HomeMy WebLinkAbout06-1522?J I ?, efl f- - opki rn 6
?tRi n ti 4F : IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06- /S J .2
?nden? CIVIL ACTION-LAW
CHILD CUSTODY
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action within twenty (20) days after
this Complaint and Notice are served, by entering a written appearance personally or by
attorney and filing in writing with the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the Court without further notice for
any money claimed in the Complaint or for any other claim or relief requested by the
Plaintiff. You may lose money or property, or other rights important to you, including
child custody, or child visitation.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO 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 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
2 Liberty Avenue
Carlisle, PA 17013
Telephone: (717) 249-3166
COURT OF COMMON PLEAS
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COMPLAINT FOR DIVORCE
COUNTY, PENNSYLVANIA
In re: the Marriage of
Plaintiff
and// 11 gg ,f//
??l/lS I C TDkrnS
Defendant
Docket No.
The Plaintiff, A??YL9 Dn?)AS respectfully
declares the following:
1. Plaintiff's Residence: Plaintiff resides at
/OSl: Allyn, t4. A&i 316- .?r?hanics?u.?. 09 1:705r
[insert Plaintiff' address] and has-'been a resident of the
Commonwealth of Pennsylvania for rn.n Nrs [insert period of
residence in months and years].
2. Defendant's Residence: Defendant resides at
ab03 York & WrYf OYk A( /V59z
[insert D endant's address] and has been a resident of t? M.yS-
C n -° ---' for arS [insert period of
residence in months and years].
3. Marriage: On ?1 1 /Q ?Q R9 in
?jriliniay (city), ?1t?tnnG (county),
?I/,r61?aiA (state), the Plaintiff and Defendant married.
An offial copy of the marriage license is attached to this
COMPLAINT FOR DIVORCE.
4. Children: Plaintiff and Defendant have the following children
born or adopted into their marriage:
Name: hz ce '. ,risk ?R Date of Birth: l-S-aoO
Name:
Name:
Name:
Date of Birth:
Date of Birth:
Date of Birth:
5. Jurisdiction: This Court is that of proper jurisdiction to
hear this cause. The Defendant has agreed to file an Affidavit
of Consent in this cause. Neither the Plaintiff nor Defendant
has been involved in any litigation or other proceeding
involving the other party in this or any other jurisdiction with
respect to their marriage or any other domestic matter.
7. Marital Settlement Agreement: Plaintiff and Defendant
>have (copy attached) have not entered
into a Marital Settlement Agreement that formalizes an
allocation of their property and finances and matters relating
to child custody and visitation.
8. Other Declarations:
NOW, THEREFORE, Plaintiff requests that the court order a DECREE
OF DIVORCE and such further relief as Plaintiff may have
requested herein.
Verification
I ?'D y C [name of
Petitioner), affir under penalty of perjury that I am the
Petitioner in the foregoing COMPLAINT FOR DIVORCE and that all
statements in this Petition are accurate to the best of my
knowledge. I have filed this Complaint in good faith and have
not colluded with anyone in relation to it.
Petitioner'/ Signature
/05 £• Rl(ep sf• 40
Petitioner's Addre ss ,
Line 1
Date
6. Grounds for No-Fault: Plaintiff wishes a dissolution of
marriage with Defendant based on the following grounds:
M(ch a.n, c; bL4,r , PR 170.5
Petitioner's AAess, Line 2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF &kfneEKtP9aD
Subscribed nd sworn to before me on this -/67 ?" day of
20 O L(
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Notary
N0I'ARIAi_ SEAL
0BREWBAKER NOTARY PUBLIC
isleBorc Cumberlxnd0ounty
nmmissioi F-xpiresApnf 4 2009
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COMMONWEALTH OF VIRGINIA
MARRIAGE REGISTER
COPY A
FOR CLERK OF COURT
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TO OFFICIANT:
CandeIs and signs
mrfi rates on both
copies.
Hetum both copies
vrhhin live days to
Clerk of Coun
fishing license.
Section 32.1-267.
Code of Virginia
CIRCUIT COURT FOR CITY OR COUNTY OF CLERKS
VIRGINIA BEACH, VA NUMBER 99003009
1. FULL NAME (Faso (middle) (last) 1a. SOCIAL SECURITY K
oFGROOMRLFRED FRANCIS IiOPKINS
1
221--62-9966
2. AGE 3. DATE OF BIRTH (AbnlA, Day, Year) 4. PLACE OF BIRTH (state or feregn cotmey)
28 March 07
1971 DELAWARE
Years ,
5. RACE 6. NUMBER OF (first. second, etc) 7. MARITAL STATUS (Ifpredmsly
WHITE THIS MARRIAGE 01 named)
WIDOWED[] DIVORCEDE3
GROOM B. EDUCATION Elementary or Secondary College 9a. USUAL RESIDENCE: STREET ADDRESS OR RT. NUMBER
of 1(8.12)
C
9
c
mp (1-4 s+1 3516 BRIGITA CT
ade
om
plet
9b. CITY OR TOWN OF RESIDENCE
I gc. COUNTY (if independenl city, leave blank) 1 M STATE (OR FOREIGN COUNTRY)
VIRGINIA BEACH I IVA. 23456
10. NAME OF FATHER 11. FULL MAIDEN NAME OF MOTHER
ALFRED RAMSEY HOPKINS N/A
112. PRESENT NAME (firsq (mlddfe) past) MAIDEN SURNAME (If different) 12a SOCIAL SECURITY#
OFBRIDECHRISTINE ANN COPELAND 062-68-2179
? 13. AGE 4. OATf OF 81Fiu Ili 1h, Dav year) ,. PLAt'c OF glgiu (syle r loragn cocTT„
24 August 29, 1975 NEW YORK
Years
i6. RACE 17. NUMBER OF (firs( second, etc) 16. MARITAL STATUS (1{previously
WHITE THIS MARRIAGE 01 mauled)
WIDOWED DIVORCED?
BRIDE i 19. EDUCATION Elementary or Secondary College 21 USUAL RESIDENCE'. STREET ADDRESS OR RT. NUMBER
(Speedy only hlgbeaf (0-12) (1-4 or 5+16 2 3516 BRIGITA CT
grade completed)
21 CITY OR TOWN OF RESIDENCE 120c. COUNTY (if imaepeencer city, leave blank) 1204. STATE (OR FOREIGN COUNTRY)
I VIRGINIA BEACH VA. 23456
21. NAME OF FATHER 22- FULL MAIDEN NAME OF MOTHER
RONALD E. COPELAND 'ATHLEEN A. HUBBARD
23. TO ANY PERSON LICENSED TO PERFORM MARRIAGES: MARRIAGE LICENSE
You are hereby amheineed to join the above named persons in marri age September 13, 1999
under procedures outlined in the stables of die Commonwealth of Virginia. Dale Issued
(I
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b License Explws Sixty Days After Above Dale
,
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Signature, Date Received by Clerk of n n
C etl eF6m w Deputy Court from Otliciam
MARRIAGE CERTIFICATE
24. DATE OF (Mwfh, Day, Year) 25. PLACE OF (ceunty or inAepeedenl city) 26 TYPE OF
MARRIAGE o Q p
Q ? MA RI GE
I/
c CEREMONY CIVI RELIGIOUS[]
/' / 7 ry
/R?? (Gxeff VIRGINIA
,,.iUCrtli?r lfrMi lJV?ryCU iq? IXnn,ouvJ YY?C r,JVrY>IIV MHriruee,VIa1r1C UN1[ a., er I Mt IIUL/JYtI•IYItU. e
SIGNATURE OFo, CA? ?Yi /'u TFFICIA
OFFICIANT Authorized to perform marriages by the Circuit Court for U` let A- `N
(ctya County) Virginia, in
iyear of authoucatlon)
NAME OF if
OFFICIANT
(type or print)
OF OFFICIANT_1_ ii
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AFFIDAVIT OF CONSENT
COURT OF COMMON PLEAS
t'4yfn6rxL'9ND COUNTY, PENNSYLVANIA
In re: the Marriage of
/?eo ? ,?on?/,hs
Plaintiff
v (? - ) 9,2 a C'- - -7-4-
Docket No.
and
1?/1/?s?7?G C' ?onk/as
Defendant
1. A COMPLAINT FOR DIVORCE was filed between Plaintiff and
Defendant on the (p day of Jr'fru{ , 20 b In
2. The marriage between Plaintiff and Defendant is irretrievably
broken and efforts at reconciliation have failed.
3. I, ek1-1-TJne L • DD?/ , have received a copy of
the COMPLAINT FOR DIVCCIRCE, and I have read it thoroughly and
understand it. I do not wish to contest this proceeding. I do
not object to the declarations made in the COMPLAINT FOR
DIVORCE. I do hereby consent to the relief requested in therein
and to the entry of a DECREE OF DIVORCE dissolving and forever
terminating the marriage between Plaintiff and Defendant. I
consent that the court may hear this cause on any day convenient
to the court without further notice to me. I further consent
that the court may enter any order granting any and all the
relief sought in the COMPLAINT FOR DIVORCE.
4. I waive any and all rights I may have to a motion for a new
trial, a record testimony, findings of fact and conclusions of
law, notice of trial, a notice of entry of a DECREE OF DIVORCE
and my right to appeal.
5. I do not waive any future rights I may have to the
modification of any judgment or decree in relation to this
cause.
6. I affirm under penalty of perjury that all statements in this
Affidavit of Consent are accurate to the best of my knowledge.
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MARITAL SETTLEMENT AGREEMENT
AGREEMENT made on this day of .20 1 by and between
?helsh,;e G• NOD&Ao (hereinafter referred to as "Wife"), who resides at
,24r<3 y&rk ;z J. We$4 ye.k, NY 14542 [insert full residential
address of Wife] and A1•/reb P7 Unok/ns (hereinafter referred to as
"Husband"), who resides at /03,E- A// a Sf. Api. 31.5 Aech.yirls Zk9 . P,4 /?bfS
[insert full residential address of Husban0
WHEREAS, we were married on the day of S4.P!- in
1.di nia &-c a [city], Viz' ei iA/A [state], and we now mutually desire
to dissofv ur marriage and mutually agree to live permanently separate and apart from each other, as if
we were single;
WHEREAS, we each have exercised good faith and have made fair, accurate, and complete disclosure to
each other regarding all financial and property matters pertaining to this marital settlement agreement;
WHEREAS, we mutually desire to settle by agreement all matters regarding our marital affairs, child
custody and visitation, personal and real property, and finances;
WHEREAS, we mutually intend this agreement to be a final disposition regarding the marital issues
addressed herein and intend that this agreement be incorporated into any subsequent DECREE OF
DIVORCE.
THEREFORE, in exchange for the mutual promises herein contained, we agree to live separately and to
divide our property and finances according to the following mutually agreed upon terms and conditions:
1. CHILDREN
Husband and Wife have the following child(ren) born or adopted into their marriage.
Name: Al-Peb it Apkfn s ? Sk • Date of Birth: t- S-a OW
Name: Date of Birth:
Name: Date of Birth:
Name: Date of Birth:
A.CUSTODY
To settle all issues in relation to custody in a manner consistent with the best interest of the child(ren),
Husband and Wife agree as follows:
Husband shall have sole custody of
Wife shall have sole custody of =
Husband and Wife shall have joint custody of A/-?Cb F //D> kjnsj SR-
ALFRED'S 1PRIM,41Ay )fF_S1D6A1CF_ Sh,9LL be wlr-;{ N1(seAA1D
B. VISITATION rf' PSNNSyLVAN1n LAK/ QE4WJKa5 TWAT Sow u1STa4Y
DE4oEs wNGts c1/ Lo1f r,& pit1MqAce REa/PE?C.G /s T> BE)Th
r /ffo sNAU- NAVE SDL
)•!uS$wNa r I-W* U - N
To settle all issues in relation to the visitation rights in a manner consistent wi h the best BNm Brest of the cal•nby
child(ren), Husband and Wife agree as follows: A4fRSb r
40PK1ASl
1) Husband shall have the following rights of visitation:
fJWSBjgA,D Shpt NM-e-
Page 1 of 10 Prfinay r?eSrde.?Ce Or drGG •
Husband's Initials Wife's Initials
B. Wife owns the following life insurance policies naming Husband as beneficiary:
(Policy Number)
(Policy Amount)
(Name and Address of Institution)
(Policy Number)
(Policy Amount)
(Name and Address of Institution)
(Policy Number)
(Policy Amount)
(Name and Address of Institution)
Wife agrees that Husband [check one:] N shall, or shall not remain the beneficiary of
the following life insurance policies:
8. HEALTH INSURANCE
Husband and Wife agree as follows in relation to their respective health care coverage:
C-E_1/LD? HIw L7}!G E GDVeAA4E JJ44" BE MOVIAED BY PN2EVr WW CRN G1?V H'M
k9i }(Srs? o- IDOLIC Y. Tf? iT;JAs To gE Quu-CHAsFo SVYGRATP LY sr&Lr ArjL,p fJUSSAvp i
9. SPOUSAL SUPPORT WI cs styli U- S'p Lir 1-HC COST or SA14D Ai r# 1n14RA07CE-
A. Husband shall pay to Wife spousal support in the sum of .?Y dollars
($ ), [specify "weekly" or "monthly'], beginning on the
day of , 20 _. Husband shall continue to pay this sum for a
period of subject to the following mutually agreed upon conditions:
B. Wife shall pay to Husband spousal support in the sum of .6K dollars
($ ), [specify "weekly"or "monthly'7, beginning on the
Page 8 of 10 .4-11, 6 V.
Husband's Initials Wife's Initials
Weekends:
Husband shall have visitation rights on the following days and times [choose one:] each
weekend OR every other weekend:
Weekdays:
Husband shall have visitation rights on the following days and times during [choose one:]
each week OR every other week:
Yearly Vacation:
Husband shall have visitation rights for the following vacation periods each year:
0I ?p><AL pii/l'
go do-J& in srnn
Husband shall have visitation rights for the following holidays during even-numbered years:
Holidays (Odd-Numbered Years):
Husband shall have visitation rights for the following holidays during odd-numbered years:
Chei,<4nr 4s
Other Visitation Rights:
Husband shall have the following additional visitation rights:
2) Wife shall have the following rights of visitation:
Weekends:
Wife shall have visitation rights on the following days and times [choose one.] each
weekend OR V everv other weekend'
Page 2 of 10 6k
Husband's Initials Wife's Initials
Weekdays:
Wife shall have visitation rights on the following days and times during [choose one:] _
each week OR every other week:
Yearly Vacation:
Wife shall have visitation rights for the following vacation periods each year:
rryci
2wA641 .4
Holidays (Even-Numbered Years):
Wife shall have visitation rights for the following holidays during even-numbered years:
rraY.n'cS
Wife shall have visitation rights for the following holidays during odd-numbered years:
?z
2. REAL ESTATE
A. RESIDENCE
Husband shall reside at
Wife shall reside at og b
B. HOMESTEAD
> -}s Me C ur"eA? are'
oflkw. HOLIb4YS N
/g1W4YJ BE6nJ
t SH4d-eD.
Husband and Wife own the following real property as their family residence, located at
rpu r
Husband and Wife agree that lea F U nkrnr Se • shall continue to reside at *9-alseve-
ra ntii. n ri f ..? /o E. H llpp Sf .4pf.315 Alec A.tnr<sb.c?, Gil 17053
p,k Wl{?rQt?cr l,pusbAno rtSiAsS .
Rights, responsibilities and expenses regarding the above mentioned family residence shall be distributed
as follows:
1) Title:
Husband shall have the following rights of title and ownership in the family residence:
rhnn, (r..Ilk)
Wife shall have the following rights of title and ownership in the family residence:
Page 3 of 10
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Husband's Initials wife's initials
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2) Expenses. Mortgage and Maintenance:
s
Husband shall be responsible for and pay the following expenses regarding the family residence:
n
s Wife shall be responsible for and pay the following expenses regarding the family residence:
i>>
>? A
S
s C. OTHER REAL ESTATE
Husband and Wife jointly own the following other real estate to be divided as follows:
1) To Husband:
2) To Wife: <<
zt
s
3. PERSONAL PROPERTY
A. HOUSEHOLD GOODS
a
Husband and Wife jointly own the following household goods to be divided as follows:
t
>` 1) To Husband:
RL? ,G?ou.tc!-(orb woDS J{fi?a /REV?oulty Bt??!
'z
J.iViO?/? /ks IA1Bae/D r WIFE L1A?E LIVeb
Sep 0.3.
2) To Wife:
A/
B. AUTOMOBILES
ti
Husband and Wife jointly own the following automobiles to be divided as follows:
1) To Husband `
A/0 ,7oinrt-y OWN?b Ay7-p/U04?/L
2) To Wife: >v
zz
< Page 4 of 10 ?. y. c
Husband's Initials Wife's Initials
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S
C. OTHER PERSONAL PROPERTY
s Husband and Wife own the following other personal property to be divided as follows:
1) To Husband:
..,/
Act G//S DY1pL P??GC {Lps PR"lousi-q Dtvibcb vjm
A/a D/svuTES 4.f 15 W/3Bn/D L.v?
yldVt ZJVob
_
5 E:FF-0-NTE. dNA Aio kr- SINCF L1! ZDn3
2) To Wife:
r
4. BANK ACCOUNTS
t
Husband and Wife jointly hold the following bank accounts:
(Account Number)
(Account Balance)
s;
S
ss
(Name and Address of Institution)
(Account Number)
(Account Balance)
t.
s
(Name and Address of Institution)
(Account Number)
(Account Balance)
_ <C
(Name and Address of Institution)
t
(Account Number)
(Account Balance)
> (Name and Addr s of Institution)
:
The above mentioned accounts shall be divided as follows: ?z
Page 5of10 A.H, C•N,
J} Husband's Initials Wife's Imtials
1) To Husband:
2) To Wife:
5. DEBTS
Husband and Wife jointly hold the following debts outstanding:
&O ja l IV r QCBf5 (Account Number)
(Account Balance)
T 1 IV Q
(Name and Address of Institution)
(Account Number)
(Account Balance)
(Name and Address of Institution)
(Account Number)
(Account Balance)
(Name and Address of Institution)
(Account Number)
(Account Balance)
and Address of Institution)
The above mentioned debts shall be divided as follows:
1) Husband agrees to pay and assume all responsibility for the following debts:
2) Wife agrees to pay and assume all responsibility for the following debts:
Page 6 of 10 A.,y G-//.
Husband's Initials Wife's Initials
Husband and Wife agree that from the date of this agreement, neither shall assume any joint debt or
liability. Husband and Wife agree that each shall be individually responsible for all debts that he or she
acquires subsequent to the date of this agreement.
6. TAX LIABILITY
A. Husband and Wife agree that any joint tax liability shall be assumed as follows:
1) By Husband:
A'lo o Alf Z4X U 6ILiZ(
t[sbt}aD f WIFE OVayE ILX S? EIC?}T L
2) By Wife:
B. The custodial parent shall have the sole right to claim as a dependent for state and federal income tax
purposes any child over which he or she has custody. In the event of joint custody, the Husband and Wife
agree as follows with respect to who shall hold this right:
7. LIFE INSURANCE
f
A. Husband owns the following life insurance policies naming Wife as beneficiary:
(Name
(Policy Number)
(Policy Amount)
(Policy Number)
(Policy Amount)
(Name and Address of Institution)
(Policy Number)
(Policy Amount)
(Name and Address of Institution)
fAX RukP0SE5-
50 A4 uTUALr-y 4'f7leGE
9S k9D CHILD rpR IWE
-flot&D -nmE. (TF PR.IMFR
k65iOEWcW of C*I D tS
W.ry WIFE1 p4oPCM
rjwjEkWa/uc Ivlu- g4
1='iu-ea Or,T-)
Husband agrees that Wife [check one:] shall, or shall not remain the beneficiary of
the following life insurance policies:
Page 7 of 10 g. N• C
Husband's Initials wife's Initials
ana AaareSS or institution)
13. ACKNOWLEDGEMENT
Husband and Wife acknowledge that each has entered into this agreement in good faith, without any
duress or undue influence. Each understands his or her right to seek independent counsel regarding this
agreement, and each has had the opportunity to seek independent counsel prior to signing this
agreement.
14. CHOICE OF LAW
Husband and Wife agree that this agreement shall be governed and construed in accordance with the
laws of the Commonwealth of Pennsylvania.
Signed and dated this day of d/? N 20
6" ? &?4,
Wife
Husband ccc
Witness #1 for Wife
Witness #2 for Wife
Witness #1 for Husband
Witness #2 for Husband
CERTIFICATE OF ACKNOWLEDGMENT OF NOTARY PUBLIC
COMMONWE TH OF PENNSYLVAANIA
COUNTY OF f??f
T 's cum@nt was a ?owledged ? efore?me on ?Ca [Date] by
no t r ?. P>t) lorr (l?-11 [name of principal].
[Notary Seal, if any]:
ti07AR1Ac St-A!,
IAUD1A BRCV9AkF=P NOTARYPIJBLIC
aj su. )mbedandCounty
Anril4 2009 .
0 k o-u i-/- . Lr(/I f/
(Signature of Notarial Officer)
Notary Public for the Commonwealth of
Pennsylvania
My commission expires:
Page 10 of 10
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Husband's Initial, Wife's hutiats
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Curtis R. Long
Prothonotary
office of the i3rotbonotarp
Cutnberlanb QCountp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
UL - IS 2-a , CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573