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Home My WebLink About03-0948Godfrey & Courtney, P.C. BY: Steven C. CourtneY, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harr}sbur~, PA 1~112 ASHLEY B. BENDER, JARRED B. BENDER, Plaintiff Defendant Attorney got plaint}i[ IN T~-~E CO~L~RT OF CO~V[~[O~ pLEAS, cuMBERLAND COUNTY, No. - CIVIL ACTION -LAW 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 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Dauphin County Court House, Front and Market Streets, Harrisburg, Pennsylvania 17101. PROPERTY, coUNSEL IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL IS FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE PAPER TO YOUR LAWTER 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 ASHLEY B BENDER, V. JARRED B. BENDER, Plaintiff : Defendant : IN THE COURT OF COMMOM PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se le avisa que si no se defiende, el caso puede procder sin usted y decreto de divorcio o anulamiento puedo ser emititdo en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompiniento ieeeparable del matrimonio, usted puedu solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothontary, en la Dauphin County Court of Common Pleas, Front and Market Street, Harrisburg, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR LIN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717.249.3166 ASHLEY B. BENDER, : IN THE COURT OF COMMOM Plaintiff : PLEAS, CUMBERLAND COUNTY, v. : PENNSYLVANIA JARRED B. BENDER, : NO. ~ ~ ~- ~/4 ~ Defendant : CIVIL ACTION -LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes Plaintiff, Ashley B. Bender, by and through his attorneys, Steven C. Courtney, Esquire and Godfrey & Courtney, P.C., and states the following cause of action and in support thereof, avers as follows: 1. Plaintiff, Ashley B. Bender, is an adult individual currently residing at 145 Goodhart Road, Shippensburg, Cumberland County, Pennsylvania, 17257. Plaintiff's social security number is 170-74-3509. 2. Defendant, Jarred B. Bender, is an adult individual currently residing at 344 Meadow Grove Lane, Chambersburg, Franklin County, 17201. Defendant's social security number is 160-62- 2154. 3. Plaintiff and Defendant have been bona fide residents in 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 the 31st day of August, 2002 in Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant are not in the military or naval forces of the United States. state. 6. There have been not prior actions of divorce between the parties in this or any other 7. No children were bom of this marriage. COUNT I DIVORCE PURSUANT TO §3301 (c) OR (d} OF THE DIVORCE CODE 8. Paragraphs One (1) through Seven (7) are incorporated herein by reference as if set forth in full. 9. 10. Plaintiff avers that the marriage is irretrievably broken. Plaintiff has been advised of the availability of marital counseling and that either party has the right to request that the court require the parties to participate in counseling. 11. The parties have separated as of January 12, 2003. WHEREFORE, Plaintiff requests that this Honorable Court enter a decree of divorce. Dated: C01/~/ 2O03 Respectfully submitted, GODFREY & COURTNEY, P.C. Steven C. C~ey, Esquire P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 I.D. # 74669 VERIFICATION I, Ashley Bender, hereby certify that the following is correct: The facts set forth in the foregoing Complaint are based upon information which I have furnished to counsel, as well as upon information which has been gathered by counsel and/or others acting on my behalf in this matter. The language of the Complaint is that of counsel and not my own. I have read the Complaint, and to the extent that it is based upon information which I have given to counsel, it is true and correct to the best of my knowledge, information, and belief. To the extent that the content of the Complaint is that of counsel, I have relied upon such counsel in making this Verification. I hereby acknowledge that the facts set forth in the aforesaid Complaint are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: Ashley Bend~ · Document #: 180841.1 Godfrey & Courtney, P.C. BY: Steven C. Courtney, Esquire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg. PA 17112 (717) 540-3900 Attorney for Plaintiff ASHLEY B. BENDER, : Plaintiff : V. -' JARRED B. BENDER, : Defendant : IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL ACTION -LAW IN DIVORCE PROOF OF SERVICE I, Steven C. Courtney, Esquire, do hereby certify that on April 4, 2003, a copy of the Court of Common Pleas Complaint filed in the above referenced matter was served upon the following person by personal service as evidenced by the executed Affidavit of Service attached hereto. Jarred Bender 344 Meadow Grove Lane Chambersburg, PA 17201 Dated: GODFREY & COURTNEY, P.C. By Steven C. Courtney,-L~quire Attorney I.D. No. 74669 P.O. Box 6280 Harrisburg, PA 17112 (717) 540-3900 Attorneys for Plaintiff NOTARIAL SEAL PAMELA A. SWITALSKI Notary Public Shippensburg, Cumberland County My Commission Expires F?b. 9, 2004 ASHLEY B. BENDER, Plaintiff Vo JARRED B. BENDER, Defendant IN TIlE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(C) of the Divorce Code was filed on March 3, 2003, and served on April 4, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not 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. § 4904 relating to unswom falsification to authorities. C) ASHLEY B. BENDER, : Plaintiff : JARRED B. BENDER, : Defendant : IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE 1. I consent to thc entry of a final 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 bc divorced until a divorce decree is entered by the Court and that a copy of thc decree will be sent to me iramediately after it is fi]ed with the Prothonotoary. I verify that thc statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to thc penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. ,ate: A~hley B. Benff ' - ASHLEY B. BENDER, : Plaintiff : V. ; ; JARRED B. BENDER, : Defendant : ; IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(d) of the Divorce Code was filed on March 3, 2003, and served on April 4, 2003. 2. The marriage of Plaintiff and Defendant is i~xetrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service of the Complaint. 3. I consent to the entry of a f'mal decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 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: Z-/c~--o.~ /~,z,ro J/~ ~ J~c~ ~. Bender ASHLEY B. BENDER, V. JARRED B. BENDER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 of property, lawyer's fees or expenses ifl 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 Cour~ and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotoary. I verify that the statements made in this affidavit are: true and correct. I understand that false s~atements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. Date: Ja~d'B.~"~der ASHLEY B. BENDER, Plaintiff V. JARRED B. BENDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL AC, TION - LAW 1N DIVORCE PRAEC?IPE TO TRANSMIT RE~ORI~ TO THE PROTHONOTARY: Kindly transmit the record, together with the following i~fformation, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under §3301 (c) of the Divorce Code. 2. Date and manner of service of Complaint: Served upon Defendant: via personal service, on April 4, 2003. Affidavit of Service filed on June 19, 2003. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plainfift~s and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301 (c) of the Divorce Code, pursuant to Pa.R.C.P. 1920.42(e)(1): Plaintiff- 7/9/03 and filed 7/22/0:3 Defendant- 7/10/03 and filed 7/22/03 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: n/a (2) Date of service of the plaintiff's affidavit upon the defendant: n/a Document #: 198356. Complete the appropriate paragraphs: (a) Related claims pending: 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 under §3301(d)(1)(i) of the Divorce Code: n/a GODFREY & COURTNEY, P.C. Steve~.~a~aey~quire I.~ff. 74669 lEO. Box 6280 Harrisburg, PA 17110-0300 (717) 540-3900 Attorneys for Plaintiff Document # 145617 ASHLEY B. BENDER, JARRED B. BENDER, Plaintiff : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-948 CIVIL ACTION - LAW IN DIVORCE CERTIFIt~ATE OF gERVICE AND NOW, this ~ ~ day of ~I, 2003 I, Steven C. Courtney, Esquire, of Godfrey & Courtney, attorneys for Plaintiff, hereby certify that I served a copy of the Praeeipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Jared Bender 820 Blanchard Avenue Chambersburg, PA 17201 GODFREY & CO'URTNEY By: SteVenS. ~C~e; Document #: 168260.1 IN THE COURT OF COMMON PLEAS Ashley B. Bender OF CUMBERLAND COUNTY STATE OF PENNA. N O.03--948 DECREE IN DIVORCE AN D N OW,__ DECREED THAT AND Jarred B. Ashley B. Bender Bender , (,.0~)--, IT IS ORDERED AND , PLAINTIFF, , 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; None PROTHONOTARY