The URL can be used to link to this page

Home My WebLink About05-3843 JACOB BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. WANDA BURKEPILE, Defendant : CIVIL DIVISION LAW : DIVORCE COMPLAINT L..,... : NO. oS - JPI.J3 (3'od 1"iI2-~ 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 rellef 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A llst of marriage counselors is available in the Office of the Prothonotary at One 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 ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIllS 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 South Bedford Street Carlisle, PA 17013 717-249-3166 JACOB BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : CIVIL DIVISION LAW WANDA BURKEPILE, : DIVORCE COMPLAINT Defendant : NO. COMPLAINT UNDER SECTION 3301 (D) OF THE DIVORCE CODE 1. Plaintiff is Jacob Burkepile, who currently resides at 1936 B Fry Loop Avenue, Carlisle, Cumberland County, Pennsylvania since 1976. 2. Defendant is Wanda Burkepile, who currently resides at 70703 Carlisle Pike, Lot #54 Carlisle, P A 17013 since approximately a year. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and the defendant were married on February 16,2000 in Cumberland County, Pennsylvania 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither party is a member of any branch of the military. 7. The marriage is irretrievably broken. 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. 9. Plaintiff requests the court to enter a decree in divorce. Respectfully submitted, ~~ cob urkepil 936 B Fry Loop Avenue Carlisle, PA 17013 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g 4904, relating to unsworn falsificatio to a ri . s. Date: 7'J.J.'~ ~ 1:~ ...... C> ~ & ~ ~ft ~ ~ i t....., (~ (:i ~.:.; -T/ ';;";1 c., =;! i'-ii , <, r>? I',) - g JACOB BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYL VANIA v. WANDA BURKEPILE, Defendant : CIVIL DIVISION LAW : DIVORCE COMPLAINT : NO. 0 S- - J ~ 41 NOTICE If you wish to deny any of the statements set forth ill this Affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served 011 you or the statements will be deemed admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF TIlE DIVORCE CODE I. The parties to this action separated on October 2000 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: ?-,;JDl-o S" 1.,-04-.1- Plaintiff! C\ .....' c-;J <:>' cJ'l :-, ,c-,;, -\::' ~- ..,). ~ o Cf"' JACOB BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. WANDA BURKEPILE, Defendant : CIVIL DIVISION LAW : DIVORCE COMPLAINT : NO. OS"'-"SS'''r3 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (C) AND ~ 3301 (D) 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 in do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divor,ce 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 lthe penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: ")~tfld~(JS 7 OJ t.J ~ f".....::'> C:::' ,-:;., ::",:.l CI cr. - JACOB BURKEPILE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v. WANDA BURKEPILE, Defendant CIVIL DIVISION LAW : DIVORCE COMPLAINT : NO. 0 5'- 'J 8' /..{ ') COUNTER-AFFIDAVIT UNDER ~ 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decret~. (b) I oppose the entry of a divorce decree because ( Check (i), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, ~ must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If! fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be tmable thereafter to file any economic claims. I verify that the statements made in this counter-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: Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER- AFFIDAVIT. ~., '-,'. \,,', .;-'tl < 'i'-- " JACOB BURKEPILE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WANDA BURKEPILE, Defendant CIVIL DIVISION LAW DIVORCE COMPLAINT NO. O~-- 3~ '0 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 9 3301 (d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: A'< 4,-< 5 +( '--&<7'- via Personal Service or Certified Mail. 3. (b)(1) Date of execution of the affidavit required by S 3301 (d) ofthe Divorce Code: 71<~s:-(2) Date of filing and service of the plaintiff's affidavit upon the respondent: 'i J..; /0 j- 4. Related claims pending: None. 5. (a) Date and manner of service of the notice of intention to file praecipe to Transmit Record, a copy of which is attached: ifllf'/&s- ; or (b) Date plaintiff's Waiver of Notice was filed with the prothonotary: 7122(05- (c) Date defendant's Waiver of Notice was filed with the prothonotary: t{~" Attory r plaintiff ;--.."..:1 ;~ I::::;.:': S,l ", CO c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + + + + + . , + + ;r: + . . . . . + . . + . . + . . . . + . + . . + . . . + . . . . . . + . . . . . . . + . . + + + + . + + + + + ++:+:+ :+ ~:t::+:+:+::+:+: ~:+:+ + . :+:+~:+:++:+ ++. ++ . .. :+:+~+:~ '+' :+:+.:+ ~:+. ~+:+:++:+:++~+:++:+:+.++.+++++:+:+~ + + + + . + + . + + + + + + + + + . + . + + . + . + + + + + + + + Of. :+ :+ +. '*' + +. + + + + + :+ '+' 'to + + + :+ :+ + 'j"+' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. JACOB BURKEPILE No. 05-3843 VERSUS WANDA BURKEPILE DECREE IN DIVORCE AND NOW, ~,~~ Z <10J/ , IT IS ORDERED AN D /....r , . DECREED THAT Tl\rnR BTTRUPPTlv , PLAI NTI FF, AND WANDA BURKEPILE , 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; tJ 0 tJt . PROTHONOTARY 'i' .- ++++:++++:+:++'f+:+ +:+:+ + 'I' '+; 'I' + ++++++:+'1'+ +:+++:+ :+ 'to '+:+ Of 'f + + + + + + . + . + + + + . + + . . + + + + + + + + . + . . + . . + . + . . . + . . . . . . . + . . . . . . . . . + . + . + . J. h~ ~ ~ JrP"{>c/ ff1 ~ ~p() ~el.eI "- ..'!.", , A