HomeMy WebLinkAbout99-07614
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IN THE COURT OF COMMON PLEAS
OF CUMBERLANDCOUNTY
STATE OF 1 ' PENNA.
SCOTT L. BOWERMASTER,
PLAINTIFF
VERSUS
TARA L. BOWERMASTER,
DEFENDANT
No.
DECREE IN
DIVORCE
99-7614 CIVIL TERM
AND NOW, ?JA JAA 19 KJV ", IT IS ORDERED AND
SCO'PT L. BOWERMASTER
DECREEDTHAT
TARA L. BOWERMASTER
AND
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,DEFENDANT,
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
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SCOTT L. BOWERMASTER,
Plaintiff
vs
TARA C. BOWERMASTER
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99 - 7 614 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 divorce: irretrievable breakdown under S3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: U. S. Mail, Certified, Return Receipt
Requested, mailed on January 11, 2000.
3. Date of execution of the affidavit of consent required by S330I (c) of the Divorce Code:
by Plaintiff 06/23/00; by Defendant 06/23/00.
4. Related claims pending: None.
5. Date Plaintiffs Waiver of Notice in S3301 (c) Divorce was filed with the Prothonotary:
9&23f60 7/i Z' dt,
Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the
Prothonotary: 0&2- { . 7't 2 l av
Sally J. 'Winder, Esquire
701 East King Street, Shippensburg PA 17257
(717) 532 - 9476
Attorney for Plaintiff
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SCOTT L. BOWERMASTER,
Plaintiff
vs
TARA L.BOWERMASTER
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99.761'1 CIVIL TERM
: 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 the 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, One South Hanover Street, 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 PA 17013
(717) 249 - 3166
Sally J. Vj? in e , Esquire
Attorney for Plaintiff, SCOTT L. BOWERMASTER
701 East King Street
Shippensburg PA 17257
(717) 532 - 9476
SCOTT L. BOWERMASTER,
Plaintiff
vs
TARA L. BOWERMASTER
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99-7&tV CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
COMES NOW, the Plaintiff, SCOTT L. BOWERMASTER, by and through his
counsel, Sally J. Winder, Esquire, and represents as follows:
1. Plaintiff is SCOTT L. BOW ERMASTER, who currently resides at, and whose
mailing address is, 21 Witmer Road, Shippensburg, Southampton Township, Cumberland County,
Pennsylvania, since September 1974.
2. Defendant is TARA L. BOW ERMASTER, who currently resides at, and whose
mailing address is, 34 Lenwood Park, Shippensburg, Southampton Township, Franklin County,
Pennsylvania, since August 1999.
3. Both Plaintiff and Defendant have been bona fide residents of 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 May 13, 1995 in Mainsville, Southampton
Township, Franklin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff avers that he has been advised of the availability of counseling sessions for
both parties upon request of either party or by order of court, and that a list of qualified
professionals who provide such counseling service is available at the Domestic Relations Office
upon request. By the filing of this Complaint, the Plaintiff acknowledges having been advised by
his attorney of record of the availability of counseling sessions and of a list of qualified
professionals. Plaintiff further avers that he has been advised that the choice of a qualified
professional shall be at the option of the Plaintiff and Defendant and need not be selected from the
list available upon request and, further, that arrangements for and the payment of the services of
the qualified professional shall be the responsibility of the parties and will not be included in the
docket costs of this proceeding.
8. Plaintiff requests the Court to enter a decree of divorce.
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Date:
C?J?v V Vt/
Sally I W der, Esquire
Attorney for Plaintiff, SCOTT L. BOWERMASTER
701 East King Street
Shippensburg PA 17257
(717) 532 - 9476
VERIFICATION
I verify that the statements made in this complaint are true and correct to the best of my
personal knowledge and belief. 1 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: ?yitri-
SCOTT L. BOWERMASTER
SCOTT L. BOWERMASTER,
Plaintiff
vs
TARA L. BOWERMASTER
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99 7614 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Sally J. Winder, being first duly sworn according to law do depose and say that I
served a Complaint in Divorce in the above action to the Defendant, TARA C.
BOWERMASTER at 34 Leawood Park, Shippensburg, Pennsylvania by certified mail, restricted
delivery, return receipt requested, on January 11, 2000, at the Shippensburg Post Office,
Shippensburg, Pennsylvania, which Complaint in Divorce was received by the Defendant as
evidenced by her signature on the attached receipt.
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.
Sally J. order, Attorney for Plaintiff
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SCOTT L. BOWERMASTER,
vs
Plaintiff
TARA L. BOWERMASTER
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NUMBER: 99 7614 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
December 21, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing 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.
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: ?n' ???19d 4dd4id 2sr
SC 1 L. B WERMASTER
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SCOTT L. BOWERMASTER,
Plaintiff
vs
TARA L. BOWERMASTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: '92- 2614 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER Section 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 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: 'v7 -b 4e%4=J>(GL?/l d
SCOTT L. BOWERMASTER
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SCOTT L. BOWERMASTER,
vs
Plaintiff
TARA L. BOWERMASTER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99 - 7614 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
December 21, 1999.
2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have
elapsed from the date of filing 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.
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: B?
Defendant
TAR( L4WF4LASATAR
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SCOTT L. BOWERMASTER,
Plaintiff
vs
TARA L. BOWERMASTER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NUMBER: 99 - 7614 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER Section 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 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
unworn falsification to authorities.
Date:
TARA L. BOWERMASTER
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