HomeMy WebLinkAbout99-06424 F g
too,
? 7rfyR
?lnv
T
tom,
,A
Y ., ? v ?)
T
t
ii?f
i r
P
S
S r
'
°
i ?
?•
x
e h.
fl.
f h
S ` Y F 4 Fem.
..
SL,
Y
R Y r , ?
G
5
.
?WX}
4.
.
?x;X 'F
_ tv N }eyf
?
? ?
?
?
9R 4p ; ,7 {
i
S? S '.:1 <
t \5 taY ? R
? ?
i
K
,
t Sf
y x? Y ij N
.
ve
L „y t
V
yy ,
'
;t "P Q
kA 1
?
?'
Y t
?? f Z
? A
??^t ?.
.v
t yy ?
°
'?
Se.1
?
Sd
' zx t
s4E? N
_ r ri
ro?
G
<
A WOW
y
#eJ$Y
??` ? r a
YA1 k,
J
?
v Y
h9y
L
Se >: 4
' ;???
4 .y]
E41 V{'
?
?
f} = y?
}j
?'
ham,
fy
i
V
t` 1'
F
3Es 0
.:
Fick;
l?????
V
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF -;p PENNA.
NICOLE L. BERTRAM,
?I N O. 99-6424 CIVIL TERM
Plaintiff
VERSUS
ROBERT F. BERTRAM,
Defendant,
DECREE IN
DIVORCE
AND NOW, 2000 IT IS ORDERED AND
NICOLE L. BERTRAM
DECREED THAT
ROBERT F. BERTRAM
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
PLAINTIFF,
,DEFENDANT,
THE COURT RETAINS 1URISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None.
It is further ORDERED, ADJUDGED and DECREED that the terms, provisions and conditions
of a certain ants Settlement grccment ctwccn the parties ate November I 0-,F999 arc
incorporated in this Dccrec in Divorce by reference as fully as if the same were set forth herein at
length. hall nutmerge- ith-but-shall-surviveihis-Decreein-DitvrcL.
BY THE COURT:
ATTES
J.
// e ,
PROTHONOTARY
.: i?.. '..' '•'
-,, A'
C
1
•• • ?
r_ +
GU
0
o
> 0
z z
U4
e
a 0
A m
M
W
r/
u
C
ltl
v
C y
pc
'"O?CFs:
?8z?
00 Is
go
go
?
80 a w
F a
U
N 8
04 W 3
U z 0
4 A.
t 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM,
Plaintiff )
V. ) NO. 99-6424 CIVIL TERM
ROBERT F. BERTRAM, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
PRAF,CIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of a divorce
decree:
I. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Service accepted by Stephen J. Dzuranin,
Esquire; Acceptance of Service is being filed contemporaneously herewith.
3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce
Code: by plaintiff, February 12, 2000; by defendant, June 5, 2000.
4. Related claims pending: All claims resolved by Marital Settlement Agreement entered
into between the parties on November 10, 1999.
5. Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary:
February 28, 2000; date defendant's Waiver of Notice in §3301(c) Divorce was filed
with the prothonotary: contemporaneously herewith.
Date: Jy,?-r 46
r
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Nicole L. Bertram
Cindy S. Conle squire /
HOWETT, K SINGER & CONLEY, P.C.
130 Walnut Street
P. 0. Box 810
L7 i f tl
C: p
oaw
n a
a
w
,t
> o
?5'aN
z
NZ
M
w
a
W z
Z
u
W
~
91. Q
C 9 O .x
O
H 'w
m
A y+
w55 f0 M
may! 6
w ,
a Y
Q z
~ m .3
azeo
O
O>.7
01 u +
?z u
3 ?
3
?
° _
81
Uzi l E z a° S
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. ) NO. 99- le11,2! CIVIL TERM
ROBERT F. BERTRAM, ) CIVIL ACTION - LAW
Defendant ) 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 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, Cumberland County Courthouse, 1 Courthouse Square, 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 1S 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
Telephone: (717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. )
ROBERT F. BERTRAM, )
Defendant )
NO. 99- tpv1Y CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Nicole L. Bertram, by and through her counsel, Howett,
Kissinger & Conley, P.C., who states the following in support of the within Complaint:
I. Plaintiff is Nicole L. Bertram, an adult individual who currently resides at
4152 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is Robert F. Bertram, an adult individual who currently resides
at 4152 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055.
3. Both the Plaintiff and the Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for a period of at least six (G) months immediately preceding
the filing of this Complaint.
4. Plaintiff and Defendant were married on December 30, 1994 in Palm City,
5. Neither Plaintiff nor Defendant is in the military or naval service of the
United States of its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of
the Congress of 1940 and its amendments.
,t
Florida.
6. There have been no prior actions for divorce or annulment of the marriage
instituted by either of the parties in this or any other jurisdiction.
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.
COUNT I - DIVORCE PURSUANT TO 63301(c) or (d)
OF THE DIVORCE. CODE
8. The prior paragraphs of this Complaint are incorporated herein by
reference thereto.
9. The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce
pursuant to §3301 (c) or (d) of the Divorce Code.
COUNT II - DIVORCE PURSUANT TO §3301(a)(6)
OF THE DIVORCE, CODE
10. The prior paragraphs of this Complaint arc incorporated herein by
reference thereto.
11. Defendant has offered such indignities to Plaintiff, who is the innocent and
injured spouse, as to render Plaintiffs condition intolerable and life burdensome.
12. This action is not collusive.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree in divorce
pursuant to §3301(a)(6) of the Divorce Code.
COUNT III - EQUITABLE. DISTRIBUTION
13. The prior paragraphs of this Complaint are incorporated herein by
reference thereto.
14. Plaintiff and Defendant have legally and beneficially acquired property,
both real and personal, during their marriage, which property is "marital property."
15. Plaintiff requests the Court to equitably divide all marital property.
Respectfully submitted,
C
r
Date:
J C. liowctt, Jr., uirc
HOWETT, KISSINGER & CONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff
Nicole L. Bertram
1
i
I
i
g
1, John C. Howctt, Jr., Esquire, hereby swear and affirm that the facts contained in the
foregoing Complaint in Divorce arc true and correct to the best of my knowledge, information,
and belief based upon information provided by Plaintiff Nicole L. Bertram and from my own
first-hand knowledge and that said facts arc made subject to the penalties of 18 Pa. C.S. §4904
relating to unswom falsification to authorities. Plaintiff is outside the jurisdiction of this Court
such that her verification cannot be timely obtained.
Date: to kh I =A r- 4
Joh owett, Jr., Esq ' e
?ir l
? Tx,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. ) NO. 99.6424 CIVIL TERM
ROBERT F. BERTRAM, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce on behalf of Robert F. Bertram, Defendant
in the above-captioned action, and certify that I am authorized to do so.
Date: I`? .1- 9f
508 North Second Street
P.O. Box 845
Harrisburg, PA 17108-0845
Telephone: (717) 2344182
. ,7 , -a- i-,t t! s 3
i
Ii
v
O•r W
y
6S> a
WWWW ..7 O W
W L
C
O
V
z
. •.
N Ca -H ca
0
O
?
r
,L
9
M
•a
. d
Q F.? N
[
; d ?
yC
pX
a N ri
F
_FFFF6` 4
9 - 0 C7
7 p
8
O .
?
o
UZ kk
7 p q
b
NR r
U
C,4
? E En
CA
8
0.
1711
kkkk
go
1 N
•[Z
? 3
z
0 N
Z O
dG N
z
?.-1
H
P^. 4
4 r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. )
ROBERT F. BERTRAM, )
Defendant )
NO. 99-6424 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF COUNSELING
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on
October 21, 1999.
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 in divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein arc made subject to the penalties of 18 Pa. C.S.A. §4904, relating to
unswom falsification to authorities.
Date:' - llD ?t' rlh?rl?
Nicole L. Bertram, Plaintiff
w •
F
tn; pga j _.
c ?
w
e
cwi >
° -
O =
0
N
A
P7M
u
m
?
W
OA
wOS S
Up?C ?S
'? a. S
^
`
$?. wr..o z<c
a
3
o??
N
FS"x w "v v
,
F•c°:? S o ??w O
z
o
v 04 A
a7 Z
r
i
z
i
IN 17HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. )
ROBERT F. BERTRAM, )
Defendant )
NO. 99-6424 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVFR OF NOTICE. OF INTENTION TO REQUEST
ENTRY OF A DIVORCE. DECREE UNDER
§3301 (c) OF THE, DIVORCE. CODE
1 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 1 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 trnc and correct. 1
understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. §4904
relating to unsworn falsification to authorities.
Dale: DU
Ni ole L. Bertram, Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. ) NO. 99-6424 CIVIL TERM
)
ROBERT F. BERTRAM, ) CIVIL ACTION - LAW
Defendant ) IN DIVORCE
DF.FF.NDA?gj5_A)AVIT OF CONSENT
AND WAIVER OF COUNSELING
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on
October 21, 1999.
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. 1 consent to the entry of it final decree in divorce after service of notice of
intention to request entry of the decree.
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,A. §4904, relating to
unswom falsification to authorities.
Date:
Robert F. Bertram, Defen nt
i
M `I
ji;
A„ .eat.
YY ?xY
1dt 4 I-
+? 4<I ti =;fl. z
Zi t?
Y?
4
?j '4? ?r . .Ir .'C 3 ?Ary SN.x r}r.
< 1
a
(I a?
x y? t1,
t??1{t ?? 11
'
k ar till y v
, Y
?
^
N
II
A
4
l
M
ff5
?
t jA
.
' k
e??a 1, 4 e I ?t.
a
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. )
ROBERT F. BERTRAM, )
Defendant )
NO. 99-6424 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OFNOTICE OF INTENTION TO RF.OU W.
ENTRY OF A 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 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 arc 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.
Date: t% S-40 L'0 &/'74&-
Robert F. Bertram, Defcnd
} ' ?
Ly ?•
F~--: J
?
t 1'?.??
'.CV .
-7
(_: _ ?.t;
.
tTl.?. «. .
,, .,
,1
'
l.i ??? .
?? J
:._ .t1
(.i f7
O °i
CJ
t r,:.'
;
i.
'i?r
,: t'
t?
r..`t3
;:€i;
xt" tYC
?5
-: a?
TA
GJ
o Mze (W? a
w 6 04
?o
w
zyya
Oa w
4-4
u o 0
U -
O
.
EEEEEE'???++++++
OC >
CG s
' m w
41 CCC C W tj u £F
E. 8 1 U)
8 -0%
g
o, a
N F
a
o
rzi z rz o a S
w
? J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NICOLE L. BERTRAM, )
Plaintiff )
V. )
ROBERT F. BERTRAM, )
Defendant )
NO. 99.6424 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE WITHDRAWING ANCILLARY CLAIMS
TO THE PROTHONOTARY:
Please withdraw the ancillary claims filed by Plaintiff Nicole L. Bertram in her
Complaint in Divorce.
Date: & Od
I?
Cindy S. Conley, E uire
HOWETT, KISSI GER & CONLEY, P.C.
130 Walnut Street
P. 0. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Nicole L. Bertram
;;i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NICOLE L. BERTRAM,
Plaintiff
vs.
ROBERT F. BERTRAM,
Defendant
File No. 99.6424 Civil Term
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a Final
Decree in Divorce on the 21" day June, 2000, hereby elects to resume the prior surname of
Nicole L. Shrawder, and gives this written notice pursuant to the provisions of 54 P.S. § 704.
DATE: ?? ' I5 D Z
Nicole L. Bertram
Nicole L. Shrawder
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS
On the 19^ day of Feb(L"t , &W2_, before me, a Notary
Public, personally appeared the above afiant known to me to be the person whose name is
subscribed to the within document and acknowledged that he/she executed the foregoing for the
purpose therein contained.
In Witness Whereof, I have hereunto set my hand and official seal.
l If.,k I -
Nota 1 Public
NOWW sod
Mgola A. Mist PAN
Minor. burp fta
tAy Coon"srbn ExOns Apt W 20.,
r7
C\Jl
? i
r'