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Home My WebLink About07-5280BRENDA BUCKBEE, Plaintiff, V. ROBERT BUCKBEE, JR., Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 07 _ ga 80 Owl l 7-em : 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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 regtat marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 BRENDA BUCKBEE, V. ROBERT BUCKBEE, JR., : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, . NO: 07 ?- S 2 90T.c..-? CIVIL ACTION - LAW IN DIVORCE Defendant. AND NOW, comes the Plaintiff, Brenda Buckbee, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint in Divorce: 1. The Plaintiff, Brenda Buckbee, is an adult individual residing at 210 E. Walnut Street, Shiremanstown, Cumberland County, Pennsylvania. 2. The Defendant, Robert Buckbee, Jr., is an adult individual residing at 210 E. Walnut Street, Shiremanstown, Cumberland County, Pennsylvania 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on April 6, 1991, in Cumberland County, Pennsylvania 5. There were two (2) children born unto the marriage, Emily, born August 31, 1993, and Garrett, born September 12, 2003. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. Neither Plaintiff nor Defendant are members of the Armed Forces of the United or any of its Allies. 8. Plaintiff has been advised of the availability of counseling and that she had the right to request that the Court require both parties to participate in counseling. 9. The Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken pursuant to §3301(c) of the Divorce Code; B. that Defendant has offered such indignities to the person of the Plaintiff as to render the condition of the Plaintiff intolerable and life burdensome pursuant to §3301(a) of the Divorce Code; and C. that as of August 1, 2009 the parties will have lived separate and apart for a period of at least two (2) continuous years pursuant to §3301(d) of the Divorce Codee. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. COUNT I EQUITARU DISTRIBUTION 9. Paragraphs 1 through 8 above are incorporated herein by reference and made a part hereof. 10. During the marriage, Plaintiff and Defendant have acquired various item$ of marital property, both real and personal, which are subject to equitable distribution udder Section 401 of the Divorce Code of 1980. COUNT II ALIMONY PENDENTE LITE COUNSEL FEES. COSTS AND EXPENSES 11. Paragraphs 1 through 10 above are incorporated herein by reference and made a part hereof. 12. By reason of this action, Plaintiff will be put to considerable expense in the preparation of her case in the employment of counsel and thepayment of costs. 13. The Plaintiff is without sufficient finds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 14. The Plaintiffs income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the cost of this litigation. 15. 'the Defendant has adequate earnings to provide support for the Plaintiff and to pay her counsel fees and expenses. 16. Paragraphs 1 through 15 above are incorporated herein by reference and made a part hereof. 17. Plaintiff lacks sufficient property to provide for her reasonable needs. 18. Plaintiff is unable to sufficiently support herself through appropriate employment. 19. Defendant has sufficient income and assets to provide continuing support' for the Plaintiff. COUNT IV CUSTODY 20. Paragraphs 1 through 19 above are incorporated herein by reference and j a part hereof. 21. The Plaintiff, Brenda Buckbee, is the natural mother of the hereinafter mentioned children. 22. The Defendant, Robert Buckbee, Jr., is the natural father of the herei mentioned children. 23. The Plaintiff and Defendant are the natural parents of two (2) children, Emily, born August 31, 1993, and Garrett, born September 12, 2003. 24. The children have resided at the address eontained in paragraph 1 above j the Plaintiff and the Defendant for the last two (2) years, and prior thereto, with the Plaintiff and Defendant at 4027 Cherokee Avenue, Camp Hill, Cumberland County, Pennsylvania. 25. Plaintiff is not aware of any other person making claim to custody or partial custody of the children. 26. Plaintiff believes and therefore avers OW the best interests of the children will be served by granting primary physical custody of the children unto the Plaintiff with periods of partial custody in the Defendant. WHEREFORE, Plaintiff prays this Honorable Court: (a) Enter a Decree in Divorce; (b) Compel the Defendant to pay alimony pendente lite to the Plain 11 ' ff, (c) Compel the Defendant to pay alimony to the Plaintiff; (d) Equitably distribute all property, both real and personal, owned by the parties; (e) Compel the Defendant to pay the Plaintiffs counsel fees, costs and expenses and the costs and expenses of this action; (f) Grant primary physical custody of the two (2) children unto the Plaintiff herein, with periods of partial custody in the Defendant; and (f) Grant such further relief as the Coact may deem equitable and j Respectfully submitted, Mancke, Wagner, Spreha & McQuillan By Ille P. Ri Wagner, Esquire . . #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Bate: 8 ,47 D 7 V VERIFICATION I verify that the statements made in the foregoing document are try and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. 0 8/,? 710 7 ?j 9- 1 d r? ?C7 !`77 ? p G a? t _A OM & Ki uLAKIs Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 BRENDA S. BUCKBEE Plaintiff V. ROBERT B. BUCKBEE Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5280 CIVIL TERM ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Robert B. Buckbee, in the above- captioned matter. Respectfully submitted, Date: 10 O'? D -7 r'? ? 44?11b, Kara W. Haggerty, I 36 South Hanover S Carlisle, PA 17013 (717) 249-0900 Attorney ID #86914 -- . CERTIFICATE OF SERVICE AND NOW, this day of October, 2007, I, Kara W. Haggerty, Esquire of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Entry of Appearance by First Class U.S. Mail addressed to the following: P. Richard Wagner, Esquire 2233 North Front Street Harrisburg, PA 17110-1027 cz? y ..-:D r, ?y , , caa t CSs BRENDA BUCKBEE, V. Plaintiff/Petitioner ROBERT B. BUCKBEE Defendant/Respondent : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 2007-5280 : CIVIL ACTION -LAW IN DIVORCE PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL HOME AND NOW, comes your Petitioner, Brenda Buckbee, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Petition For Exclusive Possession of the Marital Home: 1. Your Petitioner, Brenda Buckbee, is the Plaintiff in the above-captioned divorce action. 2. The Respondent, Robert Buckbee, is the Defendant in the above-captioned divorce action. 3. The parties have a marital home situate at 210 E. Walnut Street, Shiremanstown, Cumberland County, Pennsylvania. 4. The Respondent removed himself from the marital home and moved to 395 N. York Street, Mechanicsburg, Cumberland County, Pennsylvania, together with a female companion. 5. The Petitioner herein resides in the marital home together with the two minor children, Emily, born August 31, 1993, and Garrett, born September 12, 2003. 6. The parties separated on or about August of this year. 7. From time to time since separation, the Respondent has returned to the marital home for no legitimate purpose. 8. The Respondent's return has disrupted the family, has caused the two children to be upset, and has served no legitimate purpose. 9. Recently, Petitioner was away from the home for a short period of time and returned to the home and found the Respondent's girlfriend and her children swimming in the swimming pool at the home where the Petitioner is residing with the parties' two minor children. 10. Petitioner did not grant permission of the Respondent's girlfriend and her children to use the home nor the pool located therein. 11. The girlfriend of the Respondent and her children used the pool without any advance notice or warning or request of the Petitioner. 12. The aforementioned incident, together with his sporadic return to the home for no legitimate purpose has disrupted the home life of the Petitioner and the parties' minor children. 13. Petitioner believes that the sporadic return by the Respondent, and particularly the use of the pool and the house by Respondent's girlfriend has further caused problems for the parties' minor children. 14. Petitioner believes it is in the best interests to grant exclusive possession of the marital home unto the Petitioner together with the two minor children pending the outcome of the divorce proceeding. -2- WHEREFORE, Petitioner requests the Court to grant relief as requested. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan P. Richard er, Esquire I.D. #231 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: Q -3- VERIFICATION I verify that the statements made in the foregoing document 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 unworn falsification to authorities. ,r ,r i Date: ?/ v U ??yhJ Y\ N l . _ . . rlQ } =IZ amr r1a rNo BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner V. ROBERT B. BUCKBEE Defendant/Respondent : NO: 2007-5280 CIVIL ACTION - LAW IN DIVORCE AMENDMENT TO PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL HOME AND NOW, comes your Petitioner, Brenda Buckbee, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Amendment To Petition For Exclusive Possession of the Marital Home by adding the following paragraphs: 15. No Judge has ruled upon any issue in this matter. 16. Opposing counsel was not contacted for concurrence in this matter. WHEREFORE, Petitioner requests the Court to grant relief as requested. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan .11 / / Z-- P. Richard agner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: 30 D ??q M,? tl"?} ?.. ti`°` ?? t'z 1 a 9 *' t ? l,? ? ?? . ?ifi, ;? L._ •-?? r r SEP, BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner V. ROBERT B. BUCKBEE : NO: 2007-5280 CIVIL ACTION -LAW Defendant/Respondent IN DIVORCE ORDER AND NOW, this day of D C, , 2008 upon Petition of the Plaintiff, Brenda Buckbee, a Rule is hereby issued upon the Defendant/Respondent to show cause, if any, the relief requested should not be granted. owq RULE RETURNABLE the A/ day of 2068, at 'D d o'clock _.m. in Courtroom No.__L_of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. RE-b-i-ppiG said hewing, iono mein ?w0 over erem. XP'IR istribution: chard Wagner, Esq., 2233 N. Front St., Harrisburg, PA 17110 W. Haggerty, Esq., 36 S. Hanover St., Carlisle, PA 17013 Court Administrator eo c t?s rr?.cC: BY THE COURT: E??????S??Y?'?" 'V 4 ,i \?? '4 t /?y41 '?k1? 1?j ?! {? ?? ? •?? ! t„.1 , 41 iA J .t ..,? ? j ?j ? ? 44 Y t 6 BRENDA BUCKBEE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT B. BUCKBEE, : Defendant CIVIL ACTION - LAW NO. 07-5280 CIVIL TERM ORDER OF COURT AND NOW, this 14' day of January, 2009, upon consideration of the attached letter from P. Richard Wagner, Esq., attorney for Plaintiff, the hearing previously scheduled for January 14, 2009, is cancelled. BY THE COURT, v P Richard Wagner, Esq. 2233 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff Kara W. Haggerty, Esq. 36 South Hanover Street Carlisle, PA 17013 Attorney for Defendant :rc 'dno C Z :Z Wd S ! NVP 6001 fStiN V'iyi'l.lf lw ?v'.. la ..Ji,id 1 6 r I. LAW OFFICES MANCKE, WAGNER, SPREHA & MCQUILLAN JOHN B. MANCKE 2233 NORTH FRONT STREET P. RICHARD WAGNER HARRISBURG, pq 17110 EDWARD F. SPREHA, JR. BRYAN M. MCQUILLAN January 12, 2009 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Re: Buckbee v. Buckbee No: 2007-5280 Dear Judge Oler: This letter will confirm my telephone call regarding the above. PHONE (717) 234.7051 FAX (717) 234-7080 The parties have reached a stipulation and will avoid the necessity for a hearing on January 14, 2009. Upon signature of the Stipulation between the parties, I will forward the same to your office for signature. Your attention is appreciated. PRW/dks Enclosure agner cc: Kara W. Haggerty, Esq. 111?) ?Q? _. k P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff/Petitioner BRENDA BUCKBEE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner V. : NO: 2007-5280 ROBERT B. BUCKBEE, : CIVIL ACTION -LAW Defendant/Respondent : IN DIVORCE STIPULATION AND NOW, comes the undersigned, P. Richard Wagner, Esquire, counsel for Brenda Buckbee, Plaintiff(Petititoner, and Kara W. Haggerty, Esquire, counsel for Robert B. Buckbee, Defendant/Respondent, and do hereby stipulate and confirm that the marital home situate at 210 E. Walnut Street, Shiremanstown, Cumberland County, Pennsylvania, shall be granted unto the Brenda Buckbee, Plaintiff/Petitioner. Said exclusive possession shall continue until such time that the matter is resolved either through the court or through written agreement by and between the parties. t 01 er, Esq. Kara W. Haggerty, Zi?Respo?nt Counsel for the Plaintiff/Petitioner Counsel for the Def Y_ [r1 IJ N 2 9 209 P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for PlaintiflMetitioner BRENDA BUCKBEE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Petitioner V. ROBERT B. BUCKBEE, NO: 2007-5280 CIVIL ACTION -LAW Defendant/Respondent : IN DIVORCE ORDER AND NOW, this 2, Lday of f e , 2009 upon Stipulation of the parties through counsel, exclusive possession of the marital home situate at 210 E. Walnut Street, Shiremanstown, Cumberland County, Pennsylvania, shall be granted unto the Plaintiff/Petitioner herein, pending outcome of the divorce proceedings. Distribution: VXV 'chard Wagner, Esq., 2233 North Front St., Harrisburg, PA 17110 Kara W. Haggerty, Esq., 36 South Hanover St., Carlisle, PA 17013 Court Administrator 126F66S mat'LCL BY THE COURT: rj L.LA ? Ls., f i:L L C? ?j cv ci .,1 !lC Tt ,r i,;,?J 201011,", ` - h , ` r BRENDA BUCKBEE, IN THE COURT OF COMMON PUAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO: 2007-5280 CIVIL ACTION - LAW ROBERT BUCKBEE, JR., : IN DIVORCE Defendant. PRAECIPE TO THE PROTHONOTARY: Please withdraw Counts I, II, II and IV of Plaintiff's Complaint. Respectfully Submitted, Mancke, W & Spreha P. and Wa, Esquire I. #231 23 North Front Street Harrisburg, PA 17110 Attorneys For Plaintiff Date: P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff 2010 iii=i'i -6 A I1: 40 :. w C11111 BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 2007 - 5280 ROBERT B. BUCKBEE, Defendant. : CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated August 1, 2007, and have continued to live separate and apart for a period of at least two (2) continuous years. 2. The marriage is irretrievably broken. 3. 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. 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 18 Pa.C. . S ction 4904 relating to unworn falsification to authorities. 3 14 / ?) ` Brenda B c ee Date: P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff, NO. 2007 - 5280 : CIVIL ACTION -LAW ROBERT B. BUCKBEE, IN DIVORCE Defendant. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): X(a) I do not oppose the entry of a divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i) or (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. () (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): O (a) I do not wish to make any claims for economic relief. 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. O (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth in the Notice of Intention to Request a Decree in Divorce, a Decree in Divorce may be entered without further notice to me and I should be unable thereafter to file any economic claims. I verify that the statements made in this Counter-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. Robert B. Buckbee DATE: ! z 61/ v ti Y? tr 20 10 f `c - 6 P, I I:; 6 -IN BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO: 2007-5280 - CIVIL TERM ROBERT B. BUCKBEE, Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of Mancke, Wagner & Spreha, do hereby certify that on this date a copy of the Plaintiffs Affidavit with Defendant's Counter-Affidavit was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and also by first class mail, postage prepaid, and addressed as follows: Mr. Robert B. Buckbee 117 E. Maplewood Mechanicsburg, PA 17055 BY ?L ?^ Debra K. Spinn r, Secretary Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff Date: ?/ ?i / ¦ Complate Iterrrs 1, 2, and 3. Also complete Ram 4 N Restricted DelNery is desired. a Print your name and address on the reverse so that we can return the card to you. -Attach this card to the beck of the mailpiece, or on the front if apace permits. 1. Article Addressed lo: 11.7 PA- IV65- A A. 0 Agent elved by/Prbt y Neme)^ - -I C. Date of Delivery D. Is deNvery Oleos different from item 17 0 Yes If YES, enter delivery addrese below: 0 No 3. lyps Ca NOW Mail O EWSM Meal Pagmared 0 Ream Receipt for Mwdww Ye 0 insured Meti 0 C.O.D. 4. Restricted DelMery? (Extra Fee) Yee 2. ArdoleNun,bar 7005 1160 0001 3321 0965 (rianrbr ran service leer) PS Form 3811, Feftery 2004 Domestic Reef urn Receipt 10259!;-o2.Wt540 ?n ur-r% ¦ : - ..a Er if Only; Domestic Ma i No Insurance Coverage Provided) E3 r•- Iv OFFI CIAL USE M Postage $ . ?p O Certified Fee PcBVnerk O D e?i (Endprsernent( Squired) , { Here C3 .a ResMcter+ Delivery Fee (EndorsV Aent Required) ' / • 0 rq Total Postage & Fees C3 C3 t o " ' - ------------------------ -° ° ---°------ - (?, o Box No." ------- 2002 PS Forr, ?800. June C a P. Richard Wagner, Esquire r PA Supreme Court ID# 23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street t : -= r f Harrisburg, PA 17110 r Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 2007 - 5280 CIVIL ACTION -LAW ROBERT B. BUCKBEE, IN DIVORCE Defendant. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Robert B. Buckbee YOU HAVE BEEN SUED IN an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §3301(d)affidavit. Therefore, on or after I a 01V , the Defendant can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. COURT ADMINISTRATOR 4m Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 d 2 fl9 19 121.:;. Mr. Robert B. Buckbee 117 E. Maplewood Mechanicsburg, PA 17055 By ?64t - . , 1,0 (/It?Y? gig Debra K. Spinner, Secretary Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff clua ;- -, " , r " i '•t t 1 BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO: 2007-5280 - CIVIL TERM ROBERT B. BUCKBEE, Defendant. : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of Mancke, Wagner & Spreha, do hereby certify that on this date a copy of the Notice of Intention to Request Entry of Divorce Decree was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and also by first class mail, postage prepaid, and addressed as follows: Date: '7 of y /'0 ¦ I ompl* 16ertp;1. 2, and a. Also complete Item 4 H Restricted DeNvery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. to: X 1L_-; .1k ?r? ? D. Is delvery addreae ditr9r t from item if YEs. enter delivery addrsw Cy bti ?, z a -qvim Type ya c, j o :. XCCsrMW Men 0 Egress ? Repbtared O Return Receipt for Mardtandbs ? Insured Man E3 C.O.D. 4. Restricied DeBwry? Pit Fee) Yes 2. Article Ntxrtber ?005 1160 0001 3321 0941 rliWww from aavice label) A PS Form 3811, February 2004 Domestic Return Receipt - ¦ . - (Domestic Mail Oniy ; No Insurance Coverage Providei M , rq r M M Postage $ F--l Cerdfled Fee M Postmark C3 Receipt Fee Return Here O ntRequ ired (Endorseme) . C3 . led De'-ry Fee -0 = (Endorsement Required) rq A Total Postage & Fees $ . TO O W, ----------------------- - or PO Box No. ?/ ?r?- - - -------------------------------- PS ?,.- PF4 ? /71J?.5 1 FILE C, C, 2C 10 h Ay 15 P?'i 1: u t BRENDA BUCKBEE, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO: 2007-5280 - CIVIL TERM ROBERT B. BUCKBEE, Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of Mancke, Wagner & Spreha, do hereby certify that on this date a copy of the Complaint in Divorce was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and also by first class mail, postage prepaid, and addressed as follows: Mr. Robert B. Buckbee 210 E. Walnut Street Mechanicsburg, PA 17055 BY `7(, j 0 J Debra K. Spinner, %cretary Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff Date: _:?j r a ra Postal o CERTIFIED . REC E IPT (Domestic . C ove rage . . CID C3 ru OFFICIAL U%f--J m r M {? 0 $ tage '- O Certified Fee ;, 6 5, 0 ' Postmark O Return Receipt Fee d Here (Endorsement Required) a o C3 Restricted Delivery Fee LcL! -0 (Endorsement Required) rl $ Total Postage & Fees 7 d t.rl C3 ntTo At. reet Apt ?d i ) ?/? or -!/ (?s or PO Box No. .. . -- clq, sta . 4 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so Inat we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Sig '? Agent X t ` ? Addressee R lv y (Prin ed Name) C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery ? No 3. ice Type ?j l a Certrfied M si ? egistered , pt for Merchandise ? Insured Mail ? ,~"" 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7005 1160 0001 3320 8870 (llansfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 BRENDA BUCKBEE, Plaintiff, V. ROBERT B. BUCKBEE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 2007-5280 - CIVIL TERM CIVIL ACTION - LAW IN DIVORCE n :r PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: N 0 o` --c ko 77 c-_; PQ 5 PI 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), 3301(d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: September 12, 2007, by certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: By Defendant: (b) (1) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divorce Code: March 4, 2010 (2) Date of service of the Plaintiffs Affidavit unto the Defendant: 4/01/10 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1)(i) of the Divorce Code: April 24, 2010 by certified mail, restricted delivery, return receipt requested (b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: 04/06/10 (c) Date Defendant's Waiver of Notice was filed with the Prothonotarv: 04/06/10 BRENDA BUCKBEE V. ROBERT B. BUCKBEE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N O. 2007-5280 DIVORCE DECREE AND NOW, Z y I t~ , it is ordered and decreed that BRENDA BUCKBEE ROBERT B. BUCKBEE bonds of matrimony. plaintiff, and defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court,