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Home My WebLink About04-2785ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : DIVORCE Defendant : NO. NOTICE 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 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 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 Dauphin County, Front and Market Streets, Harrisburg, 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 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 ADRIENNE R. TAPPAN : 1N THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : DIVORCE Defendant : NO. t~t4 COMPLAINT IN DIVORCE 1. Plaintiff Adrienne R. Tappan who currently resides at 106 S. 27th Street, Camp Hill, Cumberland Connty, Pennsylvania 17011. 2. Defendant is Justin S Tappan who currently resides 106 S. 27th Street, Cam Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiffhas been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 12, 2000, in Lernoyne, Cumberland County, Pennsylvania. 5. No children were born of this marriage. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and it amendments. 7. There have been no prior actions of divorce or for annulment between the patties. 8. The marriage is irretrievably broken. 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. 10. Plaintiffrequests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce divorcing Plaintiff and Defendant and such other Orders as are just and appropriate. Respectfully submitted, Melissa L. Van Eck, Esquire Attorney ID No. 85869 7800 A Allentown Blvd. Suite B P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 Date: ~-//-t~d7/ Attorney for Plaintiff VERIFICATION I, Adrienne Tappan, verify that the statements made in the foregoing COMPLAINT in DIVORCE are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are mad subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: A ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND. COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW .' DIVORCE JUSTIN S. TAPPAN Defendant NO. 04-2785 Civil Term ACCEPTANCE OF SERVICE I, Justin S. Tappan, acknowledge that I accept service c,f the Complaint in Divorce in the above referenced matter via hand delivery on the date indicated below. ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : DIVORCE JUSTIN S. TAPPAN : Defendant : NO. 04-2785 Civil Term A~FFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 17, 2004. 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 ora final · oflntention to Request Entry of the Decree. Decree of D~vorce after service of Notice I verify that the statements made in this Affidavit are tree 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. Plaintiff ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : DIVORCE JUSTIN S. TAPPAN : : Defendant : NO. 04-2785 Civil Te~n WArieR Ot~ NOT,CE Or mTENT~ON TO REQt~ST ENTRY OF A DIVORCE DECREE UNDER §3301 (C) Og Tm~ D~VORCE CODE 1. I consent to the enh'y of a final Decree of Divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifl 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 Cour~ and that a copy of the Decree will be sent to mc immediately a.~er it is filed with the Prothonotary. I v~'ify 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 unswom falsification to authorities. ~¢rme R. Tappan /, - ' - Plaintiff ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA .. vs. : CIVIL ACTION - LAW : DIVORCE JUSTIN S. TAPPAN : : Defendant : NO. 04-2785 Civil Term A~FFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 23, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and n~nety - (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce aider 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 unswom falsification to authorities. Defend~[~Z~.~-'~ ~ ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS Plaintiff, : : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW : DIVORCE JUSTIN S. TAPPAN : : Defendant : NO. 04-2785 Civil Term WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRy OF A DIVORCE DECREE UNDER §3301 (C) OF TIlE DIVORCE CODE I. I consent to the entry of a final Decree of Divoree without notice. 2. I understand that I may lose rights concern/ng alimony, division of property, lawyer's fees or expanses ifl 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 unswom falsification to authorities. Defendant ~ ADRIENNE R. TAPPAN : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, pENNSYLVANIA Plaintiff, : CIVIL ACTION - LAW v. : DIVORCE JUSTIN S. TAPPAN, : : NO.: 04-2785 Civil Term Defendant. PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an apprcpdate decree: 1. Ground for divorce: irretxievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of servico of the complaint: Served viahand delivery on June 30, 2004. Acceptance of Service filed on July 12, 2004. 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 plaintiffon September 30, 2004; by defendant September 30, 2004. 0o)(l) Date of execution of the plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: N/A; (2) Date of service of the plaintiffs affidavit upon the defendant: N/A. 4. Related claims pending: None. 5. Complete either (a) or Co) .... file praacipe a copy of a. Date and manner of service of the not~ce of mtent~on to which is attached: b. Date Plaintiff's Waiver of Notice was filed with the pwthonotary: Executed on September 30, 2004; filed simultaneously with this praccipe. Date Defendant's Waiver of Notice was filed with the pwthonotary: Executed on September 30, 2004; filed simultaneously with this Praecipe. Respeclfully submitted, ~elissa L. Van Eck, Esquire Attorney ID No.: 85869 7800 A Allentown Blvd, Suite B Harrisburg, PA 17112 (717) 540-5406 Det :_ t O-I,%i)zl CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Adrienne R. Tappan, Plaintiff in the above- cai~ioned action, hereby certify that a m~e and correct copy of the foregoing Praecipe to Transmit was served upon Justin S. Tappan, by depositing same in the United States mail, first class, on October 13, 2004 addressed as follows: Justin S. Tappan 45 S. 39~ Street Camp Hill, PA 17011 Melissa L. Van Eck, Esquire 7800 A Allentown Blvd, Suite B Harrisburg, pennsylvania 17112 Telephone: 717-540-5406 Attorney for Plaintiff IN THE cOURT OF cOMMON PLEAS Of CUMBERLAND cOUNTY STATE OF ~~ PENNA. VERSUS DECREE IN DIvoRCE AND NOW,~ ' 2J3~4--' ~T ~S ORDERED AND -, PLAINTIFF, DECREED THAT ~ -, DEFENDANT, ARE DIvoRCED FROM THE BONDS OF MATRIMONY. THE CouRT RETAINS jURISDICTION OF THE FOLLOWING CLAIMS wHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL oRDER HAS NOT YET BEEN ENTERED: ATTEST: __ 'HONOTARY