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HomeMy WebLinkAbout04-0769JEFFREY L. BOUDER, Plaintiff Vo TIFFANIE A. BOUDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. o~t- ~Gq CIVILTERM : 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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, Pennsylvania 17013 (717) 249-3166 JEFFREY L. BOUDER, Plaintiff Vo TIFFANIE A. BOUDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. o ¥- '76~ CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Jeffrey L. Bouder, an adult individual currently residing at 17 South High Street, Carlisle, Cumberland County, Pennsylvania. Defendant is Tiffanie A. Bouder, an adult individual currently residing at 19 West Main Street, Newville, Cumberland County, Pennsylvania. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on November 20, 1992, in Cumberland County, Pennsylvania. There have been no other prior actions for divorce or annulment between the parties. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divome based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. mitted, ~L. ~fiffie, Esquire Attorney fiTr Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION verify that thc statoment~ raacl~ in th~ £or~going do~a~nCnt aro t~ md ¢o~t. 1 undcmtand that raise smmmcnts hc~: ~c i~dc subj~t lo ff~c pcnaldca of 18 Pa.C.S. 49~. relating [o unswom galsJficafions ~ auto, tics. JEFFREY L. BOUDER, Plaintiff VS. TIFFANIE A. BOUDER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-769 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this _ /i~: day of March, 2004, comes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, Jeffrey L. Bouder, and states that a true and attested copy of a Complaint in Divorce, was forwarded to Tiffanie A. Bouder, at 19 West Main Street, Newville, PA 17241, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on February 28, 2004. '~xtrforney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this l~ day of. /~a/~b~ ,2004 AR~ P~dBLIC Re~tricted ~ JEFFREY L. BOUDER, Plaintiff TIFFANIE A. BOUDER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04-769 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on February 23, 2004, and served on February 28, 2004. 2. The man'iage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING 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. JEFFREY L. BOUDER, Plaintiff TIFFANIE A. BOUDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 04-769 CIVIL TERM : 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE, DECREE UNDER §3301~c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a diw)rce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE Eq THE FOREGOING 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 UNSWOKN FALSIFICATION TO AUTHORITIES. T~b'lSAlffIJKak. BOUDER, Defendant JEFFREY L. BOUDER, Plaintiff V. TIFFANIE A. BOUDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 04-769 CIVIL TERM :1N DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §330l (c) of the Divorce Code was filed on February 23, 2004, and served on February 28, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELAT1NG TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: JEFFREY L. BOUDER, Plaintiff TIFFANIE A. BOUDER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 04-769 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 JEFFREY L, BOUDER, Plaintiff TIFFANIE A. BOUDER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-769 CIVIL TERM IN DIVORCE 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 §3301 (c) 3301 (d)(1) of th* Divorce Codo. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Certified mail, restricted delivery on February 28, 2004. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: June 10, 2004 by Defendant: June 3, 2004 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 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 plaintiWs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 11, 2004 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: June 8, 2004 ~;qAu~r;s Attorney for Plaintiff IN THE COURT OF COMMON PLEAS STATE OF JEFFREY L. BOUDER, Plaintiff VERSUS TIFFANIE A. BOUDER, Defendant OF CUMBERLAND COUNTY ,p~~, PENNA. No. 04-769 CiVil Term DECREE IN DIVORCE AN D NOW, DECREED THAT Jeffrey L. Bouder AND Tiffanie A. Bouder , ~1~'¢~ , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; BY THE COURT:/ ~ I -- PROT~(~dTARY