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Home My WebLink About03-3443SANDRA E. BOHNER, P~aintiff SCOTT A. BOHNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O3 -- 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 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 at the Cumberland County Courthouse, Carlisle. PA 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, PA 17013 (800) 990-9108 elano M. Lant~' ~ ~ Pamela L. Purdy I00 Pine Street, P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 A. Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. B. Section 3301(d): N/A 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. McNEES/W~LLAOE & NURJZ~K ~J..C Delano M. Lantz I. D. #21401 100 Pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: July 17, 2003 VERIFICATION 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. Dated: SANDRA E. BOHNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3443 Civil Term SCOTT A. BOHNER, Defendant IN DIVORCE PROOF OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce in the above matter was served on the Defendant, Scott A. Bohner, by certified mail, restricted delivery, return receipt requested on July 28, 2003. See Exhibit "A" attached. The Complaint in Divorce was received and signed for by the Defendant on August 2, 2003. The original of the return receipt is attached hereto as Exhibit "B". McNF__~S)~LACE & NURICI~,LLC Delano M.. Lantz[,_///' ~ I. D. #21401 100 Pine Street P. O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: August 7, 2003 McNees Wallace & Nurick attorneys at DELANO M. LANTZ D~RECT DIAL: (717) 237-5348 E-MAIL ADDRESS: DLANTZ~MWN.COM July 28, 2003 Mr. Scott A. Bohner R.R. 1, Box 1200 Herndon, PA 17830-9606 Re: Bohner v. Bohner No. 03-3443 Civil Term Dear Mr. Bohner: Enclosed and served upon you is a certified copy of the Complaint in Divorce which was filed of record in the Office of the Prothonotary, Cumberland County Courthouse on July 18, 2003 to No. 03-3443 Civil Term. Very truly yours, By 'd:3elano M. Lan( DML/msb Enclosure cc: Sandra E. Bohner (w/enc.) CERTIFIED MAIL, RESTRICTED DELIVERY EXHIBIT "A" 100 PINE STREET · PO Box t166 · HARRISBURG, PA 17108-1166 o TEL: 717.232.8000 ' FAX: 717.237.5300 ' '¢ANW.MWN.COM HAZLETON, PA · STATE COLLEGE, PA · COLUMBUS, OH · WASHINGTON, DC 7160 39fll 9844 1911 1889 TO: Mr. Scott A. Bohner R.R. 1. Box 1200 Hemdon. PA 17830-9606 SENDER: Delano M. Lantz. Esquire REFERENCE: 21664-0001 PS Form 3800, June 2000 RETURN RECEIPT SERVICE US Postal Se~ce Receipt for Certified Mail Certified Fee Re.t~Jrn Receipt Fee ,estricted Delivet,/~ I Total Postage & Fees ~¢'~ c~ S [A ,~-.,. POSTMA~K~ ~/~E~ 716~ ~901 9~44 1911 ~9 3~-~ Service Type CERTIFIEO MAIL ~-" Fee) ~Yes 1. A~icle Addressed to: Mr. Scott A. BohQer E.g. t, Box !,200 Hemdon, PA 17830-9606 Is delivery ~ddreSs dllN,rent lrom item If YES, enter delivery address belOW: 21664-0001 ~ M. Lantz, Esquire ~ D~--~--- Return Rece~ EXHIBIT "B" SANDRAE. BOHNER, Plaintiff SCOTT A. BOHNER, Defendant IN THE COUI~,T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3443 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT OF PLAINTIFF A Complaint in Divorce under §3301(c) of the Divorce Code was filed on July 18, 2003 and served on August 2, 2003. 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 after service of the 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. §4904 relating to unsworn falsification to authorities. Date: November .~ ,2003 ra E. Bohner, Plaintiff 194-42-8752 (Social Security Number) SANDRA E. BOHNER, Plaintiff SCOTT A. BOHNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3443 Civil Term IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF 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: Sandra E. Bohner, Plaintiff SANDRA E. BOHNER, Plaintiff SCOTT A. BOHNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3443 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT OF DEFENDANT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on July 18, 2003 and served on August 2, 2003. 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 after service of the 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. §4904 relating to unsworn falsification to authorities. Date: November / ,2003 Scott A. Bohner, Defendant 162-52-6175 (Social Security Number) SANDRA E. BOHNER, Plaintiff SCOTT A. BOHNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3443 Civil Term : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF 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: Scott A. Bohner, Defendant SANDRA E. BOHNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SCOTT A. BOHNER, Defendant NO. 03-3443 Civil Term IN DIVORCE 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 a Divorce: 23 Pa. C.S. {}3301(c) - Mutual Consent - Marriage irretrievably broken. 2. Date and Manner of Service of the Complaint: Date of service was August 2, 2003. The Complaint was served by certified mail, restricted delivery, return receipt requested on or about July 28, 2003. The return receipt was signed by Defendant, Scott A. Bohner on August 2, 2003, the date the Complaint was delivered to Defendant by the Post Office. A Proof of Service of the Complaint which attached the original green card was filed of record in the Office of the Prothonotary of Cumberland County on August 8, 2003. 3. Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: By Sandra E. Bohner (Social Security Number 194-42-8752): November 3, 2003 By Scott A. Bohner (Social Security Number 162-52-6175): November 1,2003 4. Related Claims Pending: No claims were raised. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary; November5, 2003 , Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 5, 2003 , 5. Pursuant to Paragraph 22 of the Marital Settlement Agreement between the parties dated July 17, 2003, Plaintiff requests that the terms of the Setfiement Agreement be incorporated, but not merged, into the Divorce Decree. Mc~EES/,~LLACE & NU~I'Ct~,LLC~.....~ ~J~ Delano M..L~ I.D. No. 21401 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5,348 Attorneys for Plaintiff Dated: November 4, 2003 -2- iN THE COURT OF COi,MMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. SANDRA E. BOHNER, Plaintiff Versus SCOTT A. BOHNER, Defendant ~ O. O.3~3.4.43...~ivll..I. arm... 19 DECREE ~IN AND NOW, .. · ......... , '~ .:~QQ~, it is ordered and decreed that Sandra E. Bohner .............................. plaintiff, and Scott A Bohner ........................................................ . 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; IT IS FURTHER ORDERED that the terms and conditions of the Marital Settlement m~'merged'wit~.thim. Decree. i:.D~o.roe.. .................................... SANDRA E. BOHNER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3443 Civil Term SCOTT A. BOHNER, Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, after the entry of a Final Decree in Divorce dated ~ove~be~: 17 ,2003, hereby elects to resume the prior surname of Sandra E. Peck, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. §704. Date: ~ o~ ~,,~ ~ ~,~-;° ~ . g~n ~ u ~.~ .,~- ~--'~ -~ -'S~gnature of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~J~2___ SS: On this, the ~.~ day of ~ 2003, before me, the undersigned officer, personally appeared Sandra E. Bohner, known [o me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. In WITNESS WHEREOF, I have hereunto set my hand and seal. Notary Public Notaflat Seal Rhonda L. Lang. Notary Public Harrisburg, Dauphin County My Commi,,',sicn Expires Aug. 9, 2004