HomeMy WebLinkAbout81-1458
JEAN C. BOWERS,
Plaintiff
v.
GARY C. BOWERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
. No. 1458 Civil 1981
IN DIVORCE
D E C R E E I N D I V O R C E
AND NOW, to wit: ~~~ ~'~~~~~ ~`~~ ~ ~ ~ ~~ ~' ~ the Court, having
received the Complaint in Divorce under the Act of 1980, No. 26,
Section 20I(c} and the Affidavit of Consent by both parties,
upon due consideration thereof, hereby grants the prayer of the
Plaintiff for dissolution and hereby adjudges and decrees that
Jean C. Bowers is hereby divorced and completely separated from
the bonds of matrimony with Gary C. Bowers, as fully as if the
said Defendant were naturally dead or as if the Plaintiff had
never been married; that every duty, right and claim heretofore
accruing to either of the said parties by reason of said marriage
does now cease and come to an end; and that each of the said parties
is at liberty to marry again as freely as if the marriage had
never taken place.
BY THE COURT:
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Certified:
Prothonot ry -''-~
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JEAN C. BO~~~ERS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
v. -
: No. 1458 Civil 1981
GARY C. BOWERS, -
Defendant IN DIVORCE
MOTION FOR THE ENTRY OF A
FINAL DECREE IN DIVORCE
AND NOW, comes the Plaintiff, by her attorneys, Mancke &
Lightman, and respectively represent as follows:
1. A Complaint in Divorce pursuant to Section 201(c) and
201(d) of the Divorce Code was filed on April 8, 1981.
2. Service of said Complaint in Divorce was made upon
the Defendant, Gary C. Bowers, via United States Certified
r![ail on or about April 14, 1981.
3. No responsive pleading was filed to the Complaint.
4. The Plaintiff signed an Affidavit of Consent to the
entry of the Divorce Decree on November 3, 1981 and an Affidavit
of Notice of Marriage Counseling on April 3, 1981.
5. The Defendant signed an Affidavit of Consent and
Affidavit as to the availability of marriage counseling on
October 8, 1981.
6. The parties have met the requirements of Section 201(c)
of the Divorce Code.
WHEREFORE, the Plaintiff, Jean C. Bowers, pursuant to
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M ANCKE 8c LIG HTMAN
HARRIS BURG, RA. 17108
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PA RCP 1920.4281 request that the Court enter a Final Decree
in Divorce.
Respectfully submitted,
MANCKE & LIGHTNIAN
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BY : '(, t" ~(.~t.''~~~c%~--~%~ % ;',~( is ~sr__.~'l'
Law ence J. Ne~ry, Esqu re
At orney for P]aintiff
P. O. Box 1082._'
Harrisburg, PA 17108
LAW OFFICES
MANCKE & LIGHTMAN
HARRISBURG, PA. 17108
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JEAI~T C . BOYJERS , T_N THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
v.
GARY C. BOWERS, No. ~~LS'~ ~~4~,_ /9~~
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.
IN YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAID4 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 OR TELEPHOP3E
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Court Administrator
Cumberland County Courthouse
N. Hanover Street
Carlisle, PA 17013
(717) 249-1133
t~'IANCKE & LIGHTMAN
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Law ence J. Nea y, Esqui e
Att rney for P aintiff
P.;O. Box 1082
Harrisburg, Pe nsylvania 17108
(717) 234-7051
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JEAN C . BOU7ERS , IN THE COURT OF COPM~ION PLEAS OF
Plaintiff CUr~BERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
v. .
No.
GARY C. BOWERS, .
Defendant IN DIVORCE
r1OTICE OF AVAILABILITY OF COUNSELING
To the Within Named Defendant:
You have been named as the Defendant 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 202(d) of the Divorce Code, you may request that the
Court require you and your spouse to attend marriage counseling
prior to a divorce decree being handed down by the Court. A
list of professional marriage counselors is available in the
Domestic Relations Office, 13 N. Hanover Street, Carlisle.
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 of
which you receive this notice. Failure to do so will consti-
tute a waiver of your right to counseling.
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onotary ~''~
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AFFIDAVIT
JEAN C. BOWERS,
Plaintiff
v.
GARY C. BOWERS,
Defendant
IN THE COURT OF COP'ID4ON PLEAS OF
CUMBERLAND COUPJTY, PENNSYLVANIA
Civil Action - Law
Civil
IN DIVORCE
JEAN C. BOWERS 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 re-
quire that my spouse and I participate in counseling.
2. I understand that the court maintains a list of
marriage counselors in the Domestic Relations 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 panic..ipate 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. X4904 relating to unsworn falsifi-
cation to authorities.
Sworn and subscribed to
before me this •~ `~ ~
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dal of '~~~`'~'~`~~ 19 ~ -
j;~aTean C. Bowers Plaintiff
4
JEAN C. BOWERS,
Plaintiff
v.
GARY C. BOWERS,
Defendant
IN THE COURT OF COMP~ON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
No.
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION
201(c) APdD 201(d) OF THE DIVORCE CODE
1. Plaintiff is Jean C. Bowers, who currently resides
at R. D. #4, Box 116, Carlisle, Cumberland County, Pennsyl-
vania, 17013, since February, 1963.
2. Defendant is Gary C. Bowers, who currently resides
at 1408 Holley Avenue, Imperial Beach, California 93032, since
May, 1978.
3. The Plaintiff has been a bona fide resident in the
Commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on April 17,
1955, at Big Springs, Pennsylvania.
5. There have been no prior actions for divorce or for
annulment between the parties.
6. The Plaintiff is a citizen of the United States of
America.
7. The Defendant is not a member of the Armed Services
of the United States of America or any of its Allies.
8. The marriage is irretrievably broken.
9. The Plaintiff requests the Court to enter a decree of
divorce.
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I verify that the statements made in this Complaint 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 : ~~ ~3 ~~~ ~
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P ainti
torney fob Plaint
COD'IP-SONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF DAUPHIN
Before me, a Notary Public in and for the Commonwealth and
County aforesaid, personally appeared the above-named Jean C. Bowers,
known to me to be the person whose name is subscribed to the fore-
going Complaint and Affidavit, and ackowledged that she executed
the same for the purposes contained therein.
In witness whereof, I have herunto set my hand and official
seal this 3rd day of April, 1981.
J,a ith A. Drum, Notary u lic
Il DR!!M, NOTARY eL"9~fC
M1t CoaRiuion Expires Nor I? k984
/9e PA Dbup~,n Cwnty
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JEAN C. BOWERS, IPd THE COURT OF COh'1MON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. Civil Action - Law
No. 1458 Civil 1981
GARY C . BOG•dERS ,
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 17th day of April, 1981, I hereby
certify that I have served a true and correct copy of the
Complaint in Divorce captioned to the above term and number
upon the Defendant, by mailing the same to him via United
States Certified Mail, return receipt requested, a cony of
which is attached hereto,
~1ANCKE & LIGHT^~IAN
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u ith A. Drum, Secretary to
~ rence J. Neary, Esquire
Attorney for Plaintiff
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M ANCKE & LIG HTMAN
HARRISBURG, PA. 17108
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JEAN C. BOWERS,
Plaintiff
~Aw oFF~~Es
M ANCKE u~ LoG HTMAN
HARRISBURG, PA. 17108
v.
GARY C. BOWERS,
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
No. 1458 Civil 1981
IN DIVORCE
PLAINTIFF'S AFFIDAUIT OF CONSENT
PURSUANT TO SECTION 201fc)
1. A Complaint in Divorce under Section 201(c) of the
Divorce Code was filed on April 8, 1981.
2. The marriage of Plaintiff and Defendant is irre-
trievably broken and ninety days have elapsed from the date
of filing of the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that if a claim for alimony, alimony
pendente lite, marital property or counsel fees or expenses
has not been filed with the Court before the entry of a final
decree in divorce, the right to claim any of them will be lost.
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. X4904
relating to unsworn falsification to authorities.
Date : %-,°~Y /'` ;~
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Jed C. Bowers, Plaintiff
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COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
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Personally appeared before me, a Notary Public in
and for the Commonwealth and County aforesaid, the under-
signed, being duly sworn according to la~N, deposes and says
that the facts set forth in the foregoing Affidavit of
Consent are true and correct.
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Sworn and subscribed to
before me this -,'-" day
of ,`' ,-,~`_~ ~~ 1981.
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;Notary Publ c
My Commission Expires:
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. Bowers
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MANCKE ~ LIGHTMAN
HARRISBURG, PA. 1108
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JEAN C. BOWERS,
Plaintiff
v.
GARY C. BOWERS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Civil Action - Law
No. 1458 Civil 1981
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
DIII~C!111R1 T cr M1I nn ~
,,.~,,,,I,T .O ~~CTIOIti ~_~l c,
~Aw oFF~~Es
M ANCKE @ LIG HTMAN
HARRISBURG, PA. 17108
1. A Complaint in Divorce under Section 201(c) of the
Divorce Code was filed on April 8, 1981, receipt of which is
hereby acknowledged.
2. The marriage of Plaintiff and Defendant is irre-
trievably broken and ninety days have elapsed from the date
of filing of the Complaint.
3. I consent to the entry of the final decree in divorce.
4. I understand that if a claim for alimony, alimony
pendente lite, marital property or counsel fees or expenses
has not been filed with the Court before the entry of a final
decree in divorce, the right to claim any of them will be lost.
5. I have been advised of the availability of marriage
counseling and understand that I may request that the Court re-
quire that my spouse and I participate in counseling.
6. I understand that the Court maintains a list of
marriage counselors in the Domestic Relations Office, which list
is available to me upon request.
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7. 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. X4904 relating to unsworn falsifi-
cation to authorities.
Date
Gary C. Bowers, Defendant
STATE OF CALIFORNIA:
SS
COUNTY OF .
Before me, the undersigned officer, a Notary Public
~nw or roc es
M ANCKE & LIG HTMAN
HARRIS BURG. PA. 17106
in and for the State and County aforesaid, being duly sworn
according to law, deposes and says that the facts set forth
in the foregoing Affidavit of Consent are true and correct.
Sworn and subscribed to
before me this :~ day
of ~_ ,_;.~-,, ~ s 1981 .
Notary Public
My Commission Expires:
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Gary ". Bowe `--
OFFICIAL SEAL
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