Loading...
HomeMy WebLinkAbout01-2763 RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : 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 divoree 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 Prothonotary's Office, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : CIVIL ACTION - LAW : SANDRA IC SUPLEE, : NO. D/- : Defendant : IN DIVORCE COMPLAINT AND NOW, comes the above-named Plaintiff, RICHARD A. SUPLEE, by and through his attorney, CONSTANCE P.BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce fi.om the above-named Defendant, SANDRA K. SUPLEE, upon the grounds hereinal~er set forth. 1. Plaintiff is RICHARD A. SUPLEE, an adult individual, who currently resides at 8 Victor Lane, Mechanicsburg, PA 17050. 2. Defendant is SANDRA K. SUPLEE an adult individual, who currently resides at 9071 B Jonestown Road, Grantville, PA 17028. 3. Plaintiffand 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 Piaintiffand Defendant were married on September 8, 1990, in $onestown, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiffand 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 Plaintiffhas been advised of the availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiffavers that the grounds on which the action is based are that the marriage is irretrievably broken. 10. Plaintiffrequests the Court to enter a Decree in Divome. 2 WHEREFORE, Plaintiffprays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. Respectfully submitted, CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 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 unswom falsification to authorities. DATED: ~/J/4~ ~~ RICHARD A. SUPLEE ~ RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : CIVIL ACTION - LAW SANDRAK. SUPLEE, : NO. O1---o~7/~ ~to;( : Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, SANDRA K. SUPLEE, accept service of a copy of the Complaint in Divorce filed in the above-captioned matter. RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : CIVIL ACTION - LAW : SANDRA K. SUPLEE, : NO. 01-2763 Civil Term : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 7, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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 unswom falsification to authorities. RICHARD A. SUPLEE, Plainfif~ RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : CML ACTION - LAW ; SANDRA K. SUPLEE, : NO. 01-2763 Civil Term ; Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divome Code was filed on May 7, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divome 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 unswom falsification to authorities. RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : CIVIL ACTION - LAW : SANDRA K. SUPLEE, : NO. 01-2763 Civil Term ; Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C] OF THE DIVORCE CODE 1. I consent to the entry of a final decree ofdivoree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 tree 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. RICHARD A. SUPLEE, Plaintiff RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : : v. : CIVIL ACTION - LAW : SANDRA K. SUPLEE, : NO. 01-2763 Civil Term : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C~ OF THE DIVORCE CODE 4. I consent to the entry ora final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ill do not claim them before a divorce is granted. 6. 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 unsworn falsification to authorities. RICHARD A. SUPLEE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COI~T~, PENNSYLVANIA Plaintiff : : v. : CIVIL ACTION - LAW ; SANDRA K. SUPLEE, : NO. 01-2763 Civil Term : Defendant : 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(e) or 3301 (d)( 1 ) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance Of Service dated May 2, 2001. 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 August I0, 2001; by Defendant on August 10, 2001. (b)(1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the Defendant: 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 was filed with the Prothonotary: Waiver is being filed simultaneously with this Praecipe. (c) Date defendant's Waiver of Notice was filed with the prothonotary: Waiver is being filed simultaneously with this Praecipe. Respectfully submitted, CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-'/200 Attorney for Plaintiff INTHE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF ~~ PENNA. NO. n~_~-~ ~ VERSUS DECREE IN DIVORCE AND NOW, /~-'~j'~ -~-~ , J~8/ , IT iS ORDERED AND DECREED THAT R.]:C~JJ~D ~.. SLI~3T_~ , PLAINTIFF, AND ~ K. ~[]13'[,~, ,. 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; BY THE COURT: -~' . · A~ j. PROTHONOTARY