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HomeMy WebLinkAbout07-4567w 0 Jay R. Braderman, Esquire Attorney I.D. No.: 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0'j - ~l5~'7 Civ t t Team JESSICA BOGRETTE, Defendant :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 by the Court. A judgment may also be entered against you for any other claim of 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. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (800) 990-9108 r ~ G Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. JESSICA BOGRETTE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE COMPLAINT DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW Comes Plaintiff, Daniel Bogrette, by his attorney, Jay R. Braderman, Esquire, and respectfully represents as follows: 1. Plaintiff is Daniel Bogrette, an adult individual who resides at 27 Ashburg Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Jessica Bogrette, an adult individual who resides at 3820 Leyland Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for~at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 7, 2006 in Mechanicsburg, Pennsylvania. .,. 5. There were no children born of the marriage: 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c): The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing the Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. B. Section 3301(d): The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on or about July 8, 2006. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. Date: .3 ~ ; .7~U07 miffed, R~~~~nan, Esquire rn I. D.//~No. 07047 126 ocust Street P. .Box 11489 rrisburg, PA 17108-1489 717) 232-6600 Attorney for Plaintiff 2 VERIFICATION Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 7 25 d r-- s ANIEL BOGR I verify that I have reviewed this form with my client and to the best of my knowledge the allegations herein are true and correct. r . D. No.: 07047 12 ocust Street .Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Jay r erman, Esquire Attorney For Plaintiff (\{ ~ L7 ~1 .' ~ • .'. - _T - ~ ~ ..p ~ ~ r ~ m ~ ~ ~-~ ~ T} /yy , ~ - b j~; ~ 1 ~ :~= ~~ J rrt ~ D ~ ~ Jay R. Braderman, Esquire Attorney I.D. No.: 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. JESSICA BOGRETTE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. p7_ ~'Si!v7 C~~~~~~ CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT DANIEL BOGRETTE, being duly sworn according to law, deposes and says: 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 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. s .r--- DANIEL BO TTE ~ ~. ° o O `~ ~? .~:., ~ ~'` c= : :~'. c7 rz7?~ ~~ ,_~,,_ ..Q ~ °7 ~~.~ ~, L- °= m ,~ W Q .~ Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717) 232-6600 Fax: (717) 238-3816 E-mail: jbradermanCa~thewiselawyer.com Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. JESSICA BOGRETTE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4567 Civil Term CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 1, 2007. 2. The marriage between 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 in 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 and 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. Section 4904, relating to unsworn falsification to authorities. Date: (1 ~~ © 7 JE ICA BOGRETTE SS :175-64-2921 ~.-~ ~;~ ~ ` ~. .~., r7 ~( ~~ _, ~~ -.r~ ` r - ~ ~ _,.~ ..... . ~' ~ M1 ` ~.fJ ~ ~ ' Z C~i ~~ _~ . ~..~ ...~ Q "; ~_. Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717) 232-6600 Fax: (717) 238-3816 E-mail: jbradermanC~Dthewiselawyer.com Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. JESSICA BOGRETTE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4567 Civil Term CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 Ic) OF THE DIVORCE CODE 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 understand 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: ~J J ICA BOGRETTE S N: 175-64-2921 C~ ~ ~ ~ ~ri ~: ' -~ t i r' f ~ ~ ~; :~ ` , ;,;: ~- _ - ,< j ~ RTC!°TZ l ~ -:. ~ a° ^C Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717) 232-6600 Fax: (717) 238-3816 E-mail: ibradermanCa7thewiselawver.com Attorney For Plaintiff DANIEL BOGRETTE, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4567 Civil Term JESSICA BOGRETTE, Defendant :CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 1, 2007. 2. The marriage between 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 in 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 and 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. Section 4904, relating to unsworn falsification to authorities. Date: ~ / DANIEL BOGR E SSN: 208-66-5610 1~+~~ ~v~~~, .y ~ ~ <- ' ' 7 C F7 ~r Y r-= t t; r;~. V~ T,r > ,_. , ,13. ~'= - ::~ ~~.^. f_ ~ ~ ., r.~ ~i~ ~ ~~ ~ ~, ~~ ° -c Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717} 232-6600 Fax: (717) 238-3816 E-mail: jbraderman(a~thewiselau~er.com Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. JESSICA BOGRETTE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4567 Civil Term CIVIL ACTION -LAW W 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 understand 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: G~~~i:~ ~/ DANIEL BOGR E SSN: 208-66-5610 ~ -ids ~ _~. ~.. ~ ~ ~ r _.~, , i.. ~~ ~~ _! ^ ~ f~ '3': ... ... ,. • f~ .. ~ ~._. ~ "'" ~ ~~ 1 ' ~r i• { ~ ~.~ ~ •:' Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717} 232-6600 Fax: (717) 238-3816 E-mail: jbraderman c(~.thewiselawyer.com Attorney For Plaintiff DANIEL BOGRETTE, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 07-4567 Civil Term JESSICA BOGRETTE, Defendant :CIVIL ACTION -LAW IN DIVORCE PROOF OF SERVICE PLEASE SEE ATTACHED DOCUMENT FROM THE UNITED STATES POSTAL SERVICE. TJeli..,~~-~2ecord: unrlrED srarEs PQSTLI L SERVICE c? Date: 08/29/2007 Dear Postal Customer: .~ (C ~ ~ Q l~ i ~+ . Page 1 of 1 The following is in response to your 08/29/2007 request for delivery information on your Certified item number 7006 0810 0002 6332 1005. The delivery record shows that this item was delivered on 08/10/2007 at 1:54 pm in MECHANICSBURG, PA 17055. The scanned image of the recipient information is provided below. Signature of Recipient: ~~~ JPSS~CO, L ~YeMP Address of Recipient: ~ ~~~ ~~~ ~~ ~~l ,, f~ Thank you for selecting the Postal Service for your mailing needs. (f you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service ,~, _ _ o ~ a a -. ru ~1i0 m 1 ~ Postage $ ~q.58 ~-~ r~v,t ~ ~a o cerunedFee 62.65, 22 1 ~`~ k 4 Return Receipt Fee ~ (Endorsement Required) #~ • i , ar ~ -` Q~~' ~e Fee O ReaMcted Delive ~ ry ~ (Errtloreehtem Required) ~4 • ~ p ~Q~Sf v ~ Total Postage & Fees ~ ~q •'~$ .D o o ':5 ~ I-~ ~ =----- - Q- ~-- - ------------------------------ aAOaauNb. ~ _ http: //pts. asps. gov/pts/requestDelivery. do?eventLocation=MECHANICSBURG%2C+PA+ 1705 5 &trackB ... 8/Z 9/2007 C7 ~ C ~ 4 n+~9 rz;_' _ C~j fit? ~. ~ r• '. w,. ~_ C-; ^- A' C- .. ....! ~n .-~ ' ~~ ~? ~~T~ ~rn Jay R. Braderman, Esquire Attorney I.D. No. 07047 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 Tel: (717} 232-6600 Fax: (717) 238-3816 E-mail: jbradermanCc~thewisefawyer.com Attorney For Plaintiff DANIEL BOGRETTE, Plaintiff v. JESSICA BOGRETTE, Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-4567 Civil Term CIVIL ACTION -LAW 1N DIVORCE 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(c) of the Divorce Code. 2. Date and manner of service of the Complaint: August 10, 2007, service upon Jessica Bogrette via U.S. Mail, First Class, Certified, Return Receipt Requested, Restricted Delivery, #7006 0810 0002 6332 1005; original Certified Mail Receipt of which is attached hereto. Original Retum Receipt Card was not delivered to sender. A scanned image of signature of recipient was received from United States Postal Service on August 29, 2007, a copy of which is attached hereto. 3. Date of execution of the Affidavit required by Section 3301(c) of the Divorce Ca Code: November 18, 2007, by Plaintiff. By Defendant: November 15, 2007. Plaintiffs .- A~ Affidavit was filed with the Prothonotary on December 5, 2007. Defendant's Affidavit was filed with the Prothonotary on November 29, 2007. 4. There are no related claims pending. 5. Indicate date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and attach a copy of said Notice under Sections 3301(c) or 3301(d)(1 }(i) of the Divorce Code: Plaintiffs Waiver was executed on November 18, 2007. Defendant's Waiver was executed on November 15, 2007. Plaintiffs Waiver was filed with the Prothonotary on December 5, 2007. Defendant's Waiver was filed with the Prothonotary on November 29, 2007. Date: ~~ fitted, u ~ ~ u~ ~~ ~ i iai i, ~.~yun ~ o e No. 07047 P. . B x 11489 6 cust Street Harrisburg, PA 17108-1489 Tel: (717) 232-6600 Fax: (717) 238-3816 E-mail: jbraderman@thewiselawyer.com Attorney for Plaintiff o ° ~. t .~ ~ , (7^i j, ~ S ~ • C ~ -: /` c N D ~qq r J 4-~' c, "'~ 'i ^ .. ,c ~" . 3 ('] ~ ~ ~ ~..-- ~ ~ -»~ .1 I N THE COURT OF COM MO1`~I PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DANIEL BOC~2ETTE -; PLAINTIFF No. VERSUS JESSYCA BOC~7ETTE IlEF'ENDANr 07-4567 CIVIL TERM DECREE IN DIVORCE AND NOW, ~ ~'~'e''M~ ~ ~~ ~~~~, IT IS ORDERED AND DECREED THAT AND ~3ESSICA BCX`~TTE ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAt NTI FF, 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; NOI~ BY THE COURT: ATTEST: J . PROTHONOTARY DANIEL BOGRETTE ~~ ~~c. El ~~~ ,~: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANIEL BOGRETTE, Plaintiff N0. 07-4567 CIVIL TERM V, CIVIL ACTION -LAW JESSICA BOGRETTE, IN DIVORCE Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Defendant in the above captioned Divorce Action, hereby elects to retake and hereafter use her previous name of JESSICA LYNN SMITH. This election is made pursuant to the provisions of 54 P.S. §704. JES ICA BOGRETTE Signature (married name) JESSICA LYNN SMITH Signature (former name) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss: On the ~ day of l~ ~ , 2007, before a Notary Public, personally appeared Jessica Bogrette known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set m an d Notarial Seal COMMONWEALTH OF PENNSYLVANIA Notarial Seal Diane G. RadGiff, Notary Public tary Pub 'c Camp Hill Boro, Cumberland Coup ._ MY Commission Expires Jan. 11, 2p 8 ,embsr r~- fNotaries ~ ~ na ° a ~`:r~ ~ ~ _ ~ ~ ~ , 4 u~y ° N ~ m ~ ~. ' , 1 . 1 y y t~_ V.J V'a . , { V "V