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Home My WebLink About04-5397 RYAN S. waIPPERMAN Plaintiff IN TIlE COtJRT OF COMMON PLEAS OF ctJMBERLANIl CotlNTY, PENNSYLVANIA vs. TRACY L. WHIPPERMAN, Defendant NO. 01./- S397 Ciui.L ~~ CIVIL ACTION - LAW 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 IIlOney or property or other rights important to you, including custody or visitation of your children. 1ihen 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 at 1 Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMEN'l' IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOtlLD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FOR'l'H BELOW. 'l'HIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOtJT 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 S. Bedford Street Carlisle, PA 17013 (800)990-9108 or (717)249-3166 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'l'Y, PENNSYLVANIA NO. OLJ - 5391 (!1'ui.L ~~ CIVIL ACTION - LAW DIVORCE RYAN S. WHIPPERMAN Plaintiff TRACY L. waIPPERMAN, Defendant COtlN'l' I COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Ryan S. Whipperman, who currently resides at 303 Pennsylvania Avenue, Camp Hill, Cumberland County, PA 17011 and has so resided since December 2003. 2. Defendant is Tracy L. Whipperman who currently resides at 8 Kenworthy Avenue, Glens Falls, NY 12801-2403 and has so resided since April 2004. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six IIIOnths immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 3, 1999 in Cumberland County, pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The parties have been separated since April 25, 2004. 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. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. COUNT II REQUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301 (d) OF THE DIVORCE CODE 9. Paragraphs 1 through B are incorporated herein by reference. 10. The marriage of the parties is irretrievably broken. 11. In the event a Divorce by consent is not earlier entered into, after two (2) years have elapsed from the date of separation, Plaintiff intends to file his Affidavit of having lived separate and apart for at least 2 years. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the Court require the parties to participate in such counseling. WHEREFORE, once two (2) years have elapsed from the date of separation and Plaintiff has filed his Affidavit, Plaintiff respectfully requests that the Court enter a Decree in Divorce, pursuant to Section 330l(d) of the Divorce Code. COUNT III CLADI FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 13. Paragraphs 1 through 12 are incorporated herein by reference. 14. Plaintiff and Defendant are the owners of marital property which is subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court equitably distribute the parties' marital property. YOFFE , YOFFE, P . C . ByN~/J7~ JEFFREY N. YOFFE, ESQUIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 jyoffe@verizon.net llji'::2/':::"H ~;O:: PH FF.':H: {7111:;7:'-1~1~ "!"olf" .mJ "foUa, ?C'. T0: ;'.i':-~108 hro..:;:;; r)(l4 (,r ('C4 RYAN S. WBIPPBafAN P1.a1.ntiff IN 'rHJ: COURT 01' CXM<<lN PLZAS OIl! ~RLAND COON'lY, PENNSYLVANIA VS. NO. TRACY L. WHIPPZRMlIN, Defendant CIVIL ACTION - LAII' DIVORCE VBRIFICM'IOIII I bereby state that I lIIII an adult individual ",,"0 is authorized. to make this verification and that the facts set forth in the f~ing' C<lap'~;nt are true to the best of my kDow1eclge, iDfozmatioD, and. 1oel1ef. I underst:anc1 that fal_ stats8lts herein are made subject to the peDalties of 18 Pa. C.S. S4904 relatinq to unsworn falsification to aut:hl:lrities. Dated.: o...\......... "l.1..~.I. \ 1...00,"\ ~.~ , 0 --- 1- 'i R.J ~ ~ ~ ..0 8 C> . . "- '-- 0 () D I () n ..... ~ en ' " ~ ~.- c-, # I ~- Ii"" -v .. .. r, :r!." "' ," . c.... f) :b -; i1lf'''':' (N r- r>.' -r..rTl ~ "';.' -.l -.'i? .. " c'C) ~ .. . . I J :~'I ,', '.' I "l_J - . .~(' r.::.. l. \.- :.....)In " .. I",) ~..' ..i fA ...... .0 c C -< RYAN S. WHIPPERMAN, Plaintiff v. TRACY L. WHIPPERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-5397 CIVIL TERM : CIVIL ACTION .. LAW : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Enter my appearance on behalf of the Defendant, Tracy L. Whipperman. Papers may be served at the address set forth below: Date: November 8, 2004 Diane G. Radcliff, Esquire I.D. No. 32112 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 , . _.~ , i. '.... ~ (' .,' _.-:' C) F 1."':-' f.,' :< '" <::::) <::::;:) ..c:- o -i) :;;~: o -....: I \.D U -;.... -'- :rJ fli ::n r'-" :Bf9 S=~ (1, ~;~~ :Ii ....C) :5r:(1 ;;;--1 i, -< r:y -z RYAN S. WHIPPERMAN' Plaintiff IN THE COUR~' OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. J,ro'l- 531'1 C-L VI 'r vs. TRACY L. WHIPPERMAN', Defendant CIVIL ACTIO~' - LAW DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complair.J.t on behalf of Tracy L. Whipperman and certify that I am authorized to do so. Date. \0/.2J1 Jv,! LIFF, ESQ. Trindl Road , PA 17011 ( r---.J = Cl c:;> ..e- II ::it: ::-:1 0 _.L" ~ fl1--' r- t -17"-1 \D :uy C) -.' ( ) :J:r;' :;I~ :+~ - ~... _.":,~ ~;C) '2 ('SIn ~_:-l 1'.) ~:t; .- -.... '. RY AN S. WHlPPERMAN Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY. PENNSYLV ANIA vs. ; NO. 04-5397 CIVIL TERM TRACY L. WHIPPERMAN. Defendant : CIVIL ACTION - LAW : DlVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under g3301(c) of the Diyorce Code was filed on October 27, 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 of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verilY 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. g4904 relating to unsworn falsification to authorities. Dale: ~\"/'K ~4 RYi S. W IPPERMA1' C) ~d , ,,-, J c.) '" RYAN S. WHIPPERMAN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 04-5397 CIVIL TERM TRACY L. WHIPPERMAN, Defendant : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9330I(c) of the Divorce Code was filed on October 27, 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 ofa final Decree in 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. 94904 relating to unsworn falsification to authorities. Date:~y)~ ~~Rl;)~I~" TRACY L. IPPERMAN RYAN S. WHIPPERMAN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA vs. : NO. 04-5397 CIVIL TERM TRACY L. WHIPPERMAN, Defendant : CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330I(c) OF THE DIVORCE CODE I. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 . 1 yerifY 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. g4904 relating to unsworn falsification to authorities. Date: ~\..\ <;; ~~ \ v-- RY . W PPERMAN r_.7l I.:.::-~) ',,;:'~.' cf' ..:l,~ :;,r;.' :;d I .....0 (",,) \..0 RYAN S. WHIPPERMAN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 04-5397 CIVIL TERM TRACY L. WHIPPERMAN, Defendant : CIVIL ACTION - LAW : 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in 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 unsworn falsification to authorities. Date: 42'f /0 6 ~~~.~~~~<<\'-~ TRACY HIPPERMAN VB. : IN 'l'HE COURT OF COMMON PLEAS OF CUMBERLlIND COUNTY, PENNSYLVANIA NO. ),(/,)'(- 5Jf7 c,-;;tl RYAN S. WHIPPERMAN Plaintiff TRACY L. WHIPPERMAN, Defendant : CIVIL ACTION - LAW DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint on behalf of Tracy L. Whipperman and certify that I am authorized to do so. D'''.. \O/,Zq Jo,! ( I ,__.. 1..C) 65- a?- ,-"\ c"," '" <;,:;:l <;:,:,) ..t::- IOU ;'r. ~< f'..~'i t .. IN TIffi COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA ) COUNTY BRANCH Ryan S. Whipperman Plaintiff ) ) CIVIL ACTION - LAW vs. ) ) ) NO. 04-5397 CIVIL TERM Tracy L. Whipperman Defendant ) PRAECIPE TO lRANSMIT TIIE RECORD 1. Grounds for divorce: x Section 3301(c) of the Divorce Code Section 3301 (d) of the Divorce Code 2. (a) Date complaint filed: October 27, 2004 (b) Date of service of the complaint: October 29, 2004 (c) Ifservice 30 days after date of filing, date complaint reinstated: (d) Marmer of service of the reinstated complaint: Certified mail, restricted delivery to and return receipt signed by defendant. First-class mail - not returned, certified mail refused, 15 days have elapsed Date of mailing: Date certified mail refused Personal service by Sheriff and/or Deputy Sheriff Personal service by competent adult other than Sheriff (Affidavit attached) x Acceptance of service (copy attached) By publication pursuant to Order of Court (Copy of Order attached) . 4. 5. 3. (a) Affidavit of consent required by Section 3301(c) of the Divorce Code: Date of execution: Plaintiff 3-3-2005 Defendant 2-24-2005 Date of filing: Plaintiff Defendant 2-25-2005 (herewi th) (herewi th) (b) Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: Date of execution: Date of service upon defendant: Related claims pending: None (a) Date of service of the notice of intention to request entry of divorce decree, copy of which is attached: Manner of service of notice of intention: Certified mail First-class mail Personal service Acceptance of service Publication pursuant to Order of Court Other (b) Date waiver of notice of intention to request entry of divorce decree was filed with the Prothonotary: By plaintiff: By defendant: Herewith 2-25-2005 VERIFICATION I verifY that the statements made in this praecipe are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. By .y;;;; ;;'~~c o Jeff ey. N. ~ fe, Esq. Attorney for Plaintiff Date: 3-8-2005 . . RYAN S. WHIPPEIUUN Plaintiff I IN '1'Bl!l COURT 01' COMMON PLEAS 01' I C'llJIBI!:RI.AND COlJN'1'Y. PENNSYLVllNIA vs. I : RO. TJIACY L. WHIPPEIUUN. Defendant I I CIVIL ACTION - LAW I DIVORCE ACCEPTANCE 01' SERVICE I accept service of the Divorce COIIIPlaint on behalf of Tracy L. Whipperman and certify that I am authorized to do so. ....., 10 J;2fj /61 ( '48 ClUIIP LII'I', ESQ. Trindl Road , PA 17011 n ...., ~ = ~ = ...,. -ofn :z: ~:n n11'1l 0 Z:<.l' <: "",hi "T , &, ,'. ~6 ~tJ \.0 ". 9~ ~c: :% -0 -rn $c s> ~ ~ N ~ .s:- '< C7 -", ().') .--' c::::> ~], () ""1'\ --' t,O +i'f.'f.+i:+::+::I: + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +,. + + + + +i + ~ +i + +i ~+i+i+i+++i++i+++++:+:~++i+++++'f.++++++++++~'f.++:I:'f.++++:I:+++++'f.+++++++++++++++++++~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +++'f.++i+++'f.~+++'f.++++++++++++++++++++++++++++++++++++++++++++++++++~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Ryan S. Whipperman NO. 04-5397 VERSUS Tracy L. Whipperman DECREE IN DIVORCE AND NOW, (ft~ ~/o:')tfA.P.. dot>(, IT IS ORDERED AND (~ DECREED THAT Ryan S. Whipperman , PLAINTIFF, AND Tracy L. Whipperman , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOI_LOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD II'" THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ~/)~~ By ATTEST: J. ~~~~"O,OOOO,^"~ /I?~ ~v ~ 1'7/":?","?jA'",, ," #/4 ~'1 ",.- J4p' f'V ;U ,. , . $/ ' ._. L ~I " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN S. WHIPPERMAN, Plaintiff : NO. 04-5397 CIVIL TERM : CIVIL ACTION v. IN DIVORCE TRACY L. WHIPPERMAN, Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above captioned Divorce Action, hereby elects to retake and hereafter use her previous name of Tracy L. Bean. This election is made pursuant to the provisions of 54 P.S. 9704. ~~ \U\^-~~<<Y'C~ TRACY 1::. HIPPERMAN ~~~ TRACY L. 'B.~N COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss: On the 24th day of February, 2005, before a Notary Public, personally appeared Tracy l. Whipperman known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal ~.~~ NO!5Y ic t-( COMMONWEALfH OF PENNSYl VANIA Not,irial Se31 ] Die.ln::> C.:. ;-~'<fj()iif \!8t?tV P:_~blic C::wt\ i-'f)'-"', ",,:t:,,-r'c'yJ \,ounty ;,,1\.' 'WOB L_.. cecc",... ~\\ -. <Ii' }-' ~ -'" "'\ \..--" ..--J ...() (.' ~ ~ ~ ~~ ~ '- b ~ t