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Home My WebLink About06-1959 Pamela L Purdy Attorney ID No, 85783 115 Pine Street, Suite 100 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorneys for Plaintiff ROBERT K, O'CONNOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, LORA R O'CONNOR, Defendant NO, Of... -/1!:9 C;u;L~8LW\. IN 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 for any other claim or relief 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 list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 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 THIS 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 M~. Pamela L Pu dy Attorney for Plaintiff - 2 - Pamela L. Purdy, Esquire Attorney 10 No. 85783 115 Pine Street, Suite 100 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon,net Attorneys for Plaintiff ROBERT K. O'CONNOR. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01., - /9~( IN DIVORCE c/ul'L ~~ LORA R. O'CONNOR, Defendant COMPLAINT IN DIVORCE COUNT) Divorce Under 3301 (c) or 3301 (d) of the Divorce Code 1, Plaintiff is Robert K, O'Connor, who resides currently at 1642 North Third Street, Apartment 2, Harrisburg, Dauphin County, Pennsylvania, 2. Defendant is Lora R. O'Connor, who resides currently at 19 Wetherburn Road, Enola, Cumberland County, Pennsylvania. 3, Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 25, 2004 at Hagerstown, Maryland. 5. There have been no prior actions of divorce or for annulment between the pa rties, 6. The marriage is irretrievably broken. 7, The grounds on which the action for divorce is based are: A. Section 3301 (c): The marriage of the parties is irretrievably broken, After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce, 8, Section 3301 (d): The marriage of the parties is irretrievably broken, Plaintiff and Defendant separated on December 10, 2005. After December 10, 2007, Plaintiff intends to file an Affidavit alleging that the parties have lived separate and apart for a period of two years and that the marriage is irretrievably broken, and he anticipates that Defendant will not deny that the parties have been separated for a period of at least two years and that the marriage is irretrievably broken. 8, Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling, Plaintiff hereby waives his right to such counseling. 9. Plaintiff requests the court to enter a decree of divorce, -2- WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Section 3301 (c) or (d) of the Divorce Code, COUNT II EQUITABLE DISTRIBUTION 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property that are subject to equitable distribution under Sections 3501 and 3502 of the Divorce Code. 11. Plaintiff and Defendant have not agreed to an equitable distribution of this property, 12. Plaintiff requests the Court to equitably distribute all of the marital property . WHEREFORE, Plaintiff requests the Court to enter an Order equitably dividing all of the marital property, ~{y~?Y Attorney for Plaintiff Dated: a,J. J} zav~ - 3 - VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties Pa.C.S. 94904, relating to unsworn falsification to authorities ~k~~ (' Dated: a ~ 3, z.cfO' -4- ~p 0 :\ ~ .7'- "- IL \:l ~ ~J ..0 c;\\) \) -- ~ v V( iJ- \) \> C' / ...c:: - I -,() "t:. "T) \\ b (- ?? 0- v- -I ~ ( ~ - (- ~.~ \-~\ ~(1 ( , (~ ,..-1 , u~ -- ., :~ j"'.,J. Pamela L Purdy, Esquire Attorney 10 No, 85783 115 Pine Street, Suite 100 Harrisburg, PA 17101 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon,net ROBERT K. O'CONNOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Din. Ii) 5"/ LORA R. O'CONNOR, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, JOHN J, CONNELLY, JR, ESQUIRE, attorney for the Defendant LORA R. O'CONNOR, in the above-captioned divorce action, hereby accept service of the Complaint in Divorce filed April 5, 2006, in the Court of Common Pleas of Cumberland County, Pennsylvania, and certify that I am authorized to do so. r~ <:::::;C~, l~, " JpHN J. C NNELL Y, JR., UIRE James~, Dietteric~ & n elly 134 Sipe Avenue "- Hummelstown, PA 17036 (717) 533-3280 Dated: Y \ It \0 (, ROBERT K. O'CONNOR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1959 LORA R. O'CONNOR, 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 5, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of 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 ~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.A. S4904, relating to unsworn falsification to authorities. Date: I 0 / a ~ / 0 ~ ~Q(!)~VJ \. Lo a R. O'Connor, Defendant r-:> c,:} = e,::...-.... -,----- ....-"'>;If" ...'....- c~ \ W -- S) 01 C) ~ Pamela L. Purdy Attorney I D No. 85783 115 Pine Street, Suite 100 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorneys for Plaintiff ROBERT K. O'CONNOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-1959 CIVIL TERM LORA R. O'CONNOR, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 17, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made s ec to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification auth ties. Lt ~ /r;kf k/ () t ttMy II( ~, Dated: I Db , Robert K. O'Connor ~ C) ,~ -n cr" B (...."1 CO Pamela L. Purdy Attorney ID No. 85783 115 Pine Street, Suite 100 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff ROBERT K. O'CONNOR, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1959 CIVIL TERM LORA R. O'CONNOR, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 in this affidavit are true and correct. understand that false statements herein are mad . les. l II /f) (/J ~-fIUL r (;C [) L DtUuf Robert K. O'Connor C.S. 94904 relating to unsworn falsification t I(i ii, Dated: ~/o o s: ---.------------------ ~ = C;:J c..... ~ c.:: _.- ~ ::? I W 6 0'1 CO ~ " Pamela L. Purdy Attorney 10 No. 85783 11 5 Pine Street, Suite 100 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorneys for Plaintiff ROBERT K. O'CONNOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.06-1959 CIVIL TERM LORA R. O'CON NOR, Defendant I N DIVORCE PRAECIPE TO TRANSMIT RECORD TO TH E 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 93301 (c) of the Divorce Code. .... Date: 2. Date and manner of service of the Complaint: Served via U.S. Mail on April 7, 2006 and an Acceptance of Service filed of record on April 24, 2006. 3. Date of execution of the affidavit of consent required by 9 3301 (c) of the Divorce Code: by Plaintiff: November 1, 2006; by Defendant: October 26, 2006. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: contemporaneously with this Praecipe. Date Defendant's Waiver of Notice was filed with the Prothonotary: contemporaneously with this Praecipe. By Attorney for Plaintiff Robert K. O'Connor - 2 - (") C '7':..-:0 (- ~~ 1"-.) c;:'.:l c:::: C'" -1Y" .......,.... ~ o -n .~ :L-n r'1C~ :~t:-~.~ I (.,,) 0? Ul CO - " S~ V~-4 :~~ ~ ~ ^'"'" Pamela L. Purdy, Esquire Attorney 10 No. 85783 115 Pine Street, Suite 100 PO Box 11544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net ROBERT K. O'CONNOR, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-1959 CIVIL TERM LORA R. O'CONNOR, Defendant IN DIVORCE PRAECIPE TO WITHDRAW ECONOMIC CLAIM TO THE COURT: Please withdraw Count II for equitable distribution in the divorce complaint in the above-captioned matter. Dated: .. -.. CERTI FICA TE OF SERVICE The undersigned hereby certifies that on the 1 st day of November 2006, a true and correct copy of the foregoing document was served by U.S. Mail, first-class, postage prepaid, upon the following: John J. Connelly, Jr., Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 {, Pamela L. Purdy - 2 - (") s: r---> c;::> c:> C7" ...".;~" -'~ '-' ~ I W -..;\ 1'-) o ~ ~~ ~~ ~~~ ~ ~~~ ~ ~ ~ ~~ ~~~ ~ ~ ~ ~~~~~~~~~~~~~ ~~~~~~~~ !f !f IN THE COURT OF COMMON PLEAS !f OF CUMBERLAND COUNTY STATE OF PENNA. ROBERT K. O'CONNOR, No. Ofi 19119 rTvTT, TERM Plaintiff VERSUS LORA R. O'CONNOR, Defendant DECREE IN DIVORCE AND NOW, ~ Br , Zooc. , IT IS ORDERED AND DECREED THAT ROBERT K. O'CONNOR , PLAI NTI FF, AND LORA R. O'CONNOR , 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; NONE ..~ ,~ J. PROTHONOTARY !f!f~!f!f!f!f!f!f!f ~!f!f!f!f!f !f!f!f !f~ ~~~ !f~!f~ !f~!f!f~ ~~!f~!f~ ~ !f!f~!f!f!f~!f~!f~~~~~ -h z ~~ 111 51-;/ k Jr ~ /ff:' 1rh..p7J W.51./1 . i , I l,\ NOV 29 2006 ,..i ROBERT K. O'CONNOR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : DOCKET NO. 06-1959 Civil Term LORA R. O'CONNOR, Defendant : CML ACTION - LAW : IN DIVORCE Stipulation for the Entry of Qualified Domestic Relations Order ---------- ------/ The parties, Robert K. O'Connor, Plaintiff, and Lora R. O'Connor, Defendant, do hereby stipulate as follows: 1. Lora R. O'Connor, date of birth April 23, 1966 (Social Security Number 212-94- 1467), hereinafter referred to as "Participant" is a participant in the CIBER, Inc. 401(k) Savings Plan described below (hereinafter referred to as the "Plan"). 2. The current and last known mailing address of Participant is 19 Wetherburn Road, Enola, Pennsylvania, 17025-1844. 3. Robert K. O'Connor, date of birth March 19, 1964 (Social Security Number 222- 60-2355), hereinafter referred to as "Alternate Payee," is the spouse of the Participant. 4. The current and last known mailing address of Alternate Payee is P.O. Box 42, Enola, Pennsylvania, 17025-1844 5. This order applies to the following plan: CIBER, Inc. 401(k) Savings Plan, 5251 DTC PKWY, STE 1400, GREENWOOD VLG, CO, 80111-2742. 6. A portion of the Participant's account in the Plan is marital property subject to distribution by this Court. 7. Alternate Payee shall receive the lump sum of Twenty Seven Thousand Seven Hundred Forty Three Dollars and Ninety Eight Cents ($27,743.98) from the Participant's VINVAlASNN3d I H'lnn'" ""...,. ,-V-:IAlni"\ I\.J..l' .J) " ,rJ:::CHl'Il >J 6S :01 WV 0& AON 900Z AtN10i\J01-ll08d 3H.l. :JO 301.:l:l.o-a31l:J account. The form of benefit shall be a lump sum payment. This sum shall be allocated to Husband as of October 26, 2006, and shall include all interest, earnings and losses on that amount from October 26, 2006 until the date of distribution. 8. The distribution to Alternate Payee from the Plan shall be made as soon as administratively practicable following the Plan's determination that this order is a Qualified Domestic Relations Order. 9. Participant's death shall have no effect on payment of Alternate Payee's benefit under the Plan. The Alternate Payee is at all times to be deemed the surviving spouse for purposes of the Pre-retirement Survivor Annuity until this Order effectively assigns the funds to Alternate Payee as identified in paragraph 7 above. 10. In the event the Alternate Payee dies before the Alternate Payee's benefit is paid, the benefit shall be paid in accordance with applicable Plan provisions regarding payments to beneficiaries, including payments when no beneficiary is designated. The Alternate Payee shall be entitled to name a beneficiary (or beneficiaries) to receive the unpaid balance of the benefits. The death of Alternate Payee before the Plan determines that this order is a Qualified Domestic Relations Order shall not affect the right of Alternate Payee's beneficiary to benefits from the Plan. 11. The parties shall promptly notify the Plan of any change in their addresses from those set forth in this Order. 12. Participant and Alternate Payee shall each be responsible for his or her own federal, state, and local income and other taxes attributable to any and all payments from the Plan which are received by Participant and Alternate Payee respectively. The Plan shall provide to .. '. Participant and Alternate Payee in accordance with its customary procedures such information as is normally provided to participants in the Plan with respect to the taxability of distributions from the Plan. 13. Nothing contained in this Order shall be construed to require any plan or plan administrator: (a) to provide to the Alternate Payee any type ofform of benefit or any option not otherwise available to the Participant under the Plan, or (b) to pay any benefits to the Alternate Payee which are required to be paid to another alternate payee under another order determined by the Plan Administrator to be a Qualified Domestic Relations Order before this Order is determined by the Plan Administrator to be a Qualified Domestic Relations Order. 14. It is the intent of the parties and the court that the provisions of this Order operate as an effective assignment of the Participant's interest in the Plan under both federal and state laws, for all purposes, and constitute a valid Qualified Domestic Relations Order in compliance with Section 414 (P) of the Internal Revenue Code and Section 206 (d) (3) of the Employee Retirement Income Security Act of 1974 ("ERISA"), as amended by the Retirement Equity Act of 1984. 15. The parties intend and agree that the terms of this Stipulation shall be approved, adopted and entered as an Order of Court. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend this Order, but only for the purpose of establishing it or maintaining it as a ... , Qualified Domestic Relations Order; provided, however, that no such amendment shall require the Plan to provide any form of benefit or any option not otherwise provided by the Plan, and further provided that no such amendment or right of the Court to so amend will invalidate this Order. 17. A certified copy of this Order shall be served upon the Plan. Said Order shall take effect immediately upon approval of the Order by the Plan and shall remain in effect until further Order of Court. 18. The Court retains jurisdiction over the Domestic Relations Order to amend, as necessary, to establish or maintain its qualification as Qualified Domestic Relations Order under ERISA. BY THE COURT: PARTICIPANT .Ad ORNEY FOR PARTICIPANT J Q~}~ ~onnor t. TE PAYEE ATTORNEY FOR ALTERNATE PAYEE it ^ -[if IL< O\C~~( Robert K. O'Connor .-..._-~-~.~~._---~.._---