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Home My WebLink About07-7257 LORA BIERCE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 - '7.Z 57 ARTHUR BIERCE, CIVIL ACTION -LAW Defendant 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 divorce is indignities, mutual consent 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: Office of the Prothonotary Cumberland County Court House One Courthouse Square 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 TWO LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LORA BIERCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ARTHUR BIERCE, CIVIL ACTION- LAW Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO ARTHUR BIERCE, DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. LORA BIERCE, V. ARTHUR BIERCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- 7a?.i ? Cu?v! 7?c• CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT COUNT 1- DIVORCE AND NOW comes Plaintiff, Lora Bierce, by her attorney, Diane S. Baker, Esquire, and files this Complaint, based upon the following: 1. Plaintiff, Lora Bierce, is an adult individual who currently resides at 1703 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, Arthur Bierce, is an adult individual who currently resides at 1703 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant were married on December 7, 1996, in Cumberland County, Pennsylvania. 4. Plaintiff and Defendant separated on or about November 26, 2007. 5. Plaintiff has been a bona fide resident of this Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 6. Defendant is not presently a member of the Armed Forces on active duty. Plaintiff is not presently a member of the Armed Forces on active duty. 7. There are no pending actions in divorce or annulment in this jurisdiction or in any other jurisdiction brought by either Plaintiff or Defendant above-named. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken. COUNT 2 - CLAIM FOR EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 above are herein incorporated by reference. 11. The Plaintiff and Defendant are owners of various items of personal property, furniture and household furnishings acquired during the marriage which are subject to equitable distribution by the Court. 12. The Plaintiff and Defendant are owners of various motor vehicles acquired during the marriage which are subject to equitable distribution by the Court. 13. The Plaintiff and Defendant singly or jointly have interests in various bank accounts acquired during the marriage which are subject to equitable distribution by the Court. 14. Plaintiff and Defendant own or have an interest in real estate which is subject to equitable distribution by the Court. 15. The Plaintiff and the Defendant have acquired during the marriage other marital property which is subject to equitable distribution by the Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; (b) Equitably distributing all marital property owned by the parties hereto; (c) Such further relief as the Court may determine equitable and just. Respectfully submitted, DATE: 4arre,' Baker, Esquire I Zq /v ?1 Supreme Court ID #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 VERIFICATION I, LORA BIERCE, verify that the statements made in this Complaint in Divorce 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. LORA BIERCE W a ? e o d c ?I C? i N c:.a V 0 ..n T" !7 ? ?T f f ^?e f _I y r ? f D"1 :7:;7 OZ3 LORA BIERCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. O7 - 7AS7 v C -Y''L ARTHUR BIERCE, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Lora Bierce, in the above- referenced matter. DATE: \I,?G101 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 BakerLawOffice@aol.com C) _ rl,i= 7'?J CD LORA BIERCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-7257 ARTHUR BIERCE, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE 1, Diane S. Baker, Esquire, hereby certify that a true and correct copy of the Divorce Complaint was served on the Defendant by certified mail, restricted delivery, return receipt requested, on December 4, 2007, at last known address of: Arthur Bierce 1703 Douglas Drive Carlisle, PA 17013 The return receipt card is attached hers Attorney for Plaintiff I.D. No. 53200 27 S. Arlene Street P.O. Box 6443 Harrisburg, PA 17112-0443 717-671-9600 it t EXHIBIT "A" • Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery 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. 1. Article Addressed to: C i A. Signature X ? Agent ? Aft. B. Received by (Printed Name) C. Date of DWKwy D. Is delivery address different from item 17 ? Yes If YES, enter delivery address below: ? No 3. ice Type Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Edra Fee) 2. Article Number 7007 0220 0003 1662 1542 (Transfer from service label) PS For, 3811, August 2001 Domestic Return Receipt 102595-01-M•0,381 -_, =?;? ? -' ` ' .<? ?./ .. ,... _„ ??? .., ?? -?"'' .- i -Lr ?.? „2 ? ? V 5..