Loading...
HomeMy WebLinkAbout01-0624 FX " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . ~ ~:t',., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LOW ANDA M. BARD, #01-624 CIVIL TERM PLAINTIFF No. VERSUS RICHARD E. BARD, DEFENDANT DECREE IN DIVORCE tJ ~ g- )-OD) c?l <I: ()("p. ,YJ l*YN kNBA M. BiUUI I AND NOW, , IT IS ORDERED AND DECREED THAT Lo IN It/tJb A ".". 8 /t(Jd , PLAINTIFF, AND RICHARD E. BARD , 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 B ATTEST~~ ( 7PROTHONOTARY . ;t;;t;:+; '" . . :+;;ti:+;;ti:+;:+;;F.:+;:+;;F.:+;:+; :+; :+; :+;'f.;F. ;F. 'f.:+;'f. 'f. . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . :+;;F."'''''' i i, j ~ ii ~' i...,",.,... e. /(. /1 . (}S /1. It( 'c5 . ,'.' ",.,ce' ~J 7 ""'i.- '\-' If' " ,*' ,'t- -- , ()J.~_~b-d ~ ~ )i4:e ~ ~ 4 E~ ,,,=,; ,"~ '", '"7-'.' ,'!-7~"'1 !!!!ill!IIII!III1'!II!!P!II(~,,", .!. ,__~ _, '".. r""~l1,~~,~,.,,,~:ft,, ~__, ~.~ Y ,"'P7t.rJII ..~ " , -- .....- ill!: .. LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit th~ record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: Januarv 31. 2001. bv certified mail. r~stricted delivery. 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff on October 31. 2005; by the defendant on September 8. 2005. 4. Related claims pending: NONE 5. Date plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: October 31, 2005. Date defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: October 31, 2005. Date: November 1, 2005 , Attorney for the Pla~nt~ff F1LED-DFFICE OF THE PROTI1ONOTIIRY 2005 NOV -2 PM I: 16 CU',jQ'::,:.'ll"."U" ('(',lu"NTY i~ W;..: lLr~~" v.... l PENNSYLVANIA ~ I ~ ~ .!i I I . 11 .~ I I j ~ ,~ is j ;'i' ~~ I}r ,~'~=, "~ ", . ~-'" . "",' LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant # 0/- !t;)l( CIVIL TERM 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 tail 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 divorce is indignities or irretrievable breakdown of the marriage I you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 ,~ ,. -~ , '"~ ")j LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant # CIVIL TERM AFFIDAVIT OF MARRIAGE COUNSELING I, Lowanda M. Bard, being duly sworn according to law, depose and say: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. ~4904 relating to unsworn falsification to authorities. Dated: ~ v(~ /11. ~ Lowanda M. Bard, Plaintiff Sworn and SUbSC~O bef~ me thi~ of OM' \ ~<I\ iY\Cr\Ao-W Nota>"}' Public day , 20QL. tIOTAAIAL lEAL MIle CMCll '" /IDtiII!'JN, .-rI CaI\lIle ....... 0..... ,\and CountY l><l'- ...->- June 28, 2003 "., c...- WOf"'- ,".' ~ ",." LOWANnA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant # OJ- t,.:t'f CIVIL TERM COMPLAINT IN DIVORCE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW COMES, Lowanda M. Bard, Plaintiff, by her attorney, Ruby D. Weeks, Esqui~e, who avers as follows: 1. Plaintiff, an adult sui juris, is Lowanda M. Bard, a U. S. citizen, who currently resides at 323 Airport Road, Shippensburg, Cumberland County, Pennsylvania 17257, since February 5, 2000. 2. Defendant, an adult sui juris, is Richard E. Bard, a U. S. citizen, who currently resides at 15 Irvin Drive, Shippensburg, Cumberland County, Pennsylvania 17257, since November 1997. 3. Plaintiff and Defendant have been a bona fide resident(s) 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 June 16, 1990, in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 6. Neither party is a member of the Armed Forces of the United States. 7. The marriage is irretrievably broken. 8. Plaintiff and Defendant have lived separate and apart since February 5, 2000. ,"-' - '" -, '-.f.' 9. 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. 10. Plaintiff requests the Court to enter a decree of divorce. COUNT I - IRRETRIEVABLE BREAKDOWN 3301 (c) of the Divorce Code 11. Paragrapns 1 through 10 are hereby incorporated by reference and made a part hereof. 12. The marriage is irretrievably broken. a. plaintiff and Defendant have lived separate and apart since February 5, 2000. 13. Plaintiff has been advised as to the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 14. Plaintiff requests the Court to enter a decree of divorce. COUNT II - REQUEST FOR DIVISION OF PROPERTY UNDER SECTION 53502 OF THE DIVORCE CODE 15. Paragrapns 1 through 14 are hereby incorporated by reference and made a part hereof. 16. The parties purchased or otherwise obtained during the course of their marriage property which is considered "marital property". 17. Upon entry of a divorce decree, such property should be divided equitably as is just and proper. "H_ . -I,. ~'.' , -~,1 WHEREFORE, plaintiff prays that a decree in divorce be entered divorcing plaintiff from the bonds of matrimony between the said plaintiff and defendant. a. As to Count I, in the alternative, should Defendant execute an Affidavit consenting to a divorce because the marriage is irretrievably broken, that a decree in divorce be entered divorcing Plaintiff from the bonds of matrimony between the said Plaintiff and Defendant. b. As to Count II, that this Court determine marital property and order an equitable distribution thereof. c Such other additional relief as the Court deems necessary and appropriate. 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: \\?tl\D \ I o!~ /Jt. &ud Lowanda M. Bard, Plaintiff ~ Ruby D Weeks, Esquire Attorn y for Plaintiff 10 West High Street Carlisle, PA 17013 (717) 243-1294 .' ,-.J ... . oJ' COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND The above named, Lowanda M. Bard, being duly sworn according to law, deposes and says that the facts contained in the foregoing Complaint are true and correct, and the Complaint is not made out of levity or by collusion between her and the said Defendant for the mere purpose of being freed and separated from each other, but that it is brought in sincerity and in truth for the cause mentioned in the said Complaint. r/~ /7z ~ Lowanda M. Bard, Plaintiff Sworn and subsc~i~~d to bef~ me this~ day of Cl.i'N 10. ^^^/ , 20Q.L. ~ 0~~ Notary Public NOTAIlIAL SEAL CMOI. A. ~. NcIary PubIc CaoIloIe IIcoD, eu......lallcl County "" ~, ulstl.. ExpIroo June 28. 2003 NOTAIlIAL SEAl. CUIOl. A. MORROw, Nolory Publk CarhsIe Boro. Cumbeooi"l1::i C."'1<lJ,"';' My Com~j!$.iQf'l Exoitll'J Jvn" ".., . . . .......' " ... ., \ , _...L.~ . -" .~, "" LOWANDA M. BARD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :v. :CIVIL ACTION - LAW :IN DIVORCE RICHARD E. BARD, Defendant :#01-624 CIVIL TERM AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA R.C.P. 1920.4 (al (II (ii) COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND I, RUBY D. WEEKS, ESQUIRE, Attorney for Lowanda M. Bard, being duly sworn according to law, depose and say that a true and correct copy of the Divorce Complaint was served on the Defendant, Richard E. Bard, at 15 Irvine Drive, Shippensburg, PA 17256, by mailing the same to him by certified mail, restricted delivery, postage prepaid, No. 7099 3400 0018 5048 7687, on January 31, 2001. Service was accepted on February 2, 2001. RUbY~~ Sworn and subscribed to before me this ~ day of ---f;J1 A I~\ IU-r-' 20OL. ~~~~~J'Yl W1J\ (L j NOTAIIAI. SfAL CARol. A. MOlIIlOw, Noiwy Public CaollIIe ...... C""'b.....,d ",_. My ec.... I J~ ElrpN.,. ~ ~~ ==".~""=. " HlM'),tt;.; ~, .~.J. ~~ ~ ~~ " ... \ ~ .~-,~ ~, - II' ", "::ill '}0 (_ CERTIFIED MAIL RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) "" ..D <0 SHIPPENSIlUR6 Pl\ 17257 "" <0 Postage $ $(t.SS =t' $1, o:::J Certified Fee LJ"I .c Return Receipt Fee $1.50 l <0 (Endorsement Required) ,.." $3.20 ''\ o:::J Restricted Del1very Fee I'. o:::J (Endorsement Required) t:J Total Postage & Fees $ $7.15 c ~ ___ .rC1t~:~!P:JS~.~~m:~~_~~~_s::~~n~_~:_~:m~'m, II"" S,,:!:Apt.j!JoBPXNO. 'l:)ri U 0 mmmnn ~ ~'-!-"if.~,&J.J.LAL.m.n.n'n" ~Timm,n I +-'m~~~~,., "I r' ~,*,,f.,., CARLISLE MPO CARLISLE. Pennsylvania 170132935 0113112001 (717)243-3531 11:15:48 AM Sales Receipt Sale Unit Qty Pri ce Product Description Final Price SHIPPENSBURG PA 17257 First-Class 'estri cted Dell very eturn Receipt ertified Label Serial #: $1 $: $: $: 7099340000185048: Issue PVI: $: al: j by: 1 1ge Due: $i $IC -$2 ~111 #: Clerk: 1000400114749 09 --- Thank you for your' bus i ness - eJlijn;si.~. anJ3.A1soCi,iiipl~te jf Restricted.- Delivery is desired. .' ": your name and address on the reverse ~i~t we can return the card to you. .' ~,this car~ ~o the back of the mailpiece, E)r'e~ t,he front'lf"'Space permits. 1. ~,iele :t\qdressed to: ~ '~ :~~hffKD E :-Dk~ 15 ;1JW}AJe.. Ue..iU~ ~;:Wenstvr:j) P/J r-p.~ x Q..' !s,delivery address different . m item 1? , If YES, enter delivery address below: o Agent D Addr:EtSl!3ige DYes o No , . 3. ~e ice Type , ,Certified Mail 0 Express Mail Registered tJ,"Return Receipt for Merclllanafse o Insured Mall 0 0.0.0. 4. Restricted Deiivery? ~ra Fee) Ye~ -. -'-'-_.~-,------"-------,._~ - -'-"---~-~-"--,._-,- 102595-00-M-0952 < - ! ;: OF 1: ;~~Y o I FEe - 'I ii', .1:~6 CUiv':~C:~" ",',- "i.", I'!V Jl...LJ ~L,"\, ',,,) V',.AJi"J 1 J PENNSYLvANiA <" "" " ,; ~"oo," , LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM PRAECIPE TO WITHDRAW COUNTS IN DIVORCE TO THE OFFICE OF THE PROTHONOTARY: Please withdraw the previous requests for Count I and Count II to be withdrawn, in the above captioned divorce action since these matters have been satisfactorily resolved between the parties. Dated: ~ lI~f -0 ~ B~ Ruby D. wee~squire Attorney for Plaintiff cc: Jeffrey S. Evans, Esquire j' ALED-OfflCE OF THE PROTHONOTARY 2005 NOV -I AMII: 05 CUMBERl.AND COUNTY PENNSYLVANiA '^~ ~~ o ~ LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 30, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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 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. ~4904 relating to unsworn falsification to authorities. Dated: /0-3/-0::' cI~ /k ~ ',LOWANDA M. BARD, Plaintiff Sworn and 8ubSa~ to befor~~s da~..,.... of /7 , 20~ . ~~#~ Notary Public COMMONWE~THOFP~SYLVAN~ NoIadaJ SeIII Wanda K HlIIIter, NoIaJy Public CarlIsle BolO, CurnbeJIand County My Convnlsslon Explres May 10, 200e Member, Pennsylvenle Assoclellon of Notane. .. F1U:I} OFFiCE OF THE PH:-:;'TI!ONCi1i\RY 2D05 OCT :i i Fi'! 12: 52 CU;Vi:.~,::i ' h~i' ~ '\.J\ ,~ '~.,. =" ...', i ,< .;..,-' "'. LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301 (e) 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 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 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: /0- 3/, o$' e(~ f'1.13~ LOWANDA M. BARD, Plaintiff FiLFDOiTICr: (';:: n.,!;:: DCrl'['I">"")TllqV J, ,L. j "'" ~ '\jl.~' d\l,: 2D05 OST 31 PH !2: 52 , ,. cur,.::c: ~ ~ ~" ;" ,--...,. RECBVED SEP 1 6 2005 LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 3D, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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 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. ~4904 relating to unsworn falsification to authorities. Dated: ~Y-OD tf;;i/ fA/ RICHARD E. BARD, Defendant Sworn and subscr~~d to before me this 1r' day of "So~\nAh~ 20dS ~~c\j. ~t~ NOTARlAlSEAI. V' ICeIIy V. High, Notary PublIc .lIId.1ngton TOWIISh/p, FIlIIlIcIIn CounIy My CariimIssfori Exphee Nov. 29,l!llO8 1"'11'''' "'TV','" ',_:LrUI"I"'...I,: 0;: THr: pr~i)rIO\IClTARY CU:'L/ :'Ui'ri'{ ~.........", I ~ \ t ~ - ~ 1 :;, !....:.,~ t \ -~ F"~, t ~n"r 0"'''[ A I LUll;] 'v .,:) Pi'l12: 52 fj' :H" "l'" '\~ ~. .j, .,,1\: """1.': #, ~ ~ ,.;' .' ;:,' '" "r." -::. "'-~'-" . .j," ' , ~"" '~' ,----,~'" -, ", " ';" " "" ;"", ';,i, ,~;~ _ RECEIVED 'SEP 1 6 20f15 LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S 3301 (e) 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 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 are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: ~-i-tJ5- RIg fidfendant FIU:I}-CHTICE OF THE Pi'U'I!(,!\[()T!\ny Z005 OCT 31 Pi'. 12: 52 CUM~,~;,'!._i ' i",,:,Ul.jNry ,~ ~ . . . , . \ . . . . . . . . .. . . . ;f.;F.C+; ;Ii "';Ii i1i;f.:+.:ti"',\'.f. . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . . STATE OF PEN NA. Lowanda M. Bard . No. 01-624 . . VERSUS Richard E. Bard . . . . DECREE IN DIVORCE . . . AND NOW, ,2004 , IT IS ORDERED AND . DECREED THAT Lowanda M. Bard , PLAINTIFF, . AND Richard E. Bard , DEFENDANT, ARE DIVORCED f'ROM THE BONDS OF MATRIMONY. . THE COURT FlETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . By THE coul: ~ ~~' . . . . . . . . . . . . ATTEST: J. PROTHONOTARY "':f.;t: ;f. ;t; . 'f.:f.'f. ;f. '" :f.'" '" ;t; . iIi:+. ;tiT. ;f. ;F.;t; ;F.;F.;F."''+; . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . """"",,,l , ,~, ,. ,. ,.-,'-,-,<'" 0,'_ '",,":" :",-,,' ,,'., '-<;"c".'.""",li'-',~'", ,j ',..~.' ,', , """''',''~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a v.m. NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated approximately February 4, 2000, 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! 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. Dated: I j.. -/ ?~o3 /k~~L Richard E. Bard, Defi ndant . FILED-OfFICE Of 1I1a FP,01\-\ONCJlNi'l 1nn~ J~N -1 Pt,\ 2.: 50 "'U~ ~1; .,^ ,~,' '," 'i', ,r'"JI \~ \~t"\f V l\\:D('~"'\.)-\.i";U ~j Ul',j I 1 PEJ.INS\t0/,l\,\\\\A ,1< J ,l ,~, "",,"-,, ~",:I__. ,"--'k' '~'~,-<I \-"~'Ll.; -~_*," ~"':"___""_"(";' ",:-';.:._ ,,\!{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lowanda M. Bard, Civil Action - Law Plaintiff : #01-624 Richard E. Bard, Defendant : In Divorce a v.m. AFFIDAVIT OF NON-MILITARY SERVICE PURSUANT TO PA.R.C.P. 1920.46 Defendant, Richard E. Bard, being duly sworn according to law, deposes and says that he is the Defendant in the above-captioned matter; that he personally knows the Plaintiff, Lowanda M. Bard, is over the age of eighteen years; and that the Plaintiff is not in the military service or in any branch ofthe armed forces of the United States or its allies or otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress of 1940 and the amendments. ~/~I Ricliard E. Bard, Defendant Sworn to and subscribed before me this J:L day of ~ phn)C\ n 4--' 2004. Mm'la II ?m-ITHo'6 Notary Public I NOTARIAL SEAL PAMELA A SWITALSKI, Notary Public :!lhippensburg, Cumberland County . My Commission Expires Feb, 9, 2004 ..- -,"I ., ",'Y ", ~bG "0" .f .i> 0'" , '~, , '.,C';" .. ~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN Personally appeared before me, a Notary Public, in and for said State and County, Jeffrey S. Evans, Esquire, who, being duly sworn according to law, deposes and says that he did serve Defendant's Affidavit, Affidavit of Non-Military Service, and Notice of Intention to Request the Entry of Divorce Decree in the above-captioned matter on the Plaintiff, Lowanda M. Bard, by mailing a true and attested copy of the same to her attorney of record, Ruby D. Weeks, Esquire, at her mailing address of 10 West High Street, Carlisle, Pennsylvania 17013, by regular, first class mail on January 16, 2004 at the post office in Waynesboro, Pennsylvania. Sworn to and subscribed to before me this ~ day of ~'An lCL^4--' 2004. _Ad0~ ~.~t Notary Public ' NOTARIAL SEAL Kelly V. High. Notary Pubno Washington Township, Franklin County My Commission Expires Nov. 29, 2004 'j. , ,~ ,..'.. , .,-,--,'.." ';',', '--"; t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a V.m. PRAECIPE TO TRANSMIT RECORD 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)(l) of the Divorce Code. 2. Date and marmer of service ofthe Complaint: Service ofthe Complaint in divorce was made on the Defendant, Richard E. Bard, by mailing the same, certified mail, return receipt requested, deliver to addressee only, a true and attested copy of the Complaint for Divorce to the Defendant on January 31, 2001, as evidenced by the Affidavit of Service filed in this cause. The Divorce Complaint was dated January 30, 2001. 3. Date of execution of Defendant's Affidavit required by Section 3301 (d) of the Divorce Code: Defendant's Affidavit was executed on December 18, 2003. Date of service of Defendant's Mfidavit upon the Plaintiff: Service of the Defendant's Affidavit required by Section 3301(d) of the Divorce Code together with Notice to Plaintiff was made on the Plaintiff, Lowanda M. Bard, by mailing a true and attested copy of said documents to the Defendant's attorney of record , Ruby D. Weeks, Esquire on January 16, 2004, as evidenced by the Affidavit of Service filed in this cause. " ~J . . '"~' . , , "~ ,~,' =-" <~"Hi'" , " . ",,,~ ,"~~ ,', "'--, 1 4. Related claims pending: None. 5. 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 Section 3301 (d)(1)(i) of the Divorce Code: Notice of Intention to Request Entry of Divorce Decree was served on the Defendant's attorney of record, Ruby D. Weeks, Esquire, by mailing the same to her, on January 16, 2004 as evidenced by the Affidavit of Service filed in this case. Respectfully submitted, Dated:Jtb/~ Je . .. n " .. <__,' ->,~'"".. <,"" ,. .1, , '" ,~<,,<, "";e . , "' '~,;!~"" "_'0 \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant : In Divorce a V.ID. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Lowanda M. Bard, Plaintiff RubyD. Weeks, Esquire lOWest High Street Carlisle, P A 17013 Richard E. Bard, the Defendant, by his attorney Jeffrey S. Evans, Esquire, intends to file with the court the Praecipe to Transmit Record on or after February 20, 2004 requesting that a final decree in divorce be entered. Respectfully submitted, / B{. J effrey,/ Atto efendant 2081 ERst Main Street Waynesboro, P A 17268 . '- FILE!}{)fF!CE OF THE PROTHONOTARY 200~ FES 25 Ai'lll: 36 Cul'r,'1,:"t: ,:'1 .'.,t~;~ Jr,jTV ,J._.<'. ,'-' l.-'....'VI\lj Pff'~I\SYUi/-\:\jlA I ~ ,I ,,'.. ',' ~- '--'" LOWANDA M. BARD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA V. RICHARD E. BARD NO. 2001-0624 CIVIL ORDER OF COURT AND NOW, this 4TH day of MARCH, 2004, it appears to the Court that Plaintiff's complaint requests inter alia, the equitable division of marital property. We are not prepared to enter a final decree in divorce until Plaintiff's counsel withdraws that claim or the matter is bifurcated after petition and hearing. Edward E. Guido, J. vRuby D. Weeks, Esquire 10 West High Street Carlisle, Pa. 17013 0effrey S. Evans, Esquire 2081 East Main Street Waynesboro, Pa. 17268 .> 03-0~-O'-/ :sld 'Ii FILEO-GFFlCE OF THE PROTHONOT/j'N 200HlAR -4 AllIl: II Cl1t'r--'''''1 ; \ '-' ~', "'I' , 'd,,.., '''", ."..,. ',I), 'h"rv d"'_"_lll--I"lj 'k.! \.,J" u,.. ~ PENNSYlV/,Nli\ ~ " _J,"",~ ,~" ,. ,'~''<'''''3,~""~~'Wii-''!Jfffi''f~~~~~'''f-''m:~~W.,,Jn~: l ~ - iT' 1 '. ~ ~ " DIVORCE INFORMATION S~EET PURSUANT TO ACT 2001-82. VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1, 2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM. PLEASE FILL IN THE APPROPRIA TE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DOCKET NUMBER: 01-624 DATE OF MARRIAGE: 6/16/1990 ,\',~ ff1 * ~ I ~ k' ~ ),1: il~ l:~ ~~ g, t~; ~~: l~;;;;J '-"~...~i~ ;:..- ';~ESS~.~ ..,...- ~'< '1l\...~ ..../~ q...", ,'if..lij - 3 7 - "'I' .';' . :. : -. Law Offices ofJefftey S. Evans 2081 East Main Street Waynesboro, PAl 7268 PB METER 5461145 , . . . . . * * * * * * Us. POSTAGE : J :~~ ~" ~ ~~ ~1 ff;;# ~ ~~ I ~ I &!J, ~,; " ;,<"";"~,,-,.,,,~,",,~,,,,<,,o:"""--''''":..,,,,,,'~\;i,;~,i',, .., '.,=..,=-->-'''''';_ '_'0 ,~.,"",,--,,,~,=.,,,-,=>., ,,~,._. Ii I (~ I , ~, 1\ ~ i ~ o )" Law Offices of Jeffrey S. Evans 2081 East Main Street Waynesboro, PA 17268 I c.~ -~_J;J _ ..~~ t~_ - E ...... ~ ,,\-I Sf)",,,,-" . " 0 _ /.. s 1l...~ ~ ~ - 3 7 - o.~ ,'?t< _ - "'r 4" *~ -' - "I a', Pp,. PB METER 5461145 Ruby D. Weeks, Esquire 10 West High Street Carlisle, PA 17013-2955 , . . * * * . * * * * * us. POSTAGE : 1 %,' )~ {o lE it ftl: q ~ ,,' ~ @ rl ~, Wi ~ ~ !l ~ & -<;1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "';Ii;F.:+: '" if. ;f. .. . . .. . if.;+: ;!;"'Of:+; . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Lowanda M. Bard No. 01-624 VERSUS Richard E. Bard DECREE IN DIVORCE AND NOW, , 2004 ,IT IS ORDERED AND DECREED THAT Lowanda M. Bard , PLAI NTI FF, AND Richard E. Bard , 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; By THE COURT: ATTEST: . . . J. . . . . . . . PROTHONOTARY . . . . if. if. if. if. ;f.;t;;f.;t;;F.~ . . . "''''if. :t'if. .. . '" "''''Of:+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .