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Home My WebLink About97-05606 ~ - '. :) "-- '-l -...) C:) ~ ~ 0'" . Q ~I r.. " " " " 1; " H / (,/ 31M.f dJ '~A'~ ~ ~~,w' 3./9 .f,f" 7!bk/ ,Ma:tl./ 7l: ? - , . . . -- t'J i~ t.- . i. . - ., ( III ~ ( , , ( , j: ;' r. , ,. I'. i - ~J S): :'./ ; ) C' i I - " - . L .'! r ii.-j . . !tC" , . " ,.,., , U 0' 0 NICOLE R. BLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO,97- 5tcOl.Q CIVIL TERM IN DIVORCE DA VID B. BLOWERS, Defendant 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 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 allY 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 with your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may req!.est marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 17013. 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 Fourth Floor Cumberland County Court House Carlisle. Pennsylvania ]7013 Telephone: (717) 240-6200. NICOLE R. BLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW i DAVID B. BLOWERS, Defendant NO.97- 5'(.o{.. CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Nicole R, Blowers, who has physically resided at 245 West Middlesex Drive, Carlisle, Cumberland County, Pennsylvania, since May 16,1997. however, she has maintained said address as her residence and domicile in excess of ten years. 2. Defendant is David B. Blowers, who currently resides at Elizabeth City, North Carolina, since July 21,1997, but who has also maintained his residence and domicile in Cumberland County for at least ten years; Defendant is in the military service. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 15,1996, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 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 of Divorce. I verify that the statements made In this 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 unsworn falsification to authorities. Date:~t\rL lq l..3li {){\' fJ~' ~ ~ iwD'ir.?{/':!.1 ([J '11 wro) I Nicole R. Blowers LAW OFFICE OF EOW ARD L. SCHORPP B~~4~ Edward L, Schorpp, Esquire Attorney for Plaintiff 127 West High Street Carlisle, PA 17013 (717) 243-9258 NICOLE R, BLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW DAVID B, BLOWERS, Defendant NO, 97- 5606 CIVIL TERM IN DIVORCE AFFIDA VIT OF CONSENT \. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on Oclober 10, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complain!. 3, I consent to the entry of a final decree of divorce, 4, I understand that I may lose righls concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(cl OF THE DIVORCE CODE \. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose righls concerning alimony, division of property, lawyers 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 scntlo me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit and waiver are lrue and correct, I understand that false statements herein are made subject to lhe penalties of 18 Pa, C,S. ~4904 relating to unsworn falsification to authorities. . I "r;- Dale: .J ( IL .L / ~) 'i'fj ,~(' J ). "< - I ) I 'Ir".l'......./ /t I .-/UlLtCJtD_ - . Nicole R. Blowers, Plaintiff , I ." r- C,l ~ '. C , ' .~ f:.J ..,.... U.l(l ):/ () :' ':' , [-' n~ J ...J C' ,'Jl , ' 0': ('oJ " !~j; l1J' ~ -llJ) G)~' . \0.- ,. -, . ~. \j C\~ ::; U' U NICOLE R. BLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACT[ON . LAW DAVID B, BLOWERS. Defendant NO. 97- S606 CIVIL TERM IN DIVORCE AFFIDA VIT OF CONSENT I. A Complaint in Divorce under A 3301(c) of the Divorce Code was filed on October 10, [997. I acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on October [4, [997. 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. 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 not claim them before a di vorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l330l(c) OF THE DIVORCE CODE I. 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, lawyers 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 and waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, e.S. A4904 relating to unsworn falsification to authorities. Date: 20 f' f (( 9;' .t.:.-j;{4.. " David B, Blowers, Defendant '>. "J '~ ~:; f-- , C1 I 1I1~ , (l , r--t , : L. t~; f-- d r:l ;..j " , ,. . I ! " t:., --;,.0' , C ;:'1) " ':.t. I . ". "- , (T;; ':J 0 0' l.J 'I 1, NICOLE R. BLOWERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 97- 5606 CIVIL TERM IN DIVORCE v. DAVID B. BLOWERS, Defendanl AFFIDA VIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) AND NOW, this p:j:)&daYOf ~~8,6:'C' ,1997, I, Edward L. Schorpp, Esquire, attorney for Nicole R. Blowers, Plainliff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce in the above- captioned matter, with Notice to Defend and Claim Rights, upon David B, Blowers, the Defendant, alOne Butterchurn Lane, Boiling Springs, Cumberland County, Pennsylvania 17007, by depositing same in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on October 14, 1997, indicating service was effecled, is marked Exhibit "A", attached hereto and made a part hereof, LAW OFFICE OF EDWARD L. SCHORPP By ~~~ Edward L. Schorpp, Esquire Attorney for Plaintiff Sworn a:ld subscri d to before me this ~ dayof U ,1997 ,...---. ~,..... il. . fl, ~~==1':..2.~.-_n. I . "'"'"'" tttmllnd .... on 1M ,.".,.. of "'" fofm 10 tNt .. CIft I rwtum tNI Utd . ,ou. . . Aaatl thIt form to &he "ont o' m.~. Clf on the becta If IPKI ; --......... , , . W.....ft...._....................__.....-........ 2. tl Rlltriclld DeIl.l,., . . The RItum "~I w.1haw to whom the 1rttcIlI... cWvetId end the daft ~ 10 I _. ConlUlt _una"" , III. 3. AnJcla Add".1Id 10: 41. Articla Numbat I allO _ 10 _....the lollowlng H.._ "01 III _a IHI: t. 0 Addla'_'1 A~ David B. Blowers One Butterchurn Lane Boiling 'Springs, PA 17007 Recllpl lor 8. , Doclm.... 1881 1H.I.&.~1___ DOMESTIC RETURN RECEIPT ;; Exhibit A . I l < ( , .- r-, , , - - ; I , , : ! , c. , , ( I , lL , ( C r- , l....' ) j OJ ~ 0' ?=: 11- - (1) -~ - -". ~ ~ Ie- " U.I~~ - ~~ ~:t 9 ft'. \ -~: :1.: ( . ) : "~ l-f-' u- )~j 11 ~ti. c:- 11 \J) .~; (~; ~ 0(. 1 ~ C'I , .' 'iJ ..) ::: --'~ r-t' : (:':: '.I,'-:j J.,..'J "'. 1_0 :c ~~~ :.:- U. CO :'3 () Cf\ (J