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HomeMy WebLinkAbout08-1525• F:\FILFS\Clients\7122 Hyatt\333 Bible\7122.331divcom Created: 6/1/06 8:50AM Revised: 3/6/08 10:04AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08- S CIVIL ACTION- LAW TODD BIBLE, Defendant : IN DIVORCE/CUSTODY 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08- CIVIL, ACTION - LAW TODD BIBLE, Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND CUSTODY 1. Plaintiff is Jennifer Bible, who currently resides at 201 High Street, Summerdale, Cumberland County, Pennsylvania. 2. Defendant is Todd Bible, who is currently residing with his mother, whose address is P.O. Box 158, Franklintown, PA 17323. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on August 11, 1998, in Wichita Falls, Texas. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Member's Civil Relief Act. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNTI REQUEST FOR A DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. When at the appropriate time, Plaintiffwill file an affidavit stating that two years have expired from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301 of the Divorce Code. COUNT II REQUEST FOR CONFIRMATION OF CUSTODY UNDER 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. The parties are the parents of the following unemancipated children, Christopher Bible, born September 15, 1996, and Ian Bible, born January 22, 2000. 13. During the past five years, the children have resided with the parties and at the addresses herein indicated: FROM TO August 2006 Present January 2006 August 2006 January 2002 December 2005 WITH WHOM ADDRESSES Mother and maternal 201 High Street, Summerdale, PA grandparents Mother and Father Fairchild Air Force Base Mother and Father Ramstein Air Base, Germany 14. Plaintiff has not participated in any other litigation concerning the children in this or any other state. 15. There are no other proceedings pending involving custody of the children in this or any other state. 16. Plaintiff knows of no person not a party to these proceedings who has physical custody of the children or who claims to have custody, partial custody or visitation rights with respect to the children. 17. The best interests of the children will be served if sole legal and primary physical custody of them are confirmed in Plaintiff: Defendant last contacted his children via telephone in August or September 2007, and his contact with the children prior to that was sporadic since separating with Plaintiff on December 15, 2006. He contacted Plaintiff on March 5, 2008, to say he is now in Pennsylvania. WHEREFORE, Plaintiff respectfully requests that the Court enter an Order confirming sole legal and primary physical custody of the children in Plaintiff. MARTSON LAW OFFICES By Jennifer I ears, Esquire 10 East i Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: March , 2008 VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Divorce Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. 0- -, -?T F:\FrLES\CUmts\7122 Hyatt\333 BiW7122.331divcom n r`' C - ( A TT -t 1 M:a r C N 00 CIO ,-)n 1 F:\FILES\Clients\7122 Hyatt\333 Bible\7122.333.a0s Created: 6/1/06 8:50AM Revised: 3/11/08 10:OOAM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1525 CIVIL ACTION - LAW TODD BIBLE, Defendant : IN DIVORCE/CUSTODY AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) . SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce and Custody was mailed to Defendant Todd Bible at P.O. Box 158, Franklintown, PA 17323 on March 7, 2008, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Todd Bible" and dated March 8, 2008. 1 Jenni L. Spears, Esquire Sworn to and subscribed before me this I lth day of March, 2008. /'7 Notary Public ',)MMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Victoria L. Otto, Notary Public Carlisle Borough, Cumberland Cowry My commission expires December 20, 2010 ¦ 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. Anti Is Addressed to: '6U4 Po ? O-z' A Slgn ? X ent Addressee B. Received by (Printed Name) C. Date of Delive &'•'/2 J GO D. Is delivery address different from Rem 1? ? Yes If YES, enter delivery address below: !_ No 3. Ice Type ' / 3? Certified Mail 13 Express Wail 4XI)&I ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? pft Fee) Yes 2. Article Number 7003 3110 0004 5772 5566 (Transfer from service labeq Ps Form 3811, February 2004 Domestic Retum Receipt 102595-02-M-1540 Postal TIFIED MAIL!, RECEIPT CER only; (Domestic I!1 ? a U S ...,. rl l ., C?- Ln Postage 3-0,o,ti Certified Fee O Return Redept Fee ired) R -' • ' f f ems`` O equ (endorsement O Restricted Delivery Fee (Endorsement Required) k, r-l r=1 A. p. fC; t? i M Total Postage a revs L 'y m nt 70 0 -- - ----------------------------- S`treat Apr: No.: ?X ---------------------- Z co _C1 ' Ali U JENNIFER BIBLE IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. TODD BIBLE DEFENDANT 2008-1525 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, March 13, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at_ 4th Floor, Cumberland County Courthouse, Carlisle on Monday, April 07, 2008 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ohn . Mangan, r. Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 r?v P? 14 220084xy? ?- JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-1525 CIVIL ACTION LAW TODD BIBLE, IN CUSTODY Defendant ORDER OF COURT AND NOW this VA%ay of April 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: Legal Custody: The Father, Todd Bible, and the Mother, Jennifer Bible, shall have shared legal custody of Christopher Bible, born 9/15/1996 and Ian Bible, born 1/22/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children. and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 2. Physical Custody: The Mother shall have primary physical custody of the Children subject to Father's partial physical custody as follows: a. Father shall have physical custody/visitation of the Children every Wednesday from 4:00 pm until 8:00 pm. Absent mutual agreement or further Order of Court, Father shall enjoy this time at Mother's residence or with Mother being in reasonable proximity of the Children. b. Father shall have physical custody/visitation every other Sunday from 11:00 am until 7:00 pm at an agreed upon location. Absent mutual agreement, Mother shall provide the transportation to Father's residence or some other agreed upon location and Mother shall pick the Children up. C. Father shall have additional physical custody periods of the Children at such other times or circumstances as the parties may mutually agree. 3. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 4. The custodial parent shall utilize appropriate Child restraints/seats when transporting the Children. 5. Neither party may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. ???.^i`? 3'?? ?cj?? ??? ?? ' ?? r, ?r'Y?. ?i%.! 6. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. 7. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 8. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. 9. A status update conciliation conference is hereby scheduled for June 18, 2008 at 10:00 am at the Cumberland County Court of Common Pleas, Carlisle, PA 17013. By the Court, Yistribution: ? JFnnifer Spears, Esquire ?Todd Bible, P.O. Box 158, Franklintown, PA 17323 V/John J. Mangan, Esquire e0ptES rnaLL-CCL y/is?o8 JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-1525 CIVIL ACTION LAW TODD BIBLE, : IN CUSTODY Defendant CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Christopher Bible 9/15/1996 primary Mother Ian Bible 1/22/2000 primary Mother 2. A Conciliation Conference was held with regard to this matter on April 7, 2008 with the following individuals in attendance: The Mother, Jennifer Bible, with her counsel Jennifer Spears, Esq. The Father, Todd Bible, pro se 3. The parties agreed to the entry of an Order in the form as attached. Date Johr `J. angan, Esquire Cu?to4 Conciliator , r JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 08-1525 CIVIL ACTION LAW TODD BIBLE, IN CUSTODY Defendant Prior Judge: M.L. Ebert, Jr., J. ORDER OF COURT AND NOW this IT j day of June 2008, upon consideration of the attached Custody Conciliation Report, it is Ordered and Directed as follows: 1. The prior Order of Court dated April 14, 2008 is hereby VACATED. 2. Legal Custody: The Father, Todd Bible, and the Mother, Jennifer Bible, shall have shared legal custody of Christopher Bible, born 9/15/1996 and Ian Bible, born 1/22/2000. The parties shall have an equal right to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, medical, dental, religious or school records, the residence address of the Children and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. 3. Physical Custody: The Mother shall have primary physical custody of the Children subject to Father's supervised partial physical custody as the parties may agree. 4. The non-custodial parent shall have liberal telephone contact with the Children on a reasonable basis. 5. The custodial parent shall utilize appropriate Child restraints/seats when transporting the Children. 6. Neither parry may say or do anything nor permit a third party to do or say anything that may estrange the Children from the other party, or injure the opinion of the Children as to the other party, or may hamper the free and natural development of the Children's love or affection for the other party. To the extent possible, both parties shall not allow third parties to disparage the other parent in the presence of the Children. 7. In the event of a medical emergency, the custodial parent shall notify the other parent as soon as practicable after the emergency is handled. 8. During any periods of custody or visitation, the parties shall not possess or use non-prescribed controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. 9. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. By the Court, Distribution: ,-rennifer Spears, Esquire add Bible, P.O. Box 158, Franklintown, PA 17323 ,J'6hn J. Mangan, Esquire I>?t,','4iti?t?{tr r? 3 I : 1 HIJ U NIn HE i1 11 iJ ' r' Hi dO JENNIFER BIBLE, Plaintiff V. TODD BIBLE, Defendant Prior Judge: M. L. Ebert, Jr., J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 08-1525 CIVIL ACTION LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 3. The pertinent information pertaining to the Children who are the subject of this litigation is as follows: Name Date of Birth Currently in the Custody of Christopher Bible 9/15/1996 primary Mother Ian Bible 1/22/2000 primary Mother 2. A Conciliation Conference was held with regard to this matter on April 7, 2008, and Order of Court was issued April 14, 2008 and a status update conference was held on June 18, 2008 with the following individuals in attendance: The Mother, Jennifer Bible, with her counsel Jennifer Spears, Esq. The Father, Todd Bible, pro se, did not appear. 3. Since the last conciliation conference, Mother alleges that Father has not taken advantage of the custodial periods as outlined in the order of Court dated 4/14/08. Father apparently has seen the Children approximately three or four times for abbreviated periods. Mother alleges that Father may have some untreated mental health issues and that Father is not employed as Father indicated at the last conciliation conference. Also, Mother asserts that Father has moved at least once since April 2008. At present time, Mother is unaware of Father's whereabouts and believes that Father may have relocated back to the state of Washington. 4. The assigned Conciliator recommends the entry of an Order in the form as attached as said recommended Order is in the Children's best interest. (r Zz g- -L6-Date J Mangan, Esq ust y Conciliator RLED-0? OF THE PROTHO)NIOTAPY Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff 2010 MAR 19 PM 2: 13 JENNIFER BIBLE, TODD BIBLE, Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-1525 CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 6, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. § 4904 relating to unsworn falsification to authorities. Date: _? J ' er Bible, P ntiff 7 Jennifer L. Spears, Esquire (y THE -!CN0TAPY MARTSON DEARDORFF WILLIAMS OTTO GILROY & PA MARTSON LAW OFFICES g P 2,13 I.D. 87445 10 East High Street GUki . ! Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1525 CIVIL ACTION - LAW TODD BIBLE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301 (d) OF THE DIVORCE CODE 1. 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 waiver 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: 1;) A Q? kc) J r Bible, Plai ff F: \FILES'\Clients17122 Hyatt\7122.333 Bible\7122.333.plaintiffaff Revised: 3/4,10 1 1:13AM rr OF THE P,UTP1r-',AJf0TARY Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street0 Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, TODD BIBLE, Plaintiff V. Defendant 2010 MAR 19 PM 2: 13 CUM 4 ') r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1525 CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFENDANT 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. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on December 15, 2006, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. (7?\Q t ljo (2? Date: ? n ? 10 J fer Bible, aintiff A- , -. F:\FILES\Clients\7122 Hyatt\7122.333 Bible\7122.333.cos2 Revised: 11/7/11 10:49AM Cl ? (-% 3 Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER °p MARTSON LAW OFFICES co =-n I.D. 87445 =C:) w C) 10 East High Street0 3> 2 Carlisle, PA 17013 ° 70 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1525 CIVIL ACTION - LAW TODD BIBLE, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Jennifer L. Spears, Esquire, attorney for Plaintiff, hereby certify that a copy of the attached Notice of Intention to Request Entry of §3301 (d) Divorce Decree and Counter- Affidavit under Section 3301(d) of the Divorce Code was mailed November 4, 2011, by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Todd Bible, P.O. Box 404, Franklintown, PA 17323. MARTSON LAW OFFICES Date: November 7, 2011 ?f By. Jennife L. Spears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff w Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ---------------------------------------------------------------------------------------------------- JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1525 CIVIL ACTION - LAW TODD BIBLE, Defendant . IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: Mr. Todd Bible P.O. Box 404 Franklintown, PA 17323 DEFENDANT 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 November 24, 2011, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 717-249-3166 Date: November 4, 2011 Jen f r L. Spears, Esquire MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff HFILESTlients\7122 Hyatt\7122.333 Bible\7122.331counteraff Revised: 314/10 10:52AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, TODD BIBLE, Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-1525 CIVIL ACTION - LAW : IN DIVORCE/CUSTODY COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 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) 1 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 ofmy 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 notice to me, and I shall be unable thereafter to file any economic claims. 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. §4904 relating to unsworn falsification to authorities. Date: Todd Bible, Defendant 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 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 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. FAHLES\Clients,7122 Hyatt\7122.333 Bible\7122.333,pra Revised: 11/21/11 11 ]SAM Jennifer L. Spears, Esquire MARTSON LAW OFFICES I.D. 87445 10 East High Street0 Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ?011 NOV 28 PM 1: 23 CUMBERLx ,l) CowgT y PENNSYLVANIA, JENNIFER BIBLE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1525 CIVIL ACTION - LAW TODD BIBLE, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD (3301d) 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 Section 3301(d) of the Divorce Code. 1 Date and manner of service of the complaint: Certified mail, restricted delivery, return receipt, on March 8, 2008. 3. (1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: September 26, 2011. (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on September 28, 2011, and served on or about September 29, 2011. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe, a copy of which is attached hereto: November 4, 2011, by first class mail. MARTSON W OFFICES By Jennifer L S ears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 November 28, 2011 Attorneys for Plaintiff C"R C:) i -TJ Jennifer L. Spears, Esquire N rv o0 r ) ,? MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER .? MARTSON LAW OFFICES I.D. 87445 ;r ?r ; 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff --------------------------------------- JENNIFER BIBLE, ---------------------------------------------------------- IN THE COURT OF COMMON PLEAS OF --- Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1525 CIVIL ACTION - LAW TODD BIBLE, Defendant . IN DIVORCE O d NOTICE OF INTENTION TO REQUEST ENTRY OF 6 3301(d) DIVORCE DECREE TO: Mr. Todd Bible P.O. Box 404 Franklintown, PA 17323 DEFENDANT 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 November 24, 2011, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 717-249-3166 Date: November 4, 2011 Jenr& r L. Spears, Esquire MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff - , V. Defendant : NO. 08-1525 CIVIL ACTION - LAW : IN DIVORCE/CUSTODY COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 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 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. ' F: FILESTIi t.\7122 H).M7122.333 BibI67122.331countanff ,,Revised: 3/4/10 10:52AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JENNIFER BIBLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TODD BIBLE, 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 notice to me, and I shall be unable thereafter to file any economic claims. 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. §4904 relating to unworn falsification to authorities. Date: Todd Bible, 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.