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Home My WebLink About08-3472JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff BREE D. BOND, Plaintiff VS. CHRISTOPHER M. BOND, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :No M- 347A Civi (Term CIVIL ACTION - AT LAW 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. When the ground for 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 the Cumberland 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 17013-3308 (717) 249-3166 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff BREE D. BOND, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CHRISTOPHER M. BOND, Defendant No 4 F-.31/ 7z Cte? d Tc.?. CIVIL ACTION - AT LAW DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Bree D. Bond, by and through her attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Divorce: 1. Plaintiff, Bree D. Bond, is an adult individual currently residing at 2465 Bladestone Trail, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant, Christopher M. Bond, is an adult individual currently residing at 1409 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 22, 1996 in Charlottesville, Virginia. 1 COUNT I - DIVORCE 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 10. There are three (3) dependent children from this marriage, namely Ava Bond, born August 4, 2003, Kailyn Bond, born August 31, 2005, and Tori Bond, born August 31, 2005. 11. This action is not collusive. COUNT II - CUSTODY 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. Plaintiff has filed a Complaint in Custody simultaneously with this Complaint in Divorce. The contents of said Complaint in Custody are incorporated herein by reference as though fully set forth herein. 2 WHEREFORE, Plaintiff, Bree D. Bond, respectfully requests this Honorable Court grant her relief from the bonds of matrimony and order a Decree in Divorce. Respectfully Submitted: By: NNE & COSTOPO , ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: 6,/? ATTORNEY FOR PLAINTIFF ( 0 3 VERIFICATION I, Bree D. Bond, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. 1 Date: ?a Bree D. Bond C w o 23 cn C= cn 1 \Q? Ci 3 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff BREE D. BOND, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No O F- 31) 7a. L24,,-? ?? CHRISTOPHER M. BOND, CIVIL ACTION - AT LAW Defendant CUSTODY COMPLAINT IN CUSTODY AND NOW, comes Plaintiff, Bree D. Bond, by and through her attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Custody: 1. Plaintiff, Bree D. Bond, is an adult individual currently residing at 2465 Bladestone Trail, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant, Christopher M. Bond, is an adult individual currently residing at 1409 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. There are three (3) dependent children from this marriage, namely Ava Bond, born August 4, 2003, Kailyn Bond, born August 31, 2005, and Tori Bond, born August 31, 2005. 4. The parties are married. The children were not born out of wedlock. Plaintiff is filing a Complaint in Divorce under Section 3301(c) of the Divorce Code simultaneously with this Complaint in Custody. 5. The children are currently in the custody of Plaintiff, Bree D. Bond, residing at 2465 1 Bladestone Trail, Enola, Cumberland County, Pennsylvania, 17025. 6. Since birth until the parties' separation in July of 2007, the children resided with both parties at 2465 Bladestone Trail, Enola, Cumberland County, Pennsylvania, 17025. Since July of 2007, the children have resided with primarily with Plaintiff at 2465 Bladestone Trail, Enola, Cumberland County, Pennsylvania, 17025. 7. Plaintiff is the natural mother of the children and she currently resides with the children at 2465 Bladestone Trail, Enola, Cumberland County, Pennsylvania, 17025. 8. Defendant is the natural father of the children and he currently resides alone at 1409 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 9. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other Court. 10. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 11. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 12. The best interest and permanent welfare of the children will be served by granting Plaintiff primary physical and shared legal custody of the parties' three (3) children. 13. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. 2 WHEREFORE, Plaintiff, Bree D. Bond, respectfully requests this Honorable Court to grant her primary physical and shared legal custody of the parties' three (3) minor children. Date Respectfully Submitted: By: ANNE B. COSTOPOULOS, SQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 /?k Attorney for Plaintiff 3 VERIFICATION I, Bree D. Bond, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. ?-??? - Date: -3-09 Bree D. Bond Cl p O C I T C. TT f tiT; C.J7 BREE D. BOND IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. CHRISTOPHER M. BOND DEFENDANT 2008-3472 CIVIL ACTION LAW . IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 11, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, July 08, 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/ Jacqueline M. Verney, Esq. ?? 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 ? t Ui`di1 +i '` 3Hl ?O JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff BREE D. BOND, Plaintiff VS. CHRISTOPHER M. BOND, Defendant To the Prothonotary: THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No 2008-3472 Civil Term CIVIL ACTION - AT LAW DIVORCE/CUSTODY Please mark the above-referenced divorce and custody action filed on June 6, 2008, withdrawn, discontinued and dismissed. By. `?.._ NE B. COSTOPO ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff Date: Z- ? .I ?-+?? - . 1.?, ..«... a "q ... i C..! L`:.y; .. SEP - e 2009 1-n BREE D. BOND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-3472 CIVIL ACTION - LAW CHRISTOPHER M. BOND, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this l01h day of September, 2009, having been advised that the parties have reconciled, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, AA , V ac ,line M. Verney, Esquire, C ody Conciliator OF TrE ?'RDTHOMYARY 2009 SEP 14 Phi 2: 2 7