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Home My WebLink About08-4187BRANDI BONAWITZ, Plaintiff vs. CLAYTON N. BONAWITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. d ?,-- N f RI Civil Term 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 f BRANDI BONAWITZ, Plaintiff vs. CLAYTON N. BONAWITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0 ?'- 91 'cC"] Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Brandi Bonawitz, a competent adult individual, who resides at 14 N. Orange St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Clayton N. Bonawitz, a competent adult individual, who resides at 1191 McClures Gap Road, Carlisle, Cumberland County, Pennsylvania, 17015. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on February 14, 2002 in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ? L dA- NAUX4 Brandi Bonawi , Plaintiff Respectfully subm Date: ne Adams, Esquire YNo. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF CD Cam. -Tj LAJ A BRANDI BONAWITZ, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 08 - 4187 Civil Term CLAYTON N. BONAWITZ, ACTION IN DIVORCE Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Date: -w /? 0 g Respectfully submitted, j,dje Adams, Esquire . No. 79465 W. South St. W Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -71 1 r ! CS BRANDI BONAWITZ, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND `COUNTY, PENNSYLVANIA vs. No. Civil Term CLAYTON N. BONAWITZ, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE The undersigned Constable, upon oath, deposes and says: I served Clayton N. Bonawitz, Defendant, a copy of the NOTICE TO DEFEND and COMPLAINT IN DIVORCE in the above-captioned action, as follows: Date Served: `1; Time Served: Person Documents Delivered to: (J (,?, 8f1,?wtS Location where served: Signed: Con ab a bert Lindsay 9 v Noprid 3a1 C?lisk ?,A r ? ??Y ?xpmes Sept 6, 2008 Sworn to and Subscribed before me this day of (?O" 2008. FV JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams®gmail.com BRANDI BONAWITZ, V. CLAYTON N. BONAWITZ, BLED-OFF--CE ?:)I~ E TH PE07tjo?PJOTApy 2010 FEB -5 PM 2= 52 PtNNXVAt : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008 - 4187 ACTION IN CUSTODY Defendant PETITION TO WITHDRAW AS LEGAL COUNSEL AND NOW COMES the Petitioner, Jane Adams, Esquire, and files the above- referenced Petition and represents that: 1. Petitioner is Jane Adams, Esquire, an Attorney duly authorized to practice law in the Commonwealth of Pennsylvania, having a principal place of business located at 17 W. South St., Carlisle, Pa. 17013 2. Petitioner is currently attorney of record for Brandi Bonawitz, Plaintiff, in the above-captioned matter. Her address is 14 N. Orange St., Carlisle, Pa., 17013. 3. A custody hearing is currently scheduled in this matter before this Honorable Court on Friday, February 26, 2010. 4. Defendant is currently self-represented. 5. Since Petitioner has undertaken the representation of Plaintiff, the following events have occurred which make it impossible or impractical for her to continue in this legal representation: (a) Plaintiff has indicated that she would not be able to honor the fee agreement from this point forward and would prefer to represent herself at the February 26, 2010 hearing. (b) Plaintiff signed a letter, which is attached as Exhibit A, indicating her consent to counsel's withdraw on this matter. (c)Plaintiff indicated that she intended to represent herself and that she felt comfortable representing herself. (d) Requiring counsel to stay on the case would be burdensome as substantial additional preparation would be required and Plaintiff has clearly indicated she cannot honor the fee agreement. 6. This matter was previously assigned to Judge Hess. 7. Petitioner was unable to contact Clayton N. Bonawitz, who is self- represented, however she knows of no reason that he would object to Petitioner's request. 8. Withdrawal of Petitioner's appearance would not be prejudicial to the parties. WHEREFORE, Jane Adams, Esquire requests permission to withdraw her appearance from the above-captioned matter. Date: /b Respectfully Submitted, ne Adams, Esquire D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT January 20, 2010 To: Jane Adams, Esquire 17 West South Street Carlisle, Pa. 17013 Dear Jane: Please be advised that I no longer wish for you to be my attorney and I consent to you withdrawing your appearance on my behalf. I plan on representing myself at the upcoming hearing in February. I understand that you have filed a Motion with the Court to formally withdraw your appearance and I consent to such action. Signed: L Tonya Bonawitz 19 Cold Spring Road Carlisle, Pa. 17015 CERTIFICATE OF SERVICE AND NOW, this February 5, 2010, I, Jane Adams, Attorney for Brandi Bonawitz, hereby certify that a copy of this PETITION is being forwarded contemporaneously with this mailing to the following parties, by placing such in first-class mail, addressed to: Brandi Bonawitz 14 N. Orange St. Carlisle, Pa. 17013 PLAINTIFF Clayton N. Bonawitz 1191 McClure's Gap Road Carlisle, Pa. 17013 DEFENDANT e Adams,-Esquire 1. . No. 79465 7 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR DEFENDANT OF 4 08 ?res. FEB 2010 FEB - 9 AH 10: 0 S CUPS? : v; S` !?uid ? Y ?'F' ??iLVf?hJfH BRANDI BONAWITZ, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 2008 - 4187 CLAYTON N. BONAWITZ, : ACTION IN CUSTODY Defendant ORDER OF COURT AND NOW, this J'' day of 2010, upon consideration of the within Petition, Attorney Jane Adams, is permitted to withdraw her appearance for Brandi Bonawitz, regarding the above-captioned matter. BY THE COURT: cc: ?Jane Adams, Esquire '-' Brandi Bonawitz, Plaintiff ____?Clayton N. Bonawitz, Defendant l20 J 'C57 ?ria-t L l? ca/ghv of cUM 1David 1D. Buell 44 e P Renee 7 Simpson Prothonotary D 1S` Deputy Prothonotary ' �� "� XirkS. Sofionage, ESQ, 77, Irene E. Morrow Solicitor 1750 2nd Deputy(Prothonotary Office of the Prothonotary Cum6erlantl County, Pennsylvania —41/87 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291H DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717 240-6195 • Fa.,(717)240-6573