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Home My WebLink About07-3218.t Pamela L. Purdy Attorney ID No. 85783 308 N. 2^d St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. a'Y , .3?2 LP CIVIL TERM CIVIL ACTION -LAW 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. a 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 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 4al'k4e PAMELA L. PURDY ATTORNEY FOR PLAINTIFF Pamela L. Purdy Attorney ID No. 85783 308 N. 2"d St., Ste. 200 PO Box 11544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 22107493 facsimile plpurdy@verizon.net Attorney for Plaintiff TRINH BUI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. D7- 3o21P CIVIL TERM SETH BOWER, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE COUNTI Divorce Under 3301(c) of the Divorce Code 1. Plaintiff is Trinh Bui who currently resides at 3612 Franklin Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Seth Bower who currently resides at 276 Walnut Springs Court, West Chester, Chester County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 18, 2005, at Philadelphia, PA. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are: 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. 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. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a decree in divorce. Respectfully submitted, Dated: M 4T I -- <7M+ Pamela L. Purdy Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. O,OJL TR BUI Dated: AY O xZm?- 2 -Dix te AM - r -s,; o cn --c 0 Pamela L. Purdy Attorney ID No. 85783 308 N. 2^d St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-3218 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I hereby verify that I served a true and correct copy of the Complaint in Divorce in the above-captioned matter upon Defendant Seth Bower via U.S. Mail, first class, certified, restricted delivery, postage prepaid, to his address of record at 276 Walnut Springs Court, West Chester, PA 19380-1714. A copy of said Certified Receipt signed by the Defendant is attached hereto. Respectfully submitte Pamela L. Purdy, Esquire Counsel for Plaintiff Date: Sworn to and subscribed before me this day of , 2007. i My Commission N11 ca. NOTARIAL SEAL MAURA A. JENKINS, NOTARY PUBLIC ?0=('HANICSBURQ BORO, CUMBEFILAND COUNTY .v ^?, •?^?'?A"? 1100 IS JAN. 12, 2010 Air 4%k Law Office of Pamela L. 308 N. 2nd St., Ste. 200 PO Box 11544 Harrisburg, PA 17108 Signature: I0Addraiaee r?A Received By. Poeese , t C/early) Date of Delivery/ E 1, N a 7355 5474 47100 4574 5446 RETURN RECEIPT REQUESTED Article AWresaed To: ?ntl??t?nnl?tln?t??nnrt?l?nt?nr??rln??ur?r??nn?lt? Sand...) lcondary Address / Suite / At. /Floor P (Flees Prln! CMadY) Delivery Address State ZIP + 4 Code Seth Bower 276 Walnut Springs Ct West Chester PA 19380-1714 t? ; _ - - ? ?._ ?._ ?.:: ?? ,?-?. ._v Tl ?,.y C..-, ?. ,' ???r,? : . ?..., __ .. _ _ _ E?I f r _ C _ r ' :. (`: ? ? } Pamela L. Purdy Attorney ID No. 85783 308 N. 2"d St., Ste. 200 PO Box 1 1544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS vrn ber?tnd f'rsUn?y , PENNSYLVANIA : NO. 07-3218 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce in the above- captioned matter under Section 3301(c) of the Divorce Code. Date: - -we 411 ?_+ N? Seth Bower 276 Walnut Springs Court West Chester, PA 19380-1714 r 1 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the - day of duly, 2007, a true and correct copy of the foregoing document was served by U.S. Mail, First Class, Postage Prepaid, upon the following: Seth Bower 276 Walnut Springs Court West Chester, PA 19380-1714 Pa e a L. Purdy -2- G ? -rz i.? j `? C.. --` p? _ ? -e? 3'tr 1 ? : `-r' ? _ ?:y.8. ? `-??4i y ? ? ..[ .- Pamela L. Purdy Attorney ID No. 85783 308 N. 2^d St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3218 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. 1 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authoriti TRINH Dated: '???5/?%z 9 a! R "ta ,C C'- +9 "'A, ` Vn Pamela L. Purdy Attorney ID No. 85783 308 N. 2nd St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdyC)verizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-3218 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 a es. Trin Bui Dated: q Mo Q m Oh ?: -21 Pamela L. Purdy Attorney ID No. 85783 308 N. 2 St., Ste. 200 PO Box I 'l 544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3218 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. 1 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsificatio to authorities. SETH BOWER Dated: ? ? 0 ?? ?.a '`? v (? ?" <-1 f ti' a :-r.i r } r ? ' ??=t + _ _ ; C7 .:,; C.= . :,t7 Pamela L. Purdy Attorney ID No. 85783 308 N. 2nd St., Ste. 200 PO Box 1 1 544 Harrisburg, PA 17108-1166 (717) 221-8303 (717) 221-8403 facsimile plpurdygverizon.com Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3218 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1 . I consent to the entry of a final Decree of Divorce without notice. 2. 1 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 aut o s. Seth ower Dated: ? ? n? 1 J i. j - CID t i "r Pamela L. Purdy Attorney ID No. 85783 308 N. 2 Street Suite 200 PO Box 1 1 544 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile pipurdy@verizon.net Attorney for Plaintiff TRINH BUI, Plaintiff V. SETH BOWER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07-3218 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please 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(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 4, 2007, U.S. Mail, first class, certified, restricted delivery, postage prepaid; Acceptance of Service signed on June 4, 2007, returned to the office of the undersigned, and filed with the Court on June 18, 2007. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: 9/3/07 By Defendant: 9/5/07 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: September 3, 2007. Date Defendant's Waiver of Notice was filed with the Prothonotary: September 5, 2007. Respectfully submitted, Pamela L. Purdy Date: Od&tIX--SO ?_ ? -2- CERTIFICATE OF SERVICE The undersigned certifies that on the l st day of November, 2007, a true and correct copy of the foregoing Praecipe to Transmit Record was served by first-class mail, postage prepaid, upon the following: Seth Bower 276 Walnut Springs Court West Chester, PA 19380-1714 PMY_U_? le-4 I-l' Pa ela L. Purdy, Esquire Of Counsel for Plaintiff -3- _ _.. j;? --? `- P .-,-, t,,, ,. . _ ; ':7 - ...., '- : ?=? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TRINH BUI Plaintiff No. 07-3218 CIVIL TERM VERSUS SETH BOWER Defendant DECREE IN DIVORCE AND NOW, !V 6\4tM?Q.1 , 2007 , IT IS ORDERED AND DECREED THAT TRINH BUI , PLAINTIFF, AND SETH BOWER 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. BY THE COURT: PROTHONOTARY Iv -71 y t'D'°? etc' L4 y, .,t