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Home My WebLink About01-4657 LAW OFFICE OF THOMAS D. GOULD A%FORNEYS AT LAW EAST MAIN STREET · SHIREMANSTOWN. PA 17011 JONATHA~A. LIPPY, PLAINTIFF SHARON E. LIPPY, DEFENDAlqT IN THE COURT OF CO~ON PLEAS CUMBEI~LAND COUNTY, PE~TRSYLV~NIA NO. 2001 - ~S7 CIVIL TE~ IN DIVORCE NOTICE TO DEFEND A~D 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 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 JONATHAN A. LIPPY, : IN THE COURT OF CODliN PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001 C VIL TE M SHARON E. LIPPY, : IN DIVORCE DEFENDANT : COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Jonathan A. Lippy who resides at 115 Victoria Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Morninglory Lane, Manheim, The Defendant is Sharon E. Lippy who resides at 52 Lancaster County, Pennsylvania 17545. 3. The Plaintiff and Defendant have been bonafide residents the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 27, 1997 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. The marriage is irretrievably broken. The Defendant is not a member of the Armed Services of of 7. the United States or any of its Allies. 8. The Plaintiff has been advised of the availability of counseling 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 of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made and correct. I understand that false subject to the penalties of 18 Pa. C.S. falsification to authorities. in this Complaint are true statements herein are made 4904, relating to unsworn Date: athan A. Lipp~'~ JONATHAN A. LIPPY, PLAINTIFF SHARON E. LIPPY, DEFENDANT IN THE COURT OF C0~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4657 CIVIL TE~ IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 3, 2001. 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 1-8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JONATHAN A. LIPPY, PLAINTIFF SHARON E. LIPPY, DEFENDANT IN THE COURT OF COt~ON P?.~.~S CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4657 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT Divorce 2. A Complaint in Divorce under Section 3301(c) of the Code was filed on August 3, 2001. The marriage of Plaintiff and Defendant is irretrievably from the date of the broken and ninety (90) days have elapsed 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the of intention to request entry of requirement that I receive notice the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JO~THAN A. JONATHAN A. LIPPY, PLAINTIFF SHARON E. LIPPY, DEFENDANT IN TEE COURT OF CO~ON pT.~-~S CUMBERLAND COUNTY, PENNSYLVANIA NO- ~2001 - 4657 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301¢c~ OF THE DIVORCE COD~ 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JONATHAN A. LIPPY, PLAINTIFF SHARON E. LIPPY, IN THE COURT OF CO~4ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4657 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE D~m UND~U SECTION 3301¢C} OF THE DIVORCE CO~ 1. I consent to the entry of a final decree 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 t. hat 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: I/- Iz-oI ~ARON E. JONATHAN A. LIPPY, PLAINTIFF Vo SHARON E. LIPPY, DEFENDANT IN THE COURT OF COttON P?.~-~S C~ERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4657 CIVIL TF~M IN DIVORCE ACCEPTANCE OF SERVICE I, SHARON E. LIPPY, accept service of the Co~t~laint In Divorce in the above captioned matter. Dated: 52 MORNINGLORY DRIVE MANHEIM, PA 17545 DEFENDANT JONATHAN A. LIPPY, PLAINTIFF Vo SHARON E. LIPPY, DEFENDANT IN TEE COURT OF CO~ON P?.~S CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4657 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail on August 3, 2001 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the signed Acceptance of Service attached hereto, the Complaint was received by the Defendant on August 4, 2~01. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA (717) 731-1461 17011 JONATHAN A. LIPPY, PLAINTIFF SHARON E. LIPPY, DEFENDANT IN THE COURT OF CO~ON PLEAS CUMBEBLAND COUNTY, PENNSYLVANIA NO. 2001 - 4657 CIVIL TEP~M IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO the Prothonotary: Transmit the record, to the Court for the entry of 1. Ground for divorce: 3301(c) 2. together with the following information, a divorc~ decree: irretrievable breakdown under Section of the Divorce Code. Date and manner of service of the complaint: On August 4, 2001 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, November 11, 2001; By Defendant, November 12, 4. Related claims pending: 5. Date Plaintiff's Waiver 2001. None of Notice in § 3301(c) divorce was filed with the Prothonotary on Novqmber 16, 2001. Date Defendant's Waiver of Notice in § 3301(c) was filed with the Prothonotary on November 16, 2001. Thomas D. Gould, Esquire Attorney For Plaintiff divorce IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ,~. PENNA. JONATHAN A. LIPPY, Plaintiff VERSUS Defendant NO. 2001-4657 CIVIL DECREE iN DIVORCE ! ANd NOW, L~ov/~c)- ?,o DECREED that Jonathan A. Lippy AND Sharon E. Lippy ARE DIVORCED FROM The BONDS OF mATRImONY. 2001 , IT IS ORDERED aND , PLAINTIFF, , 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; NONE BY THE COURT: /) ~ E PROthONOtarY JONATHAN A. LIPPY, PLAINTIFF SHARON E. LIPPY, DEFENDANT IN THE COURT OF CO~ON PLEAS C~ COUNTY, PENNSYL~rANIA NO. 2001 - 4657 CIVIL TERM IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR S~ CO~ONW~%LTH OF PENNSYLVANIA : : COUNTY OF CUMBEPJ~AND : SHARON ELIZABETH' LIPPY, deposes divorce being duly sworn according to law, and says that she is the Defendant in the above-captioned action in which a final decree from the bonds of matrimony was entered and she hereby elects to resume her prior surname of SHARON ELIZ~ETH ROTT~and, therefore, avowing said intention, in accordance November 15, 1972, P.L. 1063, Sworn and subscribed to before me this ~ day of ~z;~-~ ~- , 200~ gives this written notice with %704 of the Act of 54 PA.C.S. Section 704. ~SHARON ELIZABETH LIPPY J To be known as ~_/~HARON ELIZABETH ROTTMANN M~ ~. (kriS, No~y Public S~lv~ SPCa Twp., C~mt~d~d Cotmty My Commission ~Fk~ Nov. I?, 2003