HomeMy WebLinkAbout94-059744W*4W aW 4116
'aW`W
I
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNSYLVANIA
ARPAD K. SIPOS
Versus
....hXAxA P.._SIMS ...
N 1)...... 947.5.9.74 ................ 19
AND NOW,.... !Y.KJ .. <! ............ 19 q 7k.., it Is ordered and
x
decreed that ... ARPAD K. SIPOS plaintiff,
and ... WIA • P.. •SIPOS ..................................... 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;
........ Nane ........................................
.,.. ..............
By T r
A11??1:?fu??EacC! f? LG11 ?/ ??7/fLiue? 3
v'
Prothonotary
. • ::? a: iti ;. aia .,,? .?,? ;,? `?: •M 40 air 4* .e: «. mw 4& a% 40
DECREE IN
DIVORCE
ARPAD K. 81P08,
Plaintiff
V.
LYDIA P. SIPOS,
Defendant
TO THE PROTHONOTARY:
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-5974 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Transmit the record, together with the following Information, to the Court for entry of a
divorce decree:
1. Ground for Divorce: irretrievably broken under Section 3301 (c) of the Divorce Code.
2. Date and manner of service of the complaint: Served by the Sheriff of Cumberland
County October 21, 1995 as evidenced by proof of service previously filed of record.
3. Complete either Paragrah A. or B.
A. Date of execution of the Affidavit of consent required by Section 3301 (c) of
the Divorce Code: by the plaintiff April 25, 1995, by the Defendant April 7, 1995.
B. (1) Date of execution of the plaintiffs affidavit required by Section 3301
(d) of the Divorce Code:
(2) Date of service of the plaintiffs affidavit upon defendant:
4. Related claims pending: none
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)(1)(1) of the Divorce
Code
Attorney for is n
? N
we
a
.ti
v
R
i4
a?
z
PA W
W v
u b ?
W
v ?a > w&
y N
N
p4 a
N
z
OW
?O
aQ
UH Z
NICHOLAS i FOREMAN ,
e
z ?
ARPAD K, SIPOS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
NO.
LYDIA P. SIPOS, ; CIVIL ACTION - LAW
Defendant : 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 H 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 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 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, Domestic Relations Section, Cumberland County Courthouse, Carlisle, Pennsylvania. 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.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240.13200
NICHOLAS 6 FOREMAN
C,
By
BRUCE N, ESQUIRE
3207 North Front Street
Harrisburg, PA 17110
(717) 238.9391
Attorneys for Plaintiff
LD. 211193
ARPAD K, SIPOS,
Plaintiff
V.
LYDIA P, SIPOS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
CIVIL ACTION - LAW
IN DIVORCE
Le han demandado a usted an la corte, Si usted quiere defenderse de estas demandes
expuestas an las paginas sigulentes, usted Uene vlente (20) dias de piazo al partir de la fecha de Is
demands y la notificacion. Usted debe presentar una apariencia escrita o an persona o por abogedo y
archivar an la corte an fora escrita sus defensas o sus objeciones a las demandas on contra de su
personal. Sea avisado qua si usted no se dellende, la corte tomara medidas y puede entrar una orden
contra usted sin prevlo aviso o notiflcacion y por cuaiqufer queja o alivio qua as pedido an la peticion de
demanda. Usted puede perder dinero o sus propiedades o otros derechos Importantes pare usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENNE EL DINERO SURCIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA
ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240.8200
NICHOLAS $.'OREMAN
?n
Y
BRUCE D. FORE AN, ESQUI
3207 North Front Street
Harrisburg, PA 17110
(717) 236-9391
Attorneys for Plaintiff
I.D. 21193
ARPAD K. SIPOS,
Plsindff
V.
LYDIA P. SIPOS
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION -LAW
IN DIVORCE
COMPLAINT
AND NOW, comes the above-named Plaintiff, ARPAD K. SIPOS, by his a!tomeys,
NICHOLAS & FOREMAN, and seeks to obtain a Decree in Divorce from the above-named Defendant,
LYDIA P. SIPOS, upon the grounds hereinafter set forth:
1. Plaintiff Is Arpad K. Sipos, an adult individual, ki jam, presently residing 132 Sholly
Drive, Mechanicsburg, Pennsylvania 17055.
2. Defendant is Lydia P. Sipos, an adult individual, sui jy ijj, presently residing at 237 N.
33rd Street, Camp Hill, Pennsylvania 17011.
3. The Plaintiff and Defendant have each been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on August 1, 1980 in Harrisburg,
Pennsylvania.
5. There have been no prior actions for divorce or for annulment between the parties in
this or in any other jurisdiction.
6. Both Plaintiff and Defendant are citizens of the United States of America.
7. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or Its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its
amendments.
8. The Plaintiff has been advised of the availability of marriage counseling and
understands that he may request that the Court require the parties to participate In counseling but avers
that he does not desire marriage counseling.
9. The Plaintiff avers that the grounds on which the actions are based are:
(a) That the marriage of the parties is irretrievably broken under Section
3301(c) of the Divorce Code;
(b) That the parties have been continually separated since September
1. 1991, a period in excess of two (2) years and the marriage is irretrievably broken under Section 3301(d)
of the Divorce Code;
10. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff prays your Honorable Court to enter an Order dissolving the
marriage between the parties.
REMA ' //
NICHOLAS 8 O 1/
.
BRUCE D. FOREMAN,
3207 North Front Street
Harrisburg, PA 17110
(717) 236-9391
Attorneys for Plaintiff
I.D. 21193
VERMATION
I verily that the statements made In this Pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification
to authorities.
AR-PAD K. SIPGS?`""
DATED: /o/U bN
ARPAD K. SIPOS, ; IN THE COURT OF COMMON PLEAS OF
Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
LYDIA P. SIPOS, : CIVIL ACTION • LAW
Defendant ; IN DIVORCE
WAIVER OF COUNSELING
1, 1 have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate In counseling.
2. 1 understand that the Court maintains a list of marriage counselors In 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 and I
participate in counseling prior to a divorce decree being handed down by the Court.
VP Dated; i0li r SIPOS
SHERIFF'S RETURN
0344ONWEALTH OF PENNSYLVANIAt
COUN'T'Y OF CLWERLAND
Arpad K. Sipos
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-5974 Civil Term
Complaint in Divorce and Notice
VS
Lydia P. Sipos
Wesley Cook , OplemMXor Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law, says,
that he served the within Complaint in Divorce and Notice
i
upon ry I„ ?_ si^os the defendant, at 11:43 o'clock
n M. / EDST, on the 21 day of October 194 at
737 Nnrth 33rd Street. Camp Hill , Cumberland County,
Pennsylvania, by handing to Lydia Sipos "
a true and attested copy of the Complaint in Divorce and Notice
and at the same time directing her attention to the contents thereof and
the "Notice lr Plead" endorsed thereon.
Sheriff's Costs,
Docketing 14.00
Service 8.40
Affidavit
Surcharge 2.00
24.40 Pd. by Atty.
10-24-94
Sworn and subscribed to before me
So answers:
R. Thomas Kline, Sheriff
Depu Sheriff
this 14 d" day of jl.?
19_00V A. D.
t
`UL?. c t L1ti t e a r .
Prothonotary
ARPAD E. 8IP08, : THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.94-5974 CIVIL TERM
LYDIA P. 8IP08, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Personally appeared before me, a Notary Public, in and for
said Commonwealth and County, BRUCE D. FOREMAN, ESQUIRE, who,
being duly sworn according to law, deposes and says:
1. That October 18, 1994, a Complaint in Divorce, properly
endorsed with a Notice to Defend and Claim Rights, was filed on
behalf of the Plaintiff and against the Defendant in the above
case.
2. That on November 9, 1994, I forwarded by certified mail,
return receipt requested, a clocked-in copy of the Complaint in
Divorce, properly endorsed with a Notice to Defend and Claim
Rights, to the said LYDIA P. SIPOS, Defendant, at 237 North 33rd
Street, Camp Hill, Pennsylvania 17011.
3. That the aforesaid clocked-in copy of the Complaint
in Divorce, properly endorsed with a Notice to Defend and Claim
Rights, sent to Defendant LYDIA P. SIPOS, was delivered on
November 15, 1994, as evidenced by the return receipt card signed
by LYDIA P. SIPOS and attached hereto.
4. That to the best of my information and belief, the
signature on Part 5 of the return receipt card is, in fact, the
signature of the Defendant, LYDIA P. SIPOS.
i
BRUCE D. FOREKM, ESQUIR
SWORN to and subscribed
before me this day
of ?prrGtu 1994.
Notary Public
My Commission Expires:
NOTARIAL SEAL
STMC. NICHOLAS, Notary Pub%
NwIsburg, Dauphin County, Pa.
RRy Commisaion Expires Sept. 25, 1595
P 099 226 131E
RECEIPT FOR CERTIFIED MAIL
%0 NIAII1ANl.1 IAQVI HAITI iirtlV Nllll
Nr)I ll,l{ IN I I I1NAI n INLI MAII
IlIOP lle4 Pl l?'i
iYia P. sipos
Sbmrl dlnl Nn
137 N. 33rd Street
Camp H?11, IPA 17011
.29
ronn?r•n 1 r•w 1.00
91mrell lLgrv?•ly 1. ?. ._.__ ,
. uo.,Nu.era fb?liecly /r•,r .
• I?r1Wn Iir;r. egtl 'Irvwmy
N when, anJ IJdN' IN•Ilmue?l
H Iu , Ihv elyl II 1w n I lu wln n 1.00
Date or I Arltll .. 11 LJ •NVery
tOI AL I'usldgc nno Fu,-s 2. 29
gi Pnntmru. nr D1 Jje
d November 9, 1994
to ?I
'MME
'r
V •
ARPAD K. SIPOS,
Plaintiff
V.
LYDIA P. SIPOS,
Defendant
1. Check either (a) or (b)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-5974 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
(a) 1 do not oppose the entry of a divorce decree.
1L_ (b) I oppose the entry of a divorce decree because:
(Check (i), (ii) or both)
w (i) The parties to this action have not lived separate and apart
for a period of at least two years.
X (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 the rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is
granted.
?L (b) 1 wish to claim economic relief which may include alimony, division
of property, lawyer's fees or expenses or other important rights.
I verify that the statements made in this affidavit are true and correct. I understand that
fltlae statements herein am made subject to the penalties of IS Pa C. S. §4904 relating to unworn
thlsification to authorities.
Lydia . Sipos
Date: 1/ / :L Z l ?4
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 need not file this counter-affidavit.
Y . 4
CERT FI .AT . OF 4 .RVI
AND NOW, this 22nd day of November 1994, 1 Keith B. DeArmond
hereby do certify that I have served a copy of the foregoing on this date by depositing a copy of
the same in the United States Mail, postage prepaid in Camp Hill, Permsylvania, Addressed to:
Arpad K. Sipos
c/o Bruce D. Foreman, Esquire
Nicholas & Foreman
3207 North Front Street
Harrisburg, PA 17110
,.a
a
5i?
., .
.? .
. •r
AXPAD E. 2IY08,
Plaintiff
V.
LYDIA P. 8IP08,
Defendant
.. .
s IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-5974 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
1. A Complaint in Divorce under section 3301 of the Divorce
code was filed on 10/lbrl?
2. The marriage of the 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.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do riot 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. 94904 relating to unsworn
falsification to authorities.
Dated. j\ t.?V I 19') 5)
PAD K. sZPO?-'
1 i
I i ? ?
i r I i
i i I
i i
i
1' ? ? ?? r Ii ? ? - I i
I i I
i ? 1 ?
? I i ? ?
? ? ? ?
I
?!•.
"?? ?. i
Wei .l
i
1- rpl u.
1 ^ ? ? ?
ry
N
?° ?;;?, ,
?'
??
i V
••
.
ARPAD K. SIPOS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO 94 5974 CIVIL TERM
LYDIA R SIPOS, CIVIL ACTION - LAW
Defendant IN DIVORCE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tiled on
October 18, 1994.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of tiling of the Complaint
3, 1 consent to the entry of a final decree of divorce.
4. 1 understand that I may lose rights concerning alimony, division of property,
lawyer's Foes or expenses if 1 do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. 1 understand that
false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unworn
falsification to authorities.
i
i .aYY
ty0li P. Sipos, Defe t
Date:
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff
V File No. - Sq 7 q-
• P j• p IN DIVORCE
Defendant
Notice is hereby giver that the Plaintiff / defendant in the above matter,
[select one by marking " it
prior t? the entry of a Final Decree in Divorce,
or - _ after
hereby elects to resume
written notice avowing hi;
Date: - (?
COMMONWEALTH OF
COUNTY OF (`t1 m 6 ?11
On the day of
notary public, personally
name is subscribed to the
foregoing for the purpose
In Witness Whereof, I
seal.
NOTAfIIAL SEAL PUB CARLISLE CCUUMOBERLA NOTARY, CNOTARY OUNTY CCotI
MY COMMISSION EXPIRES JANUARY
e entry of a Final Decree in Divorce dated
e prior surname of U O , and gives this
/ her intention pursuant t ?)he provisions of 54 S. 704.
i44&signAture
4 ?-?, a? ? ? CLCv
Si ature of name being resumed
SYLVANIA )
200_q, before me, the Prothonotary or the
ared the above affiant known to me to be the person whose
in document and acknowledged that he / she executed the
contained.
hereunto set my hand hereunto set my hand and official
otary ublic
2010
RED-OFFICE
OP THE PFnk OTARY
2009 APR 13 PM 1: 50
n
?? ,vCvr'r l,??f
3 ? 9a