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HomeMy WebLinkAbout06-4634Ryan Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Katrina Bopp, : NO. 06 - 416-1q CIVIL TERM Defendant : IN DIVORCE 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. When the ground for the 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 Court House, High and Hanover Streets, Carlisle. 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Ryan Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL AC?IOJ - LAW Katrina Bopp, : NO. 06 - G 3 CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Ryan Bopp, an adult individual, who resides at 22 Walnut Street, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Katrina Bopp, an adult individual, who resides at R.R. 5 Box 3694 or 1426 W. Franklin Street, Salem, Missouri, 65560. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 14, 2001 in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: a a G Leslie A. Tome t, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff !? Ryan Bopp, V. Katrina Bopp, CERTIFICATE OF SERVICE 11, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day sent a copy of the within Custody Complaint upon the following by Professional Process Service in the United States out of Carlisle, Pennsylvania, addressed as follows: Katrina Bopp R.R. 5 Box 3694 and 1426 W. Franklin Street Salem, MO 65560 Dated: 41 0 : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 - CIVIL TERM Defendant : IN DIVORCE Respectfully submitted, ROMINGER & WHARE ry? ie A. Tom , Esquire 155 South Han ver Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 200198 Attorney for Plaintiff Q d C'? h r? ]y, ''1?Y77 it a A i AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania County of Cumberland Common Pleas Court Case Number: 06-4835 CIVIL TERM Plaintiff: Ryan Sopp VS. Defendant Katrina Bopp For. Leslie Tomso Rorninger & Where Received by Pennsyivan a Professional Process Svc, on th 1 th day cl A st,12006 at 10:47 am to be served on Katrina Bopp, R.R. 5 7tcEom WDPISI em: N6i386Q, Ibeing duly sworn, depose a3nd say that on ayof U4A.Q,," 2002. ai executed el service by delivering a true copy of the Notice; nder Sect i 3301(c) the ivorc Code: Order of Court: Complaint for Crreto a cordance with state statutes in the manner marked below: NGIVIDUAL SERVICE: Served the within-names; Person. () SUBSTITUTE SERVICE: By serving_ -„as () NON SERVICE: For the reason detaileC in the Comments Wow. Military Status: ( ) Yea or ( ) No If yes, wfiet branch? Marital Status. ( ) Married or ( ) Single Name of Spouse COMMENTS: i certify that i have no Interest in he above action, am of legal age and have proper authonty in the jurisdiction in which this service was made. Y06? PeW Subscri d n to? 'Wore me on the day PROCESS ER of I --- - by the afflant who is Appointed Accordance narHy known to me. with State Statutes el? Pennsylvania Professional Process Svc. ARY PUBLIC 48 W. High St. ROBERT GORDON JONES P.O. Box 1 f 4B Notary Public - Notary Seal Carlisle, PA 17013 State of Missouri - County of Phelps (800) 863-7341 My Commission Expires Apr. 3, 2009 Our Job Serial Number: 20060DO306 Commission #05405419 -20? osue?sr. s.rvFxs, na -Rmass eavefa TOOIGaz VS.:i na ? N W"r??l 77 Ryan Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Katrina Bopp, : NO. 06 -4634 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 11, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: y "pp/Plaintiff - ?7' L ?? s?v Ryan Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . : CIVIL ACTION - LAW Katrina Bopp, : NO. 06 -4634 CIVIL TERM 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. ?Cj`?-u? Date: yah Bop aint r ,. ?? ?. ; ,.?, . ., ?'., ? ,;: ?, -??: , f ? w ? ? r Y^ ?. ? c? ? ? ?, ? Ryan Bopp, V. Katrina Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06 -4634 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 11, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: ql?710 atrina Bopp/Defendant `-' _...? ?+3 ,., T'7?~ ' r ?, _: ` ? _._ S `?+ ? y? w y .? • ? .?' "' Ryan Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Katrina Bopp, : NO. 06 -4634 CIVIL TERM 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. ZL Date: Ka na Bopp, Defendant ? r ? t,t i ?? . ?.^? ,.y't Cy ,, .. rT. ?.:',? t 'r ?: 'R.:. ?,,. C_ „iii ' - - j c? Yyy r i . ? ? .?_ "r' Ryan Bopp, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Katrina Bopp, : NO. 06 -4634 CIVIL TERM Defendant : 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: August 11, 2006, was served on Defendant by a process service with an affidavit of service signed on August 31, 2006 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by § 3301(c) or The Divorce Code: by the Plaintiff, August 20, 2007; by the Defendant, August 20, 2007. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: August 20, 2006. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: August 20, 2006. Date: August 21, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 r-? C'r ?"' ? -n ?'? ? ? -?, ?, ,_-,? ..-.; __ -,, _ ?, . - ? .? IN THE COURT OF COMMON PLEAS Ryan BoW OF CUMBERLAND COUNTY STATE OF PENNA. No. 06-4634 Plaintiff VERSUS Katrina Bopp Defendant DECREE IN DIVORCE 'SAM, IT IS ORDERED AND AND NOW, *A'La 4-9-1.3 DECREED THAT Ryan Bopp PLAINTIFF, AND Katrina Bopp ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,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; 679- go- A