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Home My WebLink About00-05677 i ".'#. P S i I ;.>;;::~_._,- .::.>>::~: ':.:+::~,- ,-.", w ~.~ I ~.~ ~ ~., ~ ~.s ~ ;..~ ~ ~.~ ~ ~.~ ~ "" ;.:; ~ '-.,' M A "- 0 " ",.....c.. )::.::(:::.::.::~;~..::~:\+.::( ~- ",.i tf ~.~ k-'~ ~ ~.~ * :~>>.::~ :~~::.:::. >::C~~:)::.;{)::.X:::~::c(~~:+X,X+.::~~::::~>>::!;::}>>::~; :,:~::C()::c~;:::::~::+::<:::~::+.::~;;::::~::.::~;;: ::~~::+.::~, :X+'::!;;;''}1<~f::+'::~ff::~::C:,,*~::+'}Wt~::C~;)J,~::Ci{f!>>'::! -."'.:C'.. ,.~",,, ~ ,.,. --------- ;:<" ,..::.::" "':~:<l~~ ~ I ~ ;..~ * N * ~ ~.t ".", W ~.\! ~.~ ~ IN THE COURT OF COMMON PLEAS ',.,' i ~.~ OF CUMBERLAND COUNTY '",,' a ~.~, -"." ~ ~.~ >.~ ~ ;'.~ ~ v ~ STATE OF PENNA. ~'s * I II I No 'uuZQQQ.-:-.J6.77 .uuUuu.uu.. 19 u...Ryan.E....Cmrer ,,'..u....... Plaintiff ;"S ~ ~,., ~ Versus ~~, ~ ~ ~ ~4 ~ t') a ~.~ .. ...Yolanda..Bonifacio..Cover ,. u.... ......Defendant. DECREE IN D I V 0 R C E ~(.:~6A,~. AND NOW, '." .r':'l.1=..3..I..,........,. lt9C. 2001., it is ordered and decreed that ,Ry.an .E.. .Co\<er. ' . . . , . . . . , . , , . . . . . . . , . , , , . . . , , , , , , '. plaintiff, and.., Y01aHaa.gc;mifad0, C0ver...,.,....",....,.",....,..... defendant, are divorced from the bonds of matrimony. -,-,.' ~ ~.~ ~.~ ~ 0" ~ ;~; ~ ~.~ ;'.s ~ ~'S ~ ....,; ~.~ ~ 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; . NpPl=..,..;.."....,.,.......,.".,....",.......,."."...,..,..,.,.".... By At ".~k............. -1P:f~~otary :.>>::.-:::::.3&;;::-'::';';' ::.>>::.,,::"::+::--,::::'::+::';,. "::+::." ":.::+::." '.::+::., ~ ~ .:+;..:+;. ::.:+;.x.;..:.:+;.):~;.):+;.x+;....:.;. -:+;.:.:+;. ..:+;.' - ~- ~" ~+:~ ~ ~ ~ r.~ ~~~ ~ N ~ a ~.~ ~ '".' ~ ~.<! ~~1 ~.~ * ;'.s , I ;'S ~ ~ ~.~ >"'; ',;" ~ ~.~ N * ';, ~. ~ ~.~ '.,,' ~ ~.~ ~ ~.~ ~'S ~ ~ ~.~ a ~l i ~.~ ~ ~.~ ~ y ~ ~ '.~ J. * s ~ ~.~ ;'~ ~ , . y , ~ "~ ~ ,~^ "' . Co _ ~" '" ~'~~',~ --,,~ 5-3/-01 U ~ ~ ~ 4' $~ 531'0/ ~ ~ ~~. I I I I I I I l I I ! I I '!!II. -~ ~- --- "77"_ = ~~Jlll'l~l'<<f-'!M~~~_! ",.,.~ .". _~ _~ ~~~~~~~T ~ ~'"""~I~~~ "-''"'''',;;--..'''' 'F' ".h_.___.,,-~'. """',' c. " 'c' :.'..-, ':.;.,~_,",~,','.i,:~- , _.. .,',_,,- !-.---- " 'F'; "'3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ryan E. Cover, Plaintiff : No. 2000-5677 : Civil Action - Law vs. : In Divorce Yolanda Bonifacio Cover, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree; 1. Ground for divorce; irretrievable breakdown under 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: The complaint was served by publication pursuant to Order of Court dated 12/28/2000 a copy of which is attached as Exhibit "A": Proofs of publication from the Sentinel and the Cumberland Law Journal are attached as Exhibit "B" and Exhibit "C". 3. Date of execution of the Affidavit of Consent required by Section 3301(d) of the Divorce Code; by the Plaintiff, April 11, 2001; The Affidavit of Plaintiff was served upon Defendant by publication in the Sentinel on April 24, 2001 and in the Cumberland Law Journal on April 27, 2001, Exhibit "D" and Exhibit "E". 4. Related claims pending: None. 5. Plaintiff's Notice of Intention To Request Entry in Decree in Divorce of Section 3301(d) was signed on April 11, 2001 and was filed on April 27, 2001; Service by publication in the Sentinel on April 24, 2001 and in the Cumberland Law Journal on April 27, 2001, Exhibit "F" and Exhibit "G'. ~" '.".-' -, '-<-,- '-, ,",'" -, ,J "-_ _',F'~"'_A"'"^.c>'__;~ ,,:: -- - ,; '~';--"~< -~-,_.::. -"'-:. - ,-_ - '- ,J' . '<'~ ,~o_ R. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532- 3270 L........, .. .'^ 'o-':.L,:",.,;"_,.,,, ';-if ....... -.. , ~ , " -. _';"-0 ,,'-:.> h' '''''' -~ _ =._ .... "',~~... it: -t' t' 1 '~, ' ~J ,-, , ,'" I: --~ ~ ~"~ Ryan E. Cover, Plaintiff vs. '-'-""- - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Yolanda Bonifacio Cover, Defendant : No. 2000-5677 : Civil Action - Law : In Divorce ,:: '- - ~ -"'~"""""'"",,_: )11;,',:\ "tv ORDER OF COURT AND NOW, this cl~day of December, 2000, after review of the petition by H. Anthony Adams, Attorney for Plaintiff, Ryan E. Cover, the Plaintiff i;; _f) () .! c I! tJ J, granted the right to serve Defendant by publication~ ~ ~ re.. '.. (J (~)J) . J. ~'I~'\~\~ ~ PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication ,,,,..'.,'....-- - -', ....--.~ .--- 1M THE COURT OF COMMON PLEAS OF C,UMBERLAND COUNTY ~ PENNSYLVANIA I Ry~n E._C.oVer, No. OO~5677 Civil Term Plafntif~ vs. eMI Action - Law Yo,landaBonifacio Cover, In Divorce Defendant : . NOnCE TO DEFEND AND CLAIM RIGHTS You have been used in Court. If you wish 10 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. tt:le case may proceed without you and a de_cree il1 divorce or annulment may be 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 il:nportant to you, including the custody or visitation righ.ts of ypur children. Wherft'!1:e ground for divorce is indignities or irretrievable breakdown of the marriage, you may requeslrriarriage counseling. A list of marriage counsel- o'tS is aVailable in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IFYOUUO NOT FILE A CLAIM FOR ALIMONY, DIVI. SION OF PROPERTY, LAWYER'S FEESOR EXPENS- ES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM AN'l'OF'THEM, ' YOU SHOULD TAKE THIS PAPER TO YOUR' -i LAWYE"FfATONCE.IF YOU DO NOT HAVE A LAWYEHOR CANNOT AFFORD ONE, GO TO ClR TELEPHONE THE OFFICE SET F="ORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar-Association 2 Liberty Avenue. Carlisle. PA '170'13 (717) 249-3166 March 27, 2001 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. //~,A v{</~~ . .-"' / // March 28 2001 ~ Sworn to and subscribed before me this 28th day of March , 2001. ~O'~~ Notary Public My commission expires: NOTARIAL SEAL SHIRLEY O. DURNIN, Notary Pl'.'.'::' Carlisle Bora" Cumberland COlo. M ComrniSSlOfl Ex 'res Au . 9, ;, &1A~b~~ b ..IlIIiiiiiiiii" -","" ~i:b ,. "- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), p, L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regnlar editions and issues of the said Cumberland Law Journal on the following dates, Viz MARCH 30,2001 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are ~ Roger M. Morgenthal, E Itor SWORN TO AND SUBSCRIBED before me this 30 day of MARCH. 2001 ~ LOISE.~PubUc_ . CartIsIe Bolo. CUm CountY .' My CuRk.dlllan ElcpiI8S MIn:h 5<2Oll5 4~lb;}- ~ " ~ > . , -. ,. ~ CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 00-5677 Civil Term Ryan E. Cover. Plaintiff vs, Yolanda Bonifacio Cover, Defendant IN DNORCE NOTICE TO DEFEND AND ClAIM RIGHTS You have been sued in Court. If you wish to defend agalnst the cla!ms 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 in divorce or annulment may be agaJnst you by the Court. A judgment may also be entered against you for any other cla1m or relief requested in these papers by the Plaintiff. You may lose money or property or other rtghts important to you. including the custody or visi- tation rtghts of your children. When the ground for divorce 1s indignities or irretrievable break- down of the marriage: you may re- quest marriage counseling. A 11st of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A ClAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO ClAIM ANY OF TIlEM. YOU SHOULD TAKE THIS PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE TIlE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Uberty Avenue Carlisle, PA 17013 (717) 249-3166 Mar. 30 3 'r PROOF OF PUBLICATION ~, State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication . "'."IN THE COURT OF COMMON PLEAS ' OF CUMBERLAND COUNTY _PENNSYLVAN1A ! Ryan E Cover, . No. 2000-5677 PJaiiififf vs, Civil Action - Law' I yoranda Bonifacio Coyer, In Divorce "Defendant . , NOTICE i IfyoLi,'wish 10 deny any of the statem~!lts ~et !ot!h in I this affidavit, you must tile a CQunter-a'rfldavlt within i twenty (20) days after this affidavit has been served on you or.1he statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE .1 . The parties to this action separated on October 23, f99f'~fI1d have continued to live separate and apart for a perioo..pf at least two years. :2..Tt':"'3 marriage is irretrievably ?roken. . i 3. I understand that 1 may lose Tights concerning 8;limo- !' ny, division_of property, la.wyer's.fees or expense~ l~ I QO , nol claim them before a divorce IS granted, I verify that the statements made in this affidavit are true and correct. 1 understand that false statements I herein are made subject 10 the pe.nall!~S a! 18 Pa. C.S. I Section 4904 relating 10 unsworn falsIficatIOn 10 authorities. p, ' ,'11 Date: 4/11/01 Ryan E. Cover, am I April 24, 2001 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. ~ - Y{'~'~1/v/~~~ /0 / AtSril 25 2001 25th Sworn to and subscribed before me this day of April , 2001. 0, ~t/)U/j/J ~t~ Notary Public My commission expires: NOTARIAL SEAL . SHIRLEY O. DURNIN, Notary publ.c Carlisle lloro.. Cumberland County Comn\issiOn Ex ires A .9.2003 0~\bl~ ~ - '" - ~ "''"''.~,l , .. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues ofthe said Cumberland Law Journal on the following dates, Viz APRIL 27, 2001 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are RO~Edit: SWORN TO AND SUBSCRIBED before me this 27 day of APRIL. 2001 , ~lot . LOIS E. SNYDE~PUbIIc My=ExpilwsM8idl~ 4~\~ ~ ~ . ~ ~ . CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 2000-5677 Ryan E. Cover, Plaintiff vs. Yolanda Bonifacio Cover, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affida- vit, you must file a counter-affida- vit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF TIlE DIVORCE CODE 1. The parties to this action sep- arated on October 23, 1991 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose tights concerning alimony, division of property, lawyer's fees or ex- penses if I do not claim them be- fore a -divorce is granted. I verifY that the statements made in this affidavit are true and cor- rect. I understand that false state- ments herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifica- tion to authortties. Date: 4/11/01 Is/Ryan E. Cover Ryan E. Cover. PlaJntiff Apr. 27 3 PROOF OF PUBLICATION , "State of Pennsylvania, County of Cumberland. Sherry Clifford, Classified Ad Manager' of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ PENNSYLVANIA Ryan' E: Cover, No. 2000-5677 Plaintiff vs. Civil Action - Law April 24, 2001 Yolanda:-:i3onifacio Cover, Defer.i.danr NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (d) DIVORCE DECREE TO~..YOLANDA BONIPAC10 COVER, DEFENDANT You have been sued in an action for divorce, You have failed to answerthe complaint or1ile a counter-affidavit to' the Sl:i.Qtion 3301 (d) allidavit. Therefore, on or after May 20, ~OD1, the other party can request the court to ~nter a final decree in divorce. .If you do not file with the Prothonotary of the Court to answerwHh 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 the Prothonotary of the Court is attached to thiS notice, Unless you have already flied with the court a written claim foreconomJc relief, ,you mustdo so by the above date orthe court may grant a divorce and you win lose forever the right to ask for economic relieL The filing of the form counler.affidavit along does not protect your economic claims. -YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER ATONCE~ IF YOU DO NOT HAVE 'A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOATH BELOW TO FIND OUT WHEAE YOU CAN 'GET LEGAL HELP', . Cumberland County Bar Association 2 Liberty Avenue, CarJisie, PA 17013 (717) 248.3166 In Divorc~ Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. I /// ~d / \d~~t~/-74{'/ /~~.." . ~~ ./ / '-" ~/ >..'.? F / a;;';52001 I 25th - Sworn to and subscribed before me this day of April , 2001. ~~ 0 .~~ Notary Public My commission expires: NOTARIAL SEAL SHiRlEY O. DURNIN. Notary Pub!,c CarIi$Ie Boro., Cumberland Counly Commission E ' s Au . 9. 2003 2y ~ \-6 i-t C1-- - .0--- .- ~. -- """....."0!J; I " , " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regnlarly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regnlar editions and issues of the said Cumberland Law Journal on the following dates, Viz APRIL 27, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are ~Edit: SWORN TO AND SUBSCRIBED before me this 27 day of APRIL. 2001 ..NOli .' LOIS E. SNYDER, NoIIIy Pl!bIIC" CaIIlaIe.BoIO, CumbertandCounlY ~ CommIssIon ExpiI8s Man:hSi200S . 6-t h t' b /"}- Q-. , ' ~.... ';ji"'_.""'~"- " CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No, 2000-5677 Ryan E. Cover, Plaintiff vs. Yolanda Bonifacio Cover, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 330I(d) DIVORCE DECREE TO: YOLANDA BONIFACIO COVER, DEFENDANT You have been sued in an action for divorce. You have failed to an- swer the complaint or file a counter- affidavit to the Section 330I(d) affi- davit, Therefore, on or after May 20, 2001, the other party can request the court to enter a :final decree in divorce. Ifyail do not file with the Prothon- otary of the Court to answer with your signature notarized or vertfied or a counter-affidavit by the above date. the court can enter a final decree in divorce. A counter-affida- vit which you may file with the Pro- thonotary of the court 1s attached to this notice. Unless you have already filed with the court a written claim for economic reUef, you must do so by the above date or the court may grant a 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 PA- PER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE WE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Uberty Avenue Carlisle. PA 17013 (71 7) 249-3166 Apr. 27 4 ,-- ~-,,< "- L w"..'T'''',",'''h'''~- = ,,~, _.c,~' ,___ ~~ '"'~~j"I!'j~~~Ml~'~if.#~~_ ". ~~_, e. ,.~ -~. ~ . .- ,~ , -. , ilIIriiiliIiI -~. ~" -'__.:j;-['~"C n.. ~, jT: '>.-' ~ ~.'~)) ~S ..< "', .' '-1-: -",J t,~,; ; '-f: l~) ~ SJ. ~- w Ii!!i J&'",",,,--~-,-,,~'-~'-'J:.............:iJd. ~- """.....,.,~"'''',.- ~ ~.~~~,""''''''"' ~" - 1li.!!ii!I. , 'M A:_' '-';..---' ~-~-~-.. . ~r~".,.,,-' , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ryan E. Cover, Plaintiff : No. 00 - $"4. 77 C;oll ~ : Civil Action - Law vs. : In Divorce Yolanda Bonifacio Cover, 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 in divorce or annulment may be 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 the custody or visitation rights 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, 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, PA 17013 (717)"249-3166 "'-l!l'i",~. _'.II""'f .. "",...,,,~~ ---~"".. il1" - - ~~.~~~= -lIIP"'- -~-",_.- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ryan E. Cover, Plaintiff : No. ()tJ - ~-r. 71 Cwd. -r'.eR- : Civil Action - Law vs. : In Divorce Yolanda Bonifacio Cover, Defendant COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Ryan E. Cover, who currently resides at 114 Willow Drive, Shippensburg, Cumberland County, Pennsylvania, since October 15, 1998. 2. Defendant is Yolanda Bonifacio Cover, who currently resides at 220 Shadow Lane, Las Vegas, Nevada, since July 1, 1992. 3. Plaintiff and Defendant have been bona fide residents in 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 August 10, 1990, in Reno, Washoe County, Nevada. 5. There have been no prior actions of divorce or for annulment between the parties. ~~-=-~.....-.-~"""" - . ,-~~ ,--- "....___~a__ll'll'. 1'1 , ~ ~".-.~""'''''''''''''-~'''''''~.\" . 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. Respectfully submitted. . Anthony Adams, squire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 _.....?'~. ." -.~.- ""-~ .Lb. I:i>~_ffi;" , ' 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. Section 4904 relating to unsworn falsification to authorities. Date: &/3/0:') 1if <"- ~~ Ry E,-Cover - , , Ryan E. Cover, Plaintiff vs. '-"-,--',"',..p,,-.- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA : No. 2000-5677 : Civil Action - Law : In Divorce Yolanda Bonifacio Cover, Defendant DEe 2 7 20~ ORDER OF COURT AND NOW, this~May of December, 2000, after review of the petition by H. Anthony Adams, Attorney for Plaintiff, Ryan E. Cover, the Plainti~dl /) .l. c.~l.J1< granted the right to serve Defendant by publication";" ~ re....., ~)I) . j), [- ~ 6"~''''(\. ~. 0 \ 0* 'c';, 2>" . \ I v1t'J"~~'17ASIVN3d J 'Il.rr!(l'l n,\~!,,II! 1""'il"'I~^ /V4 \1/ j.."t.J '"I,. ',," .'c,}..!r",,"\/! I .'''...1..,\...- 'n ,- I" I t':b i.jlj 6;; J3[J GO AUVIC' .'1'0 ~ ,- " i - " -~"' ~ -'~.:~ - - ". cJ ;-,~, "-""--- -:,~?',:;'-~:,,,";:::,, ':' ~>: ~ - - ',.:, ,-. - .--~{_:' ~- - - ,.-_i' T.'__<~_""__<"" # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ryan E. Cover, Plaintiff : No. 2000-5677 : Civil Action - Law vs. : In Divorce Yolanda Bonifacio Cover, Defendant PETmON TO SERVE COMPLAINT IN DIVORCE BY PUBLICATION 1. Petitioner is Ryan E. Cover, an adult individual who resides at 114 Willow Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Yolanda Bonifacio Cover, an adult individual who resides at 220 Shadow Lane, Las Vegas, Nevada. 3. Petitioner and Defendant are husband and wife, having been married August 10, 1990 in Reno, Washoe County, Nevada. 4. The Defendant is a Philippine National. 5. Petitioner and Defendant separated on or about October 23, 1991. 6. Petitioner has not seen or spoken to Defendant since October 23, 1991, except on a single occasion in 1993. ,-,"", , ~,- ~--'", -, _,' ,n; _",~<c.,_,~ __ <:,~_-, ;,-,>'- _;>~, :t;-",- - '-:'- _:~, - ,,-'- '-' .,' ,',-,-, " ~. '- 1 7. Petitioner has attempted to locate Defendant in the following manner: a. 2000, mailed the divorce complaint by registered mail and it was returned unclaimed. b. 2000, searched the Internet for phone number. c. 1999-2000, called friends in Sacramento area to ask her family of her whereabouts. d. Early part of 2000, tried 1-800-USA-Search to attempt to find her. 8. Despite his attempts to locate and serve Defendant, the whereabouts of Yolanda Bonifacio Cover remain unknown. 9. There were no children born of the marriage, no joint interest in property created during the marriage, no real property obtained during marriage and there are no property issues raised with this divorce. 10. Petitioner requests the right of serve the Defendant by publication. Wherefore, Petitioner prays your Honorable Court enter an order allowing the Defendant to be served by publication. Respectfully submitted, ~ H. Anthony Adams, Esquire Attorney for Petitioner 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 , -C-,''''- '_"",' ,o~,> -~ ":0" '"..p',.-,,' .c,<~~;~, "_" .." _ ' ,-__~" .",,-_' _, _ 0 .-"",;,;:'-CliL " I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: II b:;2./ao if} ~ {'7 0_ .. ""-'- R}'i E. Cover , Li'1~~ ".,c..'';.-. ~"", . .., 'O"''''''r' '.""'- '-~ , ("') C) C) C C5 -'f 7 r..., [15 ~~t r."1 L_ c -') 2: ~,) (j) c:~ -< .!;:c-) ::2 -l;:c) ~, C) :i; . , c) C L,,_, Z z~ "." \ (.0 :D -( ~, - -.~ = , T "'- ~^ -, ~- - " ". . - "'-"" '''-'-"", -- -~,,' - ,-," , ,- - -~"-" ,~ ,,'-; " -", -,>,,~ -c-,'" ,____..._ , __. '",,,^( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ryan E. Cover, Plaintiff : No. 2000-5677 : Civil Action - Law vs. : In Divorce Yolanda Bonifacio Cover, Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: YOLANDA BONIFACIO COVER, DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit, Therefore, on or after lYln i 9-0, d-f.)O I , the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court to 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 the 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 court may grant a divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit along 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, 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 >'." T---.,.- 0 C~ ,~ ~.---' ~ --;-! ;J> ..-...! --r'J-cr; -; -r qJrrj :-.:0 ~:I~:t;~ <!:.- ...ll< N 2:1:;:,: (J).,:;:,. -..; C~.?~;:' -<.c. ~O v S~?~1 ~,O L.O r;,: gr.] ::i>k,; ~ r::- "-' 5J -.l -< .., ~, - - I ~~-~-0"^'" _" .-C_o ,,_,,", ;~,,'-:-,~.:;,__~<,_- , - .- -. -, - :-~-;" -,,'- " - , - 0-',. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Ryan E. Cover, Plaintiff : No. 2000-5677 : Civil Action - Law vs. : In Divorce Yolanda Bonifacio Cover, Defendant NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on October 23, 1991 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: 'i /1 Ib; ~"'-'- c!!.. (>""",,- Ry E. Cover, Plaintiff ''''''''iillk , ."'ee'.... " ---^,- H-..,~". ':C"'h." , , . ,~ ~,.~- ,o~ ~ v.__.- - ,~ .e' .~ ';l ~ C,; I; ","" ,J ~ I~i .. " ;,J " q i~~ ~ 0 c) C) C" --;-~ ~ ".. ,o-! -Or!"" "0 ~';l;Q '" 0.1 fTl :;0 Z::r) N ~@ ZS: (J') .' .-.,i .~Z kO .. eO =~~ Zo t.y >c': -..; ~ r:- 53 -". m -<