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HomeMy WebLinkAbout05-2152 Johnson, Duffie, Stewart & Weidner By: David W. DeLuce J.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff CHRISTINE LINE LEPLEY, Plaintiff IN THE COURT OF COMMON PLE S OF CUMBERLAND COUNTY, PENNSYL ANIA NO.05'-;215'.:t CIVIL ACTION - LAW v. MICHAEL T. LEPLEY, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set fort in the following pages, you must take prompt action. You are warned that if you fail to do so, th case may proceed without you and a decree of divorce or annulment may be entered against ou by the court. A judgment may also be entered against you for any other claim or relief reque ted in these papers by the Plaintiff. You may lose money or property or other rights important 0 you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the ma riage, you may request marriage counseling. A list of marriage counselors is available in the 0 ice of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROP RTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRA TED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABL TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER L GAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 CHRISTINE LINE LEPLEY n/k/a CHRISTINE L. LINE, IN THE COURT OF CCM10N PLEAS OF OJMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 05-2152 CIVIL TERM vs. MICHAEL T. LEPLEY, Defendant 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 3~R*XE~ix*1 of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant's counsel on June 10, 2005 and filed on June 30, 2005 with this Court. . 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section by the defendant DE,cember 18, by the plaintiff 7005 November 30, 2005 3301 (c) of the Divorce Code: B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Re~ated claims pending: Non~' 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code Waiver of Notice signed by Plaintiff on November Waiver of Notice s' nEed b DE:fendant on DE'cember l 2005 and filed =ntly hncwith. 2005 and filed =ntl hn:with. o ~ """ g i:J-S (:J ., ~~ ,11--' ,- -Or'<': ~_!, _1 C:,~:I '_:~ (J':'I '+r, ::'~~~; ~:1rn ::-::~ :':.::2 o 1"':1 " "''' -, :T! ~) 0) \..0 CHRISTINE LINE LEPLEY n/k/a CHRISTINE L. LINE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 05-2152 CIVIL TERM v. CIVIL ACTION - LAW MICHAEL T. LEPLEY, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on or about April 26, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. WAIVER OF NOTICE OF INTENTION TO REQUEST 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 the Decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made above 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 / I-gO-OS' u{fi~It!~ Christine L. Line, Plaintiff :263617 (') "-' 0 = ~~:~ ,:;::l -il c.n C'J .-j ,-. :t:-r, \: rq f11~1 '" :"r;bI:; r" -.l ':Cf; :" '"'" ; ; :3C ('~~ (~) rn I)? -..1 .~-'" c...) ~'D 0::> .< CHRISTINE LINE LEPLEY n/k/a CHRISTINE L. LINE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2152 CIVIL TERM v. CIVIL ACTION - LAW MICHAEL T. LEPLEY, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on or about April 26, 2005. 2 The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service 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. WAIVER OF NOTICE OF INTENTION TO REQUEST 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 the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made above are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaC.S. S 4904 relating to unsworn falsification to authorities. 1 Date: /1.-/ i S b-DO 5 I I :263617 ,,-...:'i = C? c.r< C) f'n " rv -J C) -'.\ .-\ ::C-n p1-p-" -r1\"'T': ~~;_:.:~( -~.., -0 ::~ ~~~,.fi, r:-? c:h ::< c.). co ~ Johnson, Duffie, Stewart & Weidner By: David W. DeLuce J.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff CHRISTINE LINE LEPLEY, IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYL ANIA Plaintiff NO. CIVIL TER v. CIVIL ACTION - LAW MICHAEL T. LEPLEY, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Christine Line Lepley, by and through her alto neys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint again t the Defendant, Michael T. Lepley: 1. The Plaintiff is Christine Line Lepley, an adult individual, Northgate Drive, Camp Hill, Cumberland County, Pennsylvania 17011. Security Number is 211-58-9757. residing a 125 Plaintiff's ocial 2. The Defendant is Michael T. Lepley, an adult individual, residing at 827 Se uoia Drive, Harrisburg, Dauphin County, Pennsylvania 17109. Defendant's Social Security Nu ber is 337-76-9934. 3. The Plaintiff and Defendant were married on October 4, 2003, in Camp Hill, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonw Ith of Pennsylvania at least six months immediately prior to the filing of this Complaint. . 5. There has been no prior action for divorce or annulment of marriage bet en the parties in this or any other jurisdiction. 6. The parties separated on or about December 12, 2004. 7. Neither of the parties in this action is presently a member of the Armed Fo ces on active duty. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of marriage counseling a d she may have the right to request that the Court require the parties to participate in counseling WHEREFORE, the Plaintiff respectfully requests that your Honorable Court e ter a decree of divorce. Date: April 25, 2005 :249404 VERIFICA TION I, Christine Line Lepley, verify that the statements made in this Complaint in Divo ce are true and correct to the best of my knowledge, information and belief. I understand th t false statements made herein are made subject to the penalties of 18 Pa. C.S.A 94904, rei ting to unsworn falsification to authorities. Date: J..)-!)Ij- ()5 /. ) Christine Line Lepley Johnson, Duffie, Stewart & Weidner By: David W. DeLuce J.D. No. 41687 30 I Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff CHRISTINE LINE LEPLEY, IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY, PENNSYL ANIA Plaintiff NO. CIVIL TER v. MICHAEL T. LEPLEY, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDA vir CHRISTINE LINE LEPLEY, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and under tand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse nd 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 penalties of 18 Pa.C.S. 94904, relatin to unsworn falsification to authorities. Date: 2-}-//IY-05 ) Christine Line Lepley .~ (~ 1"'" --- .---c> 5>- o ~;, [rj,~Y ..~.c. (Il;~, -<~ """ ::;C' r,,"'-<'. ~' ~..-,. ;z.-' ' jJ;'" C,. -'-,;' .,;:\ ::.< .-S> o 9 '"' , ;..:; :~ ....' = "'-~ u' ?;j :;:0 r" <5' ~ ~ .-l ff1~ "",en -fIt) (~ ).. ~.-~ \) ::c:',", ()~.- ._0 ,~.."rn ';-~:\ :~) :.<: ~. '2 o v) - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Christine Line Lepley Plaintiff Vs File No. 05-2152 IN DIVORCE Michael T. Lepley Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] ----X- prior to the entry of a Final Decree in Divorce, or _ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of Line , and gives this written notice avowing her intention pursuant to the pr9fisi~. J04'/) 1--../J Date: Mav27,2005 ~~J4/) Signature lJ ignature of name being resumed Chrfshn€. 1-.. Line- COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On th~ day of , 2005 , before me, the Prothonotary or the notary public, personally ap ared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL PROTHONOTARY. NOTARY PUBUC CAIlUSI.E CUMBERlAND COUNTY COURT HOUSE MY COMMISSION EXPIRES JANUARY 2. 2006 ?V 8 ~ -0 It '-.I s:L. () ~ ~'* - :.-:;.1 ~ .- iT. " , -'-1 ,.'j I:> .......; t;;- --c:. r- .- ~ - C-- .- <p C~ r,,:;, --.) Johnson, Duffie, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff CHRISTINE LINE LEPLEY, Plaintiff v. MICHAEL T. LEPLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-2152 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO REINSTA TE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Divorce Complaint filed on April 26, 2005 in the above-captioned action. Date: May 31, 2005 :251802 - ::':' -n t':':.' (...) (}i Johnson, Duffie, Stewart & Weidner By: David W. DeLuce J.D. No. 41687 30 I Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.. 05-2152 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CHRISTINE LINE LEPLEY, v. MICHAEL T. LEPLEY, Defendant ACCEPTANCE OF SER\J7CE I, Elizabeth S. Beckley, Esquire, attorney for Defendant, Michael T. Lepley, hereby accept service and acknowledge receipt of the Complaint in Divorce filed on April 26, 2005, and reinstated on June 1, 2005, by the Plaintiff in the above-captioned divorce action. I certify that 1 am authorized to accept service on behalf of Defendant. Date: Cr/(HJ) BECKLEY & MADDEN ~., BY: . Ii b ' . ec A orney I.D. # PO Box 11998 Harrisburg, PA 17108 Attorney for Defendant :242632-7 (') ,..., ~ <=> c: "'" ".- "" 1 ~~ <- ;:'gf" in; c::: '?;. ;b: :z: Z... (;.) ~ (j).,z",: 0 ;:;i': ~. C '<:. -0 ~~ )7'c~ :J:: Z ~. ...-::( ) >{:: - ."", ~ ., .~ z:- co - , Of'+' :+; :+ :+: + "" :+: :+ :+: :+ :+ :+ :+ :+ :+ '+' + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . . ++++ +++++++++ +++++++++++++++++ +++++++++++++++++++++++++++~ + . . . + + + + + + + + + . + + + . + + + . . + + . + . + + + + + . + . . + + + + + + + + + + + + + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY CHRISTINE LINE LEPLEY n/k/a PENNA. STATE OF 05- 2152 CIVIL TERM CHRISTINE L. LINE, No. Plaintiff VERSUS MICHAEL 1. LEPLEY , Defendant DECREE IN DIVORCE De.~..., 101'.3 IT IS ORDERED AND 2005 2.'1 AND NOW, . . . + . + + + + + + + . + + + + + + + + + + + + + + + + + + + + + . + + + + + + . . + + + + + + + + + + + + ~++++++++++++++++++++++++++++++++++++++++++++++++++ ARE DIVORCED FROM THE BONDS OF MATRIMONY. + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + ++++++++++++++++~ DECREED THAT CHRISTINE LINE LEPLEY n/k/a CHRISTINE L. L~N~LAINTIFF, AND MICHAEL 1. LEPLEY , DEFENDANT, 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; N:n::e ATTE fJ~ PROTHONOTARY 'l' ,+;of :+ :+ '+ '+ + J. J l~pP38 ',3 4tt; 9-l~71e.v ~7.I~ --P'JI~<LQ ~ OJ-.!'~7'e.\.V I,clo-;) -r3'(j\p3i) - ~QI "1/1 . . . .