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Home My WebLink About07-5623 LAURIE E. BORDLEMAY Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. RANDAL D. BORDLEMAY, Defendant r NO. 0? - &P93 0i a l -rerm 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 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, I COURTHOUSE SQUARE, 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1P .•.. LAURIE E. BORDLEMAY Plaintiff VS. RANDAL D. BORDLEMAY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 Cd ? -. : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT COUNT I - DIVORCE UNDER 93301(c) or 63301(d) OF THE DIVORCE CODE 1. Plaintiff is Laurie E. Bordlemay, who currently resides at 411 Market Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant is Randal D. Bordlemay, who currently resides at 535 7"' Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 8,1989 in Cumberland County, Pennsylvania. 5. The parties are the parents of one (1) minor child: Morgan Elizabeth Bordlemay, born on November 7, 1992. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. Plaintiff has been advised that counseling is available and that she may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued. 9. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are: (a) §3301(c). The marriage of the parties is irretrievably broken; and (b) §3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time, Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. 10. Plaintiff requests This Honorable Court enter a Decree of Divorce. WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the marriage between Plaintiff and Defendant. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.C. Dated: 9/1/0 / Angelic evelant, Esquire 130 West Church Street Dillsburg, PA 17019 (717) 432-9666 I.D. # 202759 09/14/2007 13:00 7174320426 THE WILEY GROUP r. .... a VERIFICATION PAGE 05/05 1, Laurie E. Bordlemay, verify that the statements made in this COmPlaint are true and correct to the best of my know ledge, information, and belief I understand that &Ise statements herein are made subject to the penalties of 18 Pa, CS. §4904, relating to unswom falsification to authorities. Date: 9-116 LAURIE E. BORDLEMAY Plaintiff 't ; .o 00 W g C7 2? i " ?.ra tt-? ! q t r, F a r N tai :7x C7 LAURIE E. BORDLEMAY, IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-5623 CIVIL TERM RANDAL D. BORDLEMAY, Defendant, CIVIL ACTION -DIVORCE AFFIDAVIT OF SERVICE I, Jeanette L. Roberts, being duly sworn, deposes and says that she is an adult and that she served the within Divorce Complaint, on the Defendant, Randal D. Bordlemay, at the Defendant's present address as follows: 535 7th Street, New Cumberland, PA 17070, by certified mail, restricted delivery, return receipt requested on the 29th day of September, 2007. The Certified Mail Receipt and PS Form 3811 is attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. Date: October 1, 2007 COMMONWEALTH OF PENNSYLVANIA WILEY, LENOX, COLGAN & MARZZACCO, P.C. 't A ByAJeLtte L. Roberts SS COUNTY OF YORK On this, the 1St day of October, 2007, before me, a notary public, personally appeared Jeanette L. Roberts known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and acknowledged that she executed the same for the purposes therein contained. WITNESS, my hand and notarial seal the day and year aforesaid. OTARY P LIC My Commission Expires: COIViPv;;ji +?? ?1: .; OF PENNSYLVANIA NoWal Seel LS. Dawns Gl?l?? ?, ptm Dillsburg Boro, Yolk ??Y My Commission ENO" MW 17, MW Member, Pennsylvania Aaeochdj n f Nmilaies .r ¦ 'Complete items 1; 2, and 3. Also complete A item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse x 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. 1. Article Addressed to: ? Agent ? Addressee (Printed Nam C. Date of Delivery Is delivery address different from item 1? ? Ye: If YES, enter delivery address below: ? No Randal D. Qordlemay 3f ref 53571h , ' 't New Cumberland, PA 17070 3. lce Type JA5edmied mail ? Egress Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (rmnsterfromservice iabeq 7007 0222 0003 3289 6276 PS Form 3811, February 2004 Domestic Return Receipt EXHIBIT "A" 102595-02-M-1540 n ? ?j '7"i :? "`i " -?.. ? i fi i ? -. -` . f tnJ !.. .rte . ?'` m Y? ?.... . ' Cara A. Boyanowski, Esquire Pa. Supreme Court ID No. 68736 Serratelli, Schiffman, Brown and Calhoon, P.C. 2080 Linglestown Road Suite 201 Harrisburg, Pennsylvania 17110 Telephone (717) 540-9170 Fax (717) 540-5481 Attorney For Plaintiff LAURIE E. BORDLEMAY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v . NO. 07-5623 CIVIL TERM RANDAL D. BORDLEMAY, : CIVIL ACTION - LAW Defendant : IN DIVORCE DPAPOTDr Please enter the appearance of Cara A. Boyanowksi, Esquire, as attorney for the Defendant in the above-captioned matter. Dated: I()! ama&ymw?. Cara A. Boyan wski, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 E7 ? C) co 3 P ?= tu:_ tea ....? Y Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 171 10 (717) 540-9170 Attorney for Defendant LAURIE E. BORDLEMAY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v NO. 07-5623 CIVIL TERM RANDAL D. BORDLEMAY, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on September '26,2007. 2. The marriage of 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 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.A. §4904 relating to unsworn falsification to authorities. Dater -- By Laurie E. Bordlemay, Plaintiff Social Security No. `Lq'5T_VIS C? ?s ?e ^ r - 70 C 7 Cara A. Boymowski, Esquire Supreme Court I.D. No. 68736 2080 Liuglestown Road Suite 201 1larrisburg, PA 171 10 (717) 540-9170 Attorney for Defendant LAURIE E. BORDLEMAY, Plaintiff V RANDAL D. BORDLEMAY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5623 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301(c) of the Divorce Code was filed on September 26. 2007. 2. The marriage of 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 of divorce after service of notice of intention to request entry of the decree. I verifv 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.A. §4904 relating to unsworn falsification to authorities. Date: _? --,? - By - ---- - t Znhdal aXmay, Defendant D. B Social Secwity No. ?Z -S-w_- `z'-?'t? 7 o ° a ?' ? ?' '? a ? J',^ ? ? ,j'3C_* ?.. "C== : ? -?i E' ,sk ?_ ?' ? i. -; ? ? ?? ,.?° Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 1larrisburg, PA 171 10 (717) 540-9170 Attorney for Defendant LAURIE E. BORDLEMAY, Plaintiff V RANDAL D. BORDLEMAY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5623 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. 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.A. §4904 relating to unsworn falsification to authorities. Date: By' A4!Laurie Frdlemay, Plaintiff .-a fcz]), o P r ° ? ? 1 ; r T r *7 r7l Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 l larrisburg, PA 171 10 (717) 540-9170 Attorney for Defendant LAURIE E. BORDLEMAY, Plaintiff V IZANDAL D. BORDLEMAY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5623 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) 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 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.A. §4904 relating to unsworn falsification to authorities. Date: 2 d---- -- By: CZ) -r r ? ? -q-5- 't Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 Linglestown Road Suite 201 Harrisburg, PA 171 10 Telephone: (717) 540-9170 Facsimile: (717) 540-5481 Attorney for Defendant, Randy D. Bordlemay LAURIE E. BORDLEMAY, Plaintiff V. RANDAL D. BORDLEMAY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 07-5623 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: A copy of the Divorce Complaint was served upon Defendant, Randal D. Bordlemay, by certified mail, restricted delivery on September 29, 2007. A copy of the Affidavit of Service and the Domestic Return Receipt card, signed by Defendant, have been filed of record with this Honorable Court on October 2, 2007. 3. (Complete either paragraph (a) or (b).) (a). Date of execution of the affidavit of consent required by §3301(c) of • Tv $ the Divorce Code: by Plaintiff. February 5, 2008; by Defendant: February 5, 2008. (b) (1). Date of execution of the affidavit required by §3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: N/A. 4. Related claims pending: None. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record; a copy of which is attached: N/A. (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 7, 2008 (anticipated) Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 7, 2008 (anticipated). Respectfully submitted, SERRATELLI SCHIFFMAN BROWN & CALHOON OjLwapy""- Cara A. Boyanowski, Esquire Supreme Court I.D. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Defendant C"7 ? a c;.. ITT, { {7R Ul IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LAURIE E. BORDLEMAY, PLAINTIFF N O. 07-5623 CIVIL TERM VERSUS RANDAL D. BORDLEMAY, DEFENDANT DECREE IN DIVORCE AND NOW, IT IS ORDERED AND LAURIE E. BORDLEMAY DECREED THAT RANDAL D. BORDLEMAY 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. PROTHONOTARY /lop