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HomeMy WebLinkAbout05-1923 ~ v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV NO. ()(' - /<1;2:S C:'Ll ~ vY\ Candice A Clepper, Plaintiff Mark R Clepper, Defendant CIVIL ACTION. LAW IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims se forth in the following papers, you must take prompt action. You are warned that if you ail to do so, the case may proceed without you and a Decree in Divorce or annulment m y be entered against you by the Court. A judgment may also be entered against you f r any other claim or relief requested in these papers by the Plaintiff. You may lose mo eyor property or other rights important to you, including custody or visitation of your chit ren. When the ground for the divorce is indignities or irretrievable breakdown f the marriage, you may request marriage counseling. A list of marriage counsel rs is available in the Office of the Prothonotary at the Cumberland County Court ouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROP LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULME GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. I YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 / !~~.. James A. Miller, Esqui e Attorney for Plaintiff Candice A Clepper, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA IA NO. ()!: - jq;X}. (!/'uL'-r-'VU Mark R Clepper, Defendant CIVIL ACTION. LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Candice A Clepper, who currently resides at 19 West ain Street, Upstairs, Newville PA 17241-1410. 2. Defendant is Mark R Clepper who presently resides at 315 Pin dale Road, Carlisle PA 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for a least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 152002, in Cumb rland County, Pennsylvania. 5. parties. There have been no prior actions for divorce or annulment betwe n the 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed ServiGes of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and hat the Plaintiff may have the right to request that the Court require the parties to parti pate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated h rein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a de ree dissolving the marriage between Plaintiff and Defendant; Respectfully Submitted, Miller Lipsitt LLC r i J "I^---" By: #---i'l/UL James A ~iller, Esquire Attorney for Plaintiff 2157 ~rket Street CalJ.l-PHill, PA 17011 (717) 737-6400 Candice A Clepper, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV NIA NO. CIVIL ACTION - LAW IN DIVORCE Mark R Clepper, Defendant VERI FICA TION I verify that the statements made in this Divorce Complaint are true and corr ct. I understand that false statements herein are made subject to the penalties of 18 P .C.S. S4904 relating to unsworn falsification to authorities. DATE: L( 1,.:210 ) , ~ {Q '- - --C:) \h- e - .:t:::. V, '{"- ....:z 0 /---J "'Q ~ -0 ~ ~ +-- J..... o ~~~ r-> c;:~ ,:..,.:. <;,.i" ('" ~ :v"" ~'''''l _,4' rnp::- ?:J "1':J r.n ;; ~::::\~~ -0 ~i"") ~l.~ -:... "?~1 ::2\ '-:"? U1 ~~~ .r;- G Candice A Clepper, Plaintiff In the Court of Common Pleas Cumberland County, Pennsylvania v. No.: 05-1923 Civil Term Mark R Clepper Defendant Civil Action - Law In Divorce ACCEPTANCE OF SERVICE I, Michael A. Scherer, Esquire and O'Brien, Baric & Scherer, hereby accept service of the divorce complaint filed to the above term and docket on April 14, 2005, on behalf of Defendant, Mark R Clepper. Date: Ilpr; 1 If 201: MiCh~~~Sq. O'Brien, Baric & Scherer 19 West South Street Carlisle, P A 17013 (") r:::? ,_..~ ,::;;':- c.n ~ -,-.'-' 1 (...~, o --n .--\ --Y--r", r(~t~:'~ i"') ):(-' --:1 ::::,~ - , l..;-: ..- ..... ~IILL/2005 16:15 7177375355 MILLER LIPSITT LLC PAGE 02 Candice A Clepper, Plaintiff IN lliE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. - NO, 05-.1923 Civil Term Mark R Clepper, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENt 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 14, 2005 and servios was obtained upon the defendant servicF!! was obtained upon the defendant by defendants counsel accepting service thereof on April 19, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. J. I consent to the entry of i:I Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I m;!y request that the Court reQuire that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised. I do not request that the Court require that my spouse and I participate in counseling priof to a divorce decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject tn the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to authorities. Date: 7-/,:} Lf fo S ~~;./ {lL11I8 ndice A cre e o ~; r--:t n ~ :::t1 ~ '-- c:::: \.~'~ ",) '...:., -;:::. v' (..rI ~lf22/2005 16:15 71 77375355 MILLER LIPSITT LLC PAGE 04 Candice A Clepper. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO_ 05-1923 Civil Term Mark R Clepper, Defendant CIVIL ACTION. LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on April 14, 2005 and service was obtained upon the defendant service was. nhtained upon the defendant by defendants counsel accepting service thereof on April 19, 2005. 2, The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) dayS have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final D~l,;ree in Divorce after service of notice of intention to request entry offhe decree. 4. 1 have been advised of the availability of marriage counseling, and understand that I may requel'lt th:<it the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised. I do not request that the Court require that my spouse and I partiCipate in counseling prior to a divorce decree being handed down by the Court_ I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the pe""ltias of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: 7 jdL/j oS i!tul p (~ ar1<. R Clepper o c: ....., C:::::'l t;.:;:_) <';'.01 ~:;;: \".. N -l c..) en ~11<L/2005 16:15 71 77375355 MILLER LIPSITT LLC FAGE 05 Candice A Clepper, Plaintiff ; IN T1iE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : v, NO. 05.1923 Civil Term Mark R Clepper, Defendant CIVIL ACTION. LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RE9!1EST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c\ OF THE DIVORCE CODe 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 tt\f:l decree will be 56nt to me immediately after it is filed with the prothonotary. I verify that the statements made herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to UnWorn falsification of authorities. Dam:/-J'-/~oS /1/aJ: f: L~ 'Mark R Clepper o <;~. ,..., g t;;..n (_.,~ ::~;~ N ....... ~<: _4 --< o -" c., 0'" - ..----- '-"'~L(LVtJ':J lb:15 7177375355 MILLER LIPSITT LLC PAGE 03 Candice A Clepper, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYlVANIA v, NO, 05-1923 Civil Term Mark R Clepper, Defendant CML ACnON . LAW IN DIVORCE WAIVER OF NOTICl! OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c} OF THE DIVORCE CODe 1 , I consent to the entry nf 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 nol be divorced until a divorce deoree is entered by the Gaurt 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Uate: '::f--~l{k)<; ~ ~~;4ftCcrIO ~d'ce A Cle r (~) c, "" ;;: C) <;.::'.q -.-~ r,j --.; Candice A Clepper, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1923 Civil Term Mark R Clepper, Defendant CIVIL ACTION. LAW IN DIVORCE CERTIFICATE OF SERVICE I, James A Miller, Esquire, hereby certify that I have forwarded a copy of the foregoing Praecipe to Transmit Record to the person(s) and in the manner and on the date so indicated below. Date: ~ ' ;<. 1- , /)..CC=) United State~irst Class Mail Michael A. Scherer, Esquire O'Brien, Baric & Scherer Law Offices 19 West South Street Carlisle, PA 17013 L') -.J - Candice A Clepper, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-1923 Civil Term Mark R Clepper, Defendant CIVIL ACTION. LAW 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(c) of the Divorce Code. 2. Date and manner service of the Complaint: Defendants counsel accepted service of a CERTIFIED COPY OF THE COMPLAINT IN DIVORCE on April 19, 2005. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: July 24, 2005 by Defendant: July 24, 2005 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: by Defendant: 4. Related claims pending: There are no related claims pending. Respectfully Submitted, Miller Lipsitt LLC / By: James A iller, Esquire Attor for Plaintiff Market Street Camp Hill, PA 17011 (717) 737-6400 p =2 (...) 0) "-' C:;) => w'-, 2=: j..... i'~ -.J T'> ,.,~ if.:+: :+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ',-+ '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , .. , .. , +::+:;Ii :+: ;Ii , ;Ii if. ":ti:+:+: ;Ii :+:;j.; if. :+: if.:+::+:Of.:+: if. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Candice A Clepper Pl~inriff= VERSUS M"rk R rl"pp"r n~f=~nn~nr AND NOW, PENNA. No. 05-1923 DECREE IN DIVORCE ~:J ~ l/:JIJ/'M. ,~, IT IS ORDERED AND DECREED THAT Candi~" A f"l"pp"r , PLAINTIFF, AND M:=trk R ("l~pp~r , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. Cf:f.:+: Cf +. +'f . . . . . . , . . . , , . , . . , . . . , , . , . . , , . . . . . , . . , , . , . . , , . . , . , . . . , . . , . . . . . . . , , . , . . , . , , . , 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; NONF. B . . . , , . . , . . . . , . . , . . , . , . . if. if.Cf +. Cf +:if.+ +:+ +. +.+ if.++: Am>Tj?~.~ ( ~ PROTHONOTARY Cfif.Cf+: ,.. , .. :tiif.~ if. :t'if.if.+ Cf +if.'f .. , if.:ti+ + 'f'+if.if. :tiCf+: ... J. ~ fr ff ~ ~ 5<7>P wJr r r' ~ 41 -f"? so.Jb '- . ~. ' .... 'f.' ,.. -. '