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Home My WebLink About08-0571ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA og-?7r CIV;I I-arm : CIVIL ACTION - 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 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, Cumberland County Courthouse, One Courthouse Square, 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 32 South Bedford Street Carlisle PA 17013 1-800-990-9108 717-249-3166 JONES & HENNINGER, P.C. BY: PETER R. HENNINGER, JR., ESQUIRE I. D. # 44873 339 West Governor Road Suite 201 Hershey, Pa 17033 (717) 533-7113 ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant ATTORNEY FOR PLAINTIFF, ROBERT P. BRADSHAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA yLc?. ? P - S7 / ? CIVIL ACTION - IN DIVORCE AND NOW, comes the Plaintiff, Robert P. Bradshaw, by and through his attorneys, Jones & Henninger, P.C. and avers as follows: COUNT NO. 1 23 Pa. C.S.A. §3301 (d) 1. The Plaintiff is Robert P. Bradshaw, an adult individual who currently resides at 6104 Charing Cross, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Victoria L. Bradshaw, an adult individual who currently resides at 28 Spruce Street, Lititz, Lancaster County, Pennsylvania, 17543. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant are both citizens of the United States of America. 1 r 5. The Defendant is not a member of the Armed Services of the United States or any of its allies. 6. The Plaintiff and Defendant were married on September 20, 2001, in Mechanicsburg, Cumberland County, Pennsylvania. 7. There have been no prior actions of divorce or annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests the Court to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; Respectfully submitted, Dated: a?6j' JONES & HENNINGER, P.C. Attorney for Plaintiff By: Peter R. Henninger, Jr., Esq ire I.D. No. 44873 339 West Governor Road Suite 201 Hershey, PA 17033-2086 (717) 533-7113 2 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalty o Pa. ,X-44904, relating to unsworn falsification to authorities. Robert 15'. Bradshaw, Plaintiff fty O ewP T M w ( Uj D 04 Wryry .r V v r r'! f JONES & HENNINGER, P.C. ATTORNEY FOR PLAINTIFF, BY: PETER R. HENNINGER, JR., ESQUIRE ROBERT P. BRADSHAW I. D. # 44873 339 West Governor Road Suite 201 Hershey, Pa 17033 (717) 533-7113 ROBERT P. BRADSHAW, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. VICTORIA L. BRADSHAW CIVIL ACTION - IN DIVORCE Defendant NOTICE 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. 1. A Complaint in Divorce under §3301 (d) of the Divorce Code was filed on 2. The parties to this marriage separated on or about September 1, 2004 and have continued to live separate and apart for a period of at least two (2) years. 3. The marriage is irretrievably broken. 4. I understand that I may lose rights concerning alimony, division of property, lawyers' fees and expenses if I do not claim them before a divorce is granted. I verify that the statements made in the 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:--. Z ? --. ? , ?,, _ . ; _. ?.? _ ,-{ ' - , r ?--? _. i .. _.. - ? E j a ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 08-571 : CIVIL ACTION - IN DIVORCE PROOF OF SERVICE BY CERTIFIED MAIL Peter R. Henninger, Jr., Esquire, of the law firm of Jones & Henninger, P.C., being duly sworn according to law, deposes and says that he did serve a copy of the Divorce Complaint in the above-captioned matter, filed on behalf of Robert P. Bradshaw, to the above term and number on Victoria L. Bradshaw by mailing a copy of same to Victoria L. Bradshaw by Certified Mail, Return Receipt Requested, to Defendants' last known address, that being: 28 South Spruce Street, Lititz, Pennsylvania 17543. The original Return Receipt, as well as the receipt for Certified Mail No. 7004 2890 0001 4068 3785 are attached evidencing the delivery of the above referred Petition for Divorce and Order. JONES & HENNINGER, P. C. Attorney for Robert P. Bradshaw Date: February 2, 2008 By: Peter R Henninger, Jr., Esquire I.D. No. 44873 339 West Governor Road Suite 201 Hershey, PA 17033-2086 (717) 533-7113 SWORN and subscribed to before me this 2nd day of , 2008. Q +v-n r j-,jot Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Rhonda Carlton-Shaffner, Notary Public Township of Derry, Dauphin County ley Commission Expires May 5, 2011 ,n CERTIFIED ?AAIL RE? ' t? M CO Mitu 1 L L. C USE .o ,,,r-U 0 > $ --`-?. ?, `?? ~• ri certified Fee O n Retum Receipt Fee d) i Q re (EndoraemeM Requ ` r3 r Restricted Delivery Fee (Endomement Re44lred) (r J a?* i C CO ru Total Postage & Fees r 1 4"7 $ 00 326 A2/ C3 --- f? or - O r -. ------ - 11pi- ; e7in c_..4, CVv i ,. o -Si' ¦ Complete items 1, 2, and 3. Also complete A. item 4 If Restricted Delivery is desired. x ¦ Print your name and address on the reverse so that we can return the card to you. B ¦ Attach this card to the back of the mailpi or on the front if space permits. '?. Article Addressed to: D' V iJoro- L. 3ro.8shau ". zS Sikh r*Uce. sfiree-? Li'Jz Ph 1-75'4-3 3. 2. Article Number (Transfer from seMn he" I RecetvW by (Pdnted Name) C. D to of Deli' / Is delivery address different from item 17 If YES, enter delivery address below: O'No 13 E3 R / ?pt for Merchandise 4. Restricted Delivery? (Extra Fee) hetes 7004 2890 0001 4068 3785 PS Form 3811, February 2o04 Dorrvinbc Return, Rees" 102595-02-M-1540 Q Q jr??T d 1 Co ? r J?lV +C 7 ? 4 ROBERT P. BRADSHAW, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-571 VICTORIA L. BRADSHAW CIVIL ACTION - IN DIVORCE - n Defendant PROOF OF SERVICE' Peter R. Henninger, Jr., Esquire, of the law firm of Jones & Henninger, P`-?berg duly sworn according to law, deposes and says that he did serve a copy of the Notice of Intention to Request Entry of Section 3301(d) Divorce Decree with attached Defendant's Counter-Affidavit under 23 Pa. C.S.A. Section 3301(d) in the above-captioned matter, filed on behalf of the Plaintiff, Robert P. Bradshaw, to the above term and number on April 2, 2008, by mailing a copy of same to the Defendant, Victoria L. Bradshaw, by Regular Mail, to her last known address, that being: 28 South Spruce Street, Lititz, Pennsylvania 17543. A copy of the letter with attached Notice of Intention to Request Entry of Section 3301(d) Divorce Decree with attached Defendant's Counter-Affidavit under 23 Pa. C.S.A. Section 3301(d) are attached, evidencing service of the above-referred Notice and Affidavit. JONES & HENNINGER, P.C. Attorney for Robert P. Bradshaw Date: By: Pete R. He anger, Jr., Esquire I.D. No. 44873 339 West Governor Road Suite 201 Hershey, PA 17033-2086 SWORN and subscribed to (717) 533-7113 before me this "A day of G?L? , 2008. CCa??I?Ob`1iAfEALTi"I q PENNSYLVANIA C?z 040n _ V i? NOTARIAL SEAL Notary Public RhLmoy nda Cariton-Shaffner, Notary Public nship of Derry, Dauphin County Comm ission Expires May 5, 2011 ,111 <t Y it :'`? .c c A )1 ]v :IN IN it I'S'Ut 11-1 1, It. 201 II';\ 1 Y01 3-2080 71 7-I, i i /I I i ill]" (n)jnucs-11'.11Ili 11,?cr.i Ml FILE Copy I??s 71?-X33-7'ii I'i:ri:R I:. I11.NNIN61I V, Ir.. April 2, 2008 Victoria L. Bradshaw 28 South Spruce Street Lititz, PA 17543 Re: Bradshaw v. Bradshaw No. 08-571 CCP Cumberland County Dear Ms. Bradshaw: Enclosed please find a Notice of Intention to Request Entry of Section 3301(d) of the Divorce Code and also Defendant's Counter-Affidavit. If you have any questions, please contact an attorney of your choosing. Sincerely, Peter R. Henninger, Jr. PRH/res Enclosure cc: Robert P. Bradshaw (w/enclosure) I tr. BRADS HAW. v ictoria. bradshaw.00326.04.02.08 a JONES & HENNINGER, P.C. BY: PETER R. HENNINGER, JR., ESQUIRE I.D. # 44873 339 West Governor Road Suite 201 Hershey, Pa 17033 (717) 533.7113 ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant ATTORNEY FOR PLAINTIFF, ROBERT P. BRADSHAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PC" 0?_V'71 : CIVIL ACTION - IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF -43301 (d) DIVORCE CODE TO: Victoria L. Bradshaw, Defendant 28 South Spruce Street Lititz, PA 17543 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 April 23, 2008, the other party 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. A counter-affidavit which you may file with the Prothonotary of the Court is attached to this notice. F% 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. The filing of the form counter-affidavit alone does not protect your economic claims. 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 32 South Bedford Street Carlisle PA 17013 1-800-990-9108 / 717-249-3166 ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA All CIVIL ACTION - IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER §23 Pa. C.S.A. §3301(d) I . Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two (2) years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (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. (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 on the Notice of Intention to Request Divorce Decree, the Divorce Decree may be entered without further delay. 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.A. §4904 relating to unsworn falsification to authorities. Date: Victoria L. Bradshaw, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. CERTIFICATE OF SERVICE A copy of the foregoing Notice of Intention to Request Entry of Section 3301(d) of the Divorce Code has been served by sending a copy of record to the Defendant: Victoria L. Bradshaw, Defendant 28 South Spruce Street Lititz, PA 17543 By depositing same in the United States mail, postage prepaid, in Hershey, Pennsylvania, this ^j day of/. 2008. Jones & Henninger, P.C. Attorneys for Plaintiff By: Peter R. Henninger, Jr., V quire I. D.# 44873 339 West Governor Road Suite 201 Hershey, PA 17033-2086 (717) 533-7113 QJJ (l) N. 1-1-1. Q& ll ?l- Jl".111'?T r IT IN ((77 T--" jFZ 339 WI:S Si rn; 201 11 PA 17033-20136 T1:1-IT ONI: 1'NNlmi. 71 7-6 3 1-711 j6i)c (a)j„nes-lirnnin&r.wnn FILE COPY I;,\ 717-633-%233 DONALD L. JON1:1 12. I11?NNING1:1,, 1R. April 2, 2008 Victoria L. Bradshaw 28 South Spruce Street Lititz, PA 17543 Re: Bradshaw v. Bradshaw No. 08-571 CCP Cumberland County Dear Ms. Bradshaw: Enclosed please find a Notice of Intention to Request Entry of Section 3301(d) of the Divorce Code and also Defendant's Counter-Affidavit. If you have any questions, please contact an attorney of your choosing. Sincerely, Peter R. Henninger, Jr. PRH/res Enclosure cc: Robert P. Bradshaw (w/enclosure) Itr.BRADSHAW . victoria. bradshaw.00326.04.02.08 ???? .? n JONES & HENNINGER, P.C. BY: PETER R. HENNINGER, JR., ESQUIRE I.D. # 44873 339 West Governor Road Suite 201 Hershey, Pa 17033 (717) 533.7113 ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant • ATTORNEY FOR PLAINTIFF, ROBERT P. BRADSHAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0?1_5cil CIVIL ACTION - IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 3301 d DIVORCE CODE TO: Victoria L. Bradshaw, Defendant 28 South Spruce Street Lititz, PA 17543 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 April 23, 2008, the other party 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. A counter-affidavit which you may file with the Prothonotary of the Court is attached to this notice. • 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. The filing of the form counter-affidavit alone does not protect your economic claims. 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 32 South Bedford Street Carlisle PA 17013 1-800-990-9108 / 717-249-3166 C] ROBERT P. BRADSHAW, Plaintiff V. VICTORIA L. BRADSHAW Defendant • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA a CIVIL ACTION - IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER §23 Pa. C.S.A. §3301(d) 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two (2) years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (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. (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 on the Notice of Intention to Request Divorce Decree, the Divorce Decree may be entered without further delay. 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.A. §4904 relating to unworn falsification to authorities. Date: Victoria L. Bradshaw, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. CERTIFICATE OF SERVICE A copy of the foregoing Notice of Intention to Request Entry of Section 3301(d) of the Divorce Code has been served by sending a copy of record to the Defendant: Victoria L. Bradshaw, Defendant 28 South Spruce Street Lititz, PA 17543 By depositing same in the United States mail, postage prepaid, in Hershey, Pennsylvania, this day of A, 2008. Jones & Henninger, P.C. Attorneys for Plaintiff / A By: 1 J1 z6tzl-z? Peter R. Henninger, Jr., quire I.D.# 44873 339 West Governor Road Suite 201 Hershey, PA 17033-2086 (717) 533-7113 ort o? ? t D v ROBERT P. BRADSHAW IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-571 VICTORIA L. BRADSHAW CIVIL ACTION- IN DIVORCE Defendant 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 f)Q=X9() 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: February 2, 2008 certified mail 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 53301 (c) of the Divorce Code: by Plaintiff N/A ; by Defendant N/A (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: 1/24/08 ; (2) date of filing and service of the Plaintiff's affidavit upon the Respondent: 1/25/08 . 2/ 1 1 /08 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: (b) Date of Plaintiff's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary: N/A Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: N A orne or (PLAINTIFF) (UNIMMI ) "•..7 4"-- . .v ? Y.y C'\'" F.. ?? d ...p,., i»...1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROBERT P. BRADSHAW VERSUS VICTORIA L. BRADSHAW No. 08 - 571 DECREE IN DIVORCE AND NOW, 2008 IT IS ORDERED AND DECREED THAT ROBERT P. BRADSHAW AND VICTORIA L. BRADSHAW 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; N/A PROTHONOTARY V, -. ?? „.. v