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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: ,~ L / `~ ,- 'r Certified: Prothonot ry -''-~ ~. w. 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 ~Aw oFF~~Es M ANCKE 8c LIG HTMAN HARRIS BURG, RA. 17108 ~ .s _, , PA RCP 1920.4281 request that the Court enter a Final Decree in Divorce. Respectfully submitted, MANCKE & LIGHTNIAN ~, r ~ / 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 ~ % l._~ /J is , ``~ : I ~1 `~l ~~ . `~~~; 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 ;, Law ence J. Nea y, Esqui e Att rney for P aintiff P.;O. Box 1082 Harrisburg, Pe nsylvania 17108 (717) 234-7051 ~. .,. 1 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. 1 onotary ~''~ s ~ 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 •~ `~ ~ ~.. 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. w 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 ~~~ ~ ;;~ ,~' 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 r ;; ;-~;- ~C~. ~~ ~ ~ P~ ~~~ ~ ~~ ~ ' ~ 1 ~~~-~7 s =' P ^w'~ ~ ~ ~ I • • ~ • • , • i • 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 ~f `~ 1 u ith A. Drum, Secretary to ~ rence J. Neary, Esquire Attorney for Plaintiff ~Aw oFF~~Es M ANCKE & LIG HTMAN HARRISBURG, PA. 17108 ~~ ~~ ~~~~ ' ,-~~ r r JEAN C. BOWERS, Plaintiff ~Aw oFF~~Es M ANCKE u~ LoG HTMAN HARRISBURG, PA. 17108 v. GARY C. BOWERS, Defendant .~ r 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 /'` ;~ ! ' Jed C. Bowers, Plaintiff r' ~~ w . . COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF w 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. ~' ' , ]ea? Sworn and subscribed to before me this -,'-" day of ,`' ,-,~`_~ ~~ 1981. /~ ;' r <~ ;Notary Publ c My Commission Expires: ~ n - - - ~ , J `~ ., -. - ) ~,,. . Bowers f~-.e~-=GEC ~~ MANCKE ~ LIGHTMAN HARRISBURG, PA. 1108 l I ~, E 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. ~ 1 r 1 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: ~ ~ . ! ~~C~ J ~ ~.. Gary ". Bowe `-- OFFICIAL SEAL • t , ~,, Q'RM~ ~®Y9L ' h~rARr w~~! f - rxu~o~3r,~~ ~~ ° PRlNCIi•dL LEFT":=Cc' !~E ~P . SAM C1lFGO C?~SM'C "'°""~ My Cammissiaa Fxp. Sect. 1', 185 ~ . ice. ~,