Loading...
HomeMy WebLinkAbout02-5732WILLIAM R. BOGEL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DENISE P. BOGEL, Defendant CIVIL ACTION - LAW NO. X'72,2. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Denise P. Bogel 2534 West Walnut Street Colmar, PA 18915 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. 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, One Courthouse Square, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #. 2452861 WILLIAM R. BOGEL, Plaintiff V. DENISE P. BOGEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION o LAW NO. IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff, William R. Bogel, is an adult individual currently residing at 926 Grahams Woods Road, Newville, Cumberland County, Pennsylvania, 17241. 2. The Defendant, Denise P. Bogel, is an adult individual currently residing at 2534 West Walnut Street, Colmar, Montgomery County, Pennsylvania, 18915. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. Plaintiff and Defendant were married on May 27, 1995, in Monroe County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. PlaintiWs Social Security Number is 181-38-9334 and Defendant's Social Security Number is 530-76-6075. 7. There have been no prior actions of divorce or for annulment between the parties. 8. 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. Document #. 245286.1 10. 11. 12. Defendant. There were no children bom of this marriage.. The marriage is irretrievably broken. The parties have been living separate and apart since August 15, 1999. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and enter any such other Orders as are appropriate and just. Dated: METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Anc[rew~. g"~ars, Es~ire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document~245286.1 VERIFICATION I, William R. Bogel, hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best o£ my knowledge, infomaation and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: Document#.'2452861 WILLIAM R. BOGEL, V. DENISE p. BOGEL, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION _ LAW IN DIVORCE NOTICE If you wish to deny any of these statements set forth in this Affidavit, you must file a Counteraffidavit within twenty (20) days after this Affidavit has been served on you, or these statements will be admitted. Date: 1. AFFIDAVIT UNDER SECTION 3301 d OF THE DIVORCE CODE The parties to this action separated August 15, 1999, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses/fi do not claim them before divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that thlse statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Document #.. 24528Z 1 WILLIAM R. BOGEL, DENISE P. BOGEL, Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5732 CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Denise P. Bogel 245 South Cedar Street, Apt. F222 Spring City, PA 19475 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. 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, One Courthouse Square, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #: 248587.1 WILLIAM R. BOGEL, DENISE P. BOGEL, Plaintiff ' Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5732 CIVIL TERM IN DIVORCE AMENDED COMPLAINT IN DIVORCE 1. The Plaintiff, William R. Bogel, is an adult individual currently residing at 926 Grahams Woods Road, Newville, Cumberland County, Pennsylvania, 17241. 2. The Defendant, Denise P. Bogel, is an adult individual currently residing at 245 South Cedar Street, Apt. F222, Spring City, Chester County, Pennsylvania, 19475. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. Plaintiff and Defendant were married on May 27, 1995, in Monroe County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United and Sailors' Civil Relief Act of the States or its allies within the provision of the Soldiers' Congress of 1940 and its amendments. 6. Plaintiff's Social Security Number is 181-38-9334 and Defendant's Social Security Number is 530-76-6075. 7. There have been no prior actions of divorce or for annulment between the parties. 8. 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. Document #: 248587.1 10. 11. 12. Defendant. There were no children bom of this marriage.. The marriage is irretrievably broken. The parties have been living separate and apart since August 15, 1999. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and WHEREFORE, Plaintiff requests that this Court enter a decree in divorce and enter any such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 248587.1 VERIFICATION I, Andrew C. Spears, Esquire, attorney for Plaintiff, William R. Bogel, hereby certify that the facts set forth in the within Amended Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statemems herein are made subject to the penalties of 18 Pa. C.S.A. {}4904 relating to unswom falsification to authorities. Andrew C. Spears Document #: 248587.1 © 02/21/2003 11:09 7172389280 STERN OR WEI[4TRAUB PAGE 02 MICHAEL J. LUKENS, Plaintiff, ELENI LUKENS, Defendant. * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * NO. * * CIVIL ACTION - LAW * IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce filed in this matter. Dated: Eleni Luke~s Defendant A/,)THE(])/-) 3 4 ~ Mailing Address A TH £,,-) S RECEIVED TIME FEB, 21, IO:ISAM WILLIAM R. BOGEL, DENISE P. BOGEL, Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5732 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff, William R. Bogel, in the above captioned action, hereby certify that a true and correct copy of the Amended Divorce Complaint and Plaintiff's Affidavit Under §3301(d) was served upon Defendant, Denise P. Bogel, by certified mail, return receipt requested, restricted delivery, and regular mail on January 22, 2003· The certified mail came back unclaimed; however, the copy sent regular mail has not been returned to our office; therefore, Defendant is deemed served on February 10, 2003 (15 days after regular mailing)· Attached hereto and marked as Exhibit "A" is a copy of the letter sent via regular and certified mail· Also attached hereto and marked as Exhibit "B" is a copy of the envelope returned and marked unclaimed. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: ~-'~-'~- 03 Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 281598-1 January 17, 2003 VIA CERTIFIED MAIL/17001 2510 0000 2436 0887 RETURN RECEIPT REQUESTED~ RESTRICTED DELIVERY~ AND U.S. MAIL SINC[ 1888 3211 North Front Street EO. Box 5300 Ha rrisburg, PA 17110-0300 717-238-8187 Fax: 717-234-9478 Other Offices Colonial Park Mechanicsburg 717-652-7020 717-691-5577 Millersburg Shippensburg 717-692-5810 717-530-7515 Denise P. Bogel 245 South Cedar Street, Apt. F222 Spring City, PA 19475 Re: William R. Bogel v. Denise P. Bogel Dear Ms. Bogel: Enclosed please find an important legal document. your attorney. Very truly yours, METZGER, WICKERSHAM, KNAUSS & ERB, P.C. You should take this document at once to Andrew C. Spears ACS:cl Enclosure Enclosure: Clocked-in copy of .4mended Complaint in Divorce Document #: 248779. I 0 Certified Fee ~'~ , Return Receipt Fee (Endorsement Required) Restrt~ed Delivery Fee (Endo~ement Required) $8.t5 Total Po~tage & Fees [ Denise P. Bose [ '~U~',:'h~.7 ....................................................... 72Z2 .... [or~O~ox~o. 245 South Cedar St.a .A.~.t.: ....... / 'E~,' g£~£~,'2t~' ......................................................... / Spring I'1'1 C) 0 - I. rl I~~ 0 0 0 WILLIAM R. BOGEL, : Plaintiff : DENISE P. BOGEL, : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT]iON - LAW NO. 02-5732 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREI~ TO: Denise P. Bogel 245 South Cedar Street, Apt. F222 Spring City, PA 19475 YOU have been sued in an action for divorce. 'You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after twenty (20) days from the date hereof, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Corox an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a final Decree in Divorce. A counter-affidavit which you may file with t2he Prothonotary of the court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the cour~ may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, (30 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. PA Lawyer Referral Service PA Bar Association 100 South Street - P. O. Box 186 Harrisburg, PA 17108 Dated: Document #: 245331.1 WILLIAM R. BOGEL, DENISE P. BOGEL, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5732 CIVIL TERM 1N DIVORCE COUNTER-AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE Check either (a) or (b): [] (a) I do not oppose the entry of a divorce: decree. FI (b) I oppose the entry of a divorce decree because: [] (i) The parties to this action have not lived separate and apart for a period of at least two(2) years. [] (ii) The marriage is not irretrievably broken. [] (a) I do not wish to make any claims for economic relief. 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. [] (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request a Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims delay. I verify that the statements made in this counter-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. Dated: Denise P. Bogel Defendant 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 REL1EF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. Document It.- 245330.1 0112 WILLIAM R. BOGEL, DENISE P. BOGEL, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBEILLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5732 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code. Parties have been separated and apart for two years or more. Date and manner of service of Complaint: A Complaint in Divorce was filed on December 2, 2002, and an Amended Complaint in Divorce was filed on January 15, 2003, and served on Defendant, Denise P. Bogel on February 10, 2003, by certified mail, return receipt requested and regular mail. An Affidavit of Service was filed on May 28, 2003. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: NA (b)(1) Date of execution of Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: November 25, 2002 (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: Filing: December 2, 2002 Service: February 10, 2003 (see Affidavit of Service). Complete the appropriate paragraphs: 284372-1 (a) (b) (c) (d) 5. (a) (b) Related claims pending: None Claims withdrawn: None Claims settled by agreement of the parties: All State whether any written agreement is to be incorporated into the Divorce Decree: N/A Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered trader Section 3301 (d)(1)(i) of the Divorce Code: Service: Certified mail, remm receipt requested on May 27, 2003 in US Mail. Respondent signed for the Certified Mail on May 31, 2003. (See letter and copy of Certified Mail receipt attached as Exhibit "A". Date Plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: NA Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: NA METZGER, WICKERSH.~Vi, KNAUSS & ERB, P.C. Dated: By Andrew ~ Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 284372-1 WILLIAM R. BOGEL, DENISE P. BOGEL, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02-5732 CIVIL TERM : : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this \\IYX day of h~\ ~ , 2003, I, Andrew C. Spears, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, William R. Bogel, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Denise P. Bogel 245 South Cedar Street, Apt. F222 Spring City, PA 19475 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By:. Andrew C. Spears 284372-1 IN THE COURT OF COMMON PLEAS WILLIAM R. BOGEL, Plaintiff VERSUS DENISE P. BOGEL, Defendant OFCUMBErLAND COUNTY STATE OF ~~~, ~ PENNA. DECREE 1N DIVORCE AND NOWi DECREED THAT AND WILLIAM R. BOGEL DENISE P. BOGEL , IT IS ORDERED AND , PLAI NTI FF~ , 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; ATT E S ~'Z/~//? /I j. /