to participate in counseling.
9. The Plaintiff avers as grounds on which this action is based are:
A. That the marriage is irretrievably broken pursuant to §3301(c) of the
Divorce Code; and
B. That as of January 7, 2012, the parties will have lived separate and apart
for a period of at least two (2) continuous years pursuant to §3301(d) of
the Divorce Code.
WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce.
Respectfully Submitted,
agner & Spreha
P. R, ih:?er, Esquire
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
Attorneys For Plaintiff
Date: -?13? rG
-2-
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.A. §4904,
relating to unworn falsification to authorities.
Date: `k? -
ANGELA SIPES,
Plaintiff,
V.
JAMIE SIPES,
Defendant.
IN THE COURT OF
CUMBERLAND CO
NO. 2010-2467 -
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Di
on April 14, 2010.
LION PLEAS
, PENNSYLVANIA
TERM
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Code was filed
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 Comp aint.
3. I consent to the entry of a final decree of divorce after se ice of notice of
intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony, d'vision of property,
lawyer's fees or expenses if l do not claim them before a divorce i granted.
I verify that the statements made in this affidavit are true an correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
Date: ° ? -1 ()
Angela
ANGELA SIPES,
Plaintiff,
V.
.JAMIE SIPES,
Defendant.
IN THE COURT OF
CUMBERLAND CC
NO. 2010-2467 -
CIVIL ACTION -LAW
IN DIVORCE
1. I consent to the entry of a final decree of divorce without
LION PLEAS
, PENNSYLVANIA
TERM
2. I understand that I may lose rights concerning alimony, divisi n 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 led with the
prothonotary.
I verify that the statements made in this affidavit are true and cc
false statements herein are made subject to the penalties of 18 Pa.C.S.
falsification to authorities.
Angela
I understand that
. relating to unworn
DATE: K) - i _t (
IN THE COURT OF COMMON PLEAS OF
ANGELA SIPES CUMBERLAND COUNTY, PENNSYLVANIA
V.
JAMIE SIPES
NO. 2010-2467 CIVIL TERM
DIVORCE DECREE
AND NOW, mom, i7 2 a i 2 , it is ordered and decreed that
ANGELA SIPES , plaintiff, and
JAMIE SIPES , 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,
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