HomeMy WebLinkAbout02-5536BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. do -fK.~,CIVIL TERM
)
) IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHT~
You have been sued in court. If you wish to defend against 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 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 piaintiff. 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, 1
Courthouse Square, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAAIM 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
2 Liberty Avenue
Carlisle, PA 17013
(717)249-3166
BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) 1N THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. CIVIL TERM
)
) IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELINC
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a complaint in a divome proceeding
fried in the Court of Comn~n Pleas of Cumberland County. This notice is to advise you
that in accordance with section 3302(d) of the Divorce Code, you may request that the
court require you or your spouse to attend marriage counseling prior to a divoree being
handed down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You're
advised that this list is kept as a convenience to you and you are not bound to choose a
counselor ~om this list. All necessary arrangements and the cost of counseling sessions
are to he borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within 20 days of the date on which received this notice. Failure to do so will constitute a
waiver of your right to request counseling.
BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. CIVIL TERM
) IN DIVORCE
.COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
1. Plaintiffis Brett C. Bornman, who curremly resides at 35 North Hanover Street,
Apartment 3, in the City of Carlisle, the County of Cumberland, Commonwealth of
Pennsylvania.
2. The Defendant is Angela Bornman, who curremly resides at 7 Teaberry Drive, City of
Carlisle, County of Cumberland, Commonwealth of Pennsylvania.
3. Both Plaintiffand Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this complaint.
4. The Plaintiff and Defendant were married on May 15, 1998 in the Town of Boiling
Springs, County of Cumberland, Commonwealth of Pennsylvania.
5. There have been no prior actions of divorce or for armulmem between the parties.
6. There were no children bom to Plaintiff, Brett Bomman, or Defendant, Angela
Bornman.
7. The marriage is irretrievably broken.
8. Plaintiffhas been advised that counseling is available and that Plaintiffmay have the
right to request that the court require the parties to participate in counseling.
9. The Defendant, Angela K. Bornman, is not a member of the armed forces of the
United States or its allies.
9. Plaintiffrequests the court to enter a decree of divorce.
Date
Respectfully Submitted,
Brian C. Born~n, Esq.
Atty. ID 89105
Kline Law Office
714 Bridge Street
Post Office Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint 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.
Brett C. Bornman- Plaintiff
BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. 02-5536 CIVIL TERM
)
) IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint Under Sections 3301(c) and 3301(d) of
the Divorce Code.
Date:
Angelot~rK. Bornman- Defendant
7 Teaberry Lane
Carlisle, PA 17013
BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. 02-5536 CIVIL TERM
)
) IN DIVORCE
~AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301 (c) of the Divorce Code was filed on November
15, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the complaint. Service was completed by
an Acceptance of service being filed by Defendant on November 26, 2002.
3. I consent to the entry of a final decree of divorce and waive notice of intention to
request entry of a Divorce Decree under §3301 (c).
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:~~
~)efendant
Social security #: 184-58-1952
BRETT C. BO~
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMlVION PLEAS
) OF CUMBE~AND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. 02-5536 CIVIL TERM
)
) IN 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 ofproperty, lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is emered 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
unde~d that false statements herein are made subject to the penalties of 18 Pa.C.S.
~4904 relating to un_sworn falsification to authorities.
Date.-_~/~ ~//_v~
Angela l~~-----7'~ndant
BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACTION-LAW
)
) NO. 02-5536 CIVIL TERM
)
) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~3301(c) of the Divorce Code was filed on November
15, 2002.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the complaint. Service was completed by
an Acceptance of service being filed by Defendant on November 26, 2002.
3. I consent to the entry of a final decree of divorce and waive notice ofintemion to
request emry of a Divorce Decree under §3301 (c).
I verify that the statements made in this affidavit are true and correct. I
understand that false statemems herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date:
BTtt C. Bomman. plaint~Tf~t~ ....
Social Security #: 177-66-5463
BRETT C. BORNMAN
Plaintiff
VS.
ANGELA K. BORNMAN
Defendant
) IN THE COURT OF COMMON PLEAS
) OF CUMBERLAND COUNTY
) PENNSYLVANIA
)
) CIVIL ACT/ON-LAW
)
) NO. 02-5536 CIVIL TERM
)
) IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO RE UEST ENTRY OF A DIVORCE
DECREE UNDER 3301 c OF THE DIVORCE CODE
1. I consent to the emry ofa fmal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI 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 sero to me immediately after it is filed with the
prothonotary.
I verify that the statemems made in this affidavit are tree and correct. I
understand that false statemems herein are made subject to the penalties of 18 Pa.C.S.
§4904 relating to unsworn falsification to authorities.
Date:
Brett C. Bomman- Plaintiff
BRETT C. BORNMAN,
PLAINTIFF
Vo
ANGELA K. BORNMAN,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-5536 CIVIL TERM
CIVIL ACTION - LAW
· 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:
Code.
Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce
2. Date and manner of service of the Complaint: Acceptance of Service filed by
Defendant on November 26, 2002.
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: By Plaintiff: March 3, 2003; By Defendant: February 28, 2003.
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) of the Divorce Code: Waiver of notice
executed by Plaintiff on March 3, 2003 and by Defendant on February 28, 2003.
Respectfully submitted,
Date
BRIAN C. BORNMAN, ESQUIRE
714 Bridge Street
Post Office Box 461
New Cumberland, PA 17070-0461
(717) 770-2540
Attorney for Plaimiff
IN
THE COURT OF COMMON PLEAS
Of CUMBERLAND COUNTY
STATE Of
BRETT C. BORNMAN,
PLA INT IFF
VERSUS
ANGEL~ K. BORNMAN,
PENNA.
NO. 02-5536 Civil
DEFENDANT
DECREE IN
DIVORCE
AND NOW,. ,/~ II '~ , 2003 , IT IS ORDERED AND
DECREED THAT
.... BRETT C. BORNMA'N
, PLAINTIFF,
AN D ANGELA K. BORNMAN
, 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;
Nol~e
PROTHONOTA~'
BRETT C. BORNMAN,
PLAINTIFF
Vo
ANGELA K. BORNMAN,
DEFENDANT
· IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
· NO. 02-5536 CIVIL TERM
· CIVIL ACTION - LAW
· IN DIVORCE
NOTICE OF ELECTION TO RETAKE FORMER NAME
NOTICE IS HEREBY GIVEN that the Defendant in the above matter, having received a
iqnal Decree in Divorce from the bonds of matrimony on March 11, 2003, hereby elects to retake
and hereafter use her previous name of ANGELA KAY VORODI.
ANGEL)f KAY VORQDI
COMMONWEALTH OF PENNSYLVANIA:
· SS
COUNTY OF ~ '
On the tqTI~ da)' of ,2003, before me, the undersigned
I
officer, a Notary Public, personally appeared Angela K. Bornman, known to me or satisfactorily
proven to be the person whose name is subscribed to the within instrument, and acknowledged that
she executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
NOTARIAL SEAL
JODY S. SMITH, NOTARY PUBLIC
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005
NOTAR'~/PUBLIC