Loading...
HomeMy WebLinkAbout01-2953SHERI A. RIPLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : No. 0,- DOUGLAS A. RIPLEY, = COMPLAINT IN DIVORCE Defendant : NOTICE TO DEFEND AND C~IM 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 Courthouse, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOUMAY 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. COURT ADMINISTRATOR Cumberland County Court House i Courthouse Square, 4th Flr. Carlisle, PA 17013-3387 ... By:FRIEDMAN ~~.C. Richard ~. Friedman, Esquire 600 N. S~cond St., 5th Flr. P. O. B°~ 984 Harrisb~.g, PA 17108 (717) 23~-8000 SHERI A. RIPLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. DOUGLAS A. RIPLEY, = COMPLAINT IN DIVORCE Defendant COMPLAINT UNDER HECTION 33OX(e! ~ BECTXON 33OX(dj OF THE DIVORCE CODE 1. Plaintiff is Sheri A. Ripley, who currently resides at 119 Bunker Hill Rd., New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is Douglas A. Ripley, who currently resides at 41 Stayman Way, Box 271, Littlestown, Adams County, Pennsylvania 17340. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 9, 1993, in Harrisburg, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of eighteen (18). 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on July 1, 1999. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, FRIEDMAN & ~v~, P.C. R~chard Fr 600 N. ~econd Street Penthogse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 RSF/bp:divorce\ripley.div I, Sheri A. Ripley, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsw°rnfalsificati°nt°auth°riti~~~R.~ SHERI A. RIPLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01-2953 Civil Term : DOUGLAS A. RIPLEY, : COMPLAINT IN DIVORCE Defendant : AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF DAUPHIN : Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Richard S. Friedman, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Douglas A. Ripley, by Certified Mail, Restricted Delivery, on May 18, 2001, as evidenced by the attached Certified Mail card./ __ Richard ~.~iedman,// Esquire Sworn and subscr~b~ to before me day of ~2002. NOTARIAL SEAL I BARBARA E. PALMER, Nol~ry Publk~ ~ Har~sburg, Dauphin County I My Commissi~ Expires May 23, 2005~ PS Fo~n 3811, Ju~ 1~ D=n~e~c Return Recelp~ SHERI A. RIPLEY, = IN THE CO~T OF CO~ON PLUS Plaintiff = CUMBERLAND CO~TY, PENNSYLV~IA v. = NO. 01-2953 civil TeN ~UG~S A. RIPLEY, ~ COMP~INT IN DIVORCE Defendant = AFFIDAVIT OF CONSI~ 1. A Complaint in Divorce under Section 3301(¢) of the Divorce Code was filed on May 15, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. S 4904 relating to unsworn falsification to authorities. SHERI A. RIPLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2953 Civil Term DOUGLAS A. RIPLEY, : COMPLAINT IN DIVORCE Defendant : WAIVER OF NOTICE OF INTENTION TO REQUEHT ENTRY OF A DIVORCE DECREE UNDER 3301fCJ AND 3301(DJ OF THE DIV0~CE CODR 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division 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 filed with the Prothonotary. 4. 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. S 4904 relating to unsworn falsification to authorities. Date:~~~__ ~ SHERI A. RIPLEY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2953 Civil Term DOUGLAS A. RIPLEY, : COMPLAINT IN DIVORCE Defendant : PP~a-ECIPE TO TRANSMIT P-ECORD 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(c) of the Divorce Code. 2. Date and manner of service of the complaint: By Certified Mail, Restricted Delivery, on May 18, 2001. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, June 3, 2002; by Defendant, May 29, 2002. 4. Related claims pending: There are no related claims pending. 5. (a) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: June 7, 2002· (b) Date Defendant's Waiver of Notice was filed with the Prothonotary: June 7, 2002. Richard ~' Friedman, Esquire Attorne/for Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ' PENNA. SHERI A. RIPLL'Y, DECREE IN DIVORCE AND NOW, ................... /./.~. ., ~lC~..~.0.Q:~, it is ordered and ~ decreed that ............. 5..~..~...A....~?...L~'. ...................... plaintiff, and ............... .~x~..C'..~.~.. A...~..p..L~/ .......................... 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; ............ i~o~o~;~;' '