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Home My WebLink About08-5257STEPHANIE E. CHERTOK, ESQUIRE CINDY L. HRIBAL, ESQUIRE PA Supreme Court ID: 52651 PA Supreme Court ID: 202325 61 West Louther Street 61 West Louther Street Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-8749 Attorneys for Plaintiff BENJAMIN C. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLOTTE M. BLOSSER, Defendant No.: o 0 -,5 25'7 CIVIL ACTION - LAW 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. 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 STEPHANIE E. CHERTOK, ESQUIRE CINDY L. HRIBAL, ESQUIRE PA Supreme Court ID: 52651 PA Supreme Court ID: 202325 61 West Louther Street 61 West Louther Street Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-8749 Attorneys for Plaintiff BENJAMIN C. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLOTTE M. BLOSSER, Defendant No.. V ??- i?oZ S?? GI'J! CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER & 3301(d) OF THE DIVORCE CODE Plaintiff is Benjamin C. Blosser, who currently resides at 24 North Hanover St. (Rear), Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Charlotte M. Blosser, who currently resides at 76 Country View Estates, Newville, Cumberland County, Pennsylvania. 3. No children have been born of this marriage. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 5. The Plaintiff and Defendant were married on October 28, 1991, at the Grace United Methodist Church, Carlisle, Cumberland County, Pennsylvania. 6. The Plaintiff and Defendant have been separated since May 1998. 7. There have been no prior actions for divorce or for annulment between the parties. 8. Neither Party in this action is a member of the Armed Forces. 9. The marriage is irretrievably broken, and the parties have been living separate and apart for over two (2) years. 10. 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 such counseling. WHEREFORE, The Plaintiff requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, tep anie erto A rney . No. 52651 Cindy L. Hribal, Esquire Supreme Court I.D. 202325 61 West Louther St. Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff VERIFICATION I, Benjamin C. Blosser, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. i Date: z"q Benja,n C. Blosser STEPHANIE E. CHERTOK, ESQUIRE CINDY L. HRIBAL, ESQUIRE PA Supreme Court ID: 52651 PA Supreme Court ID: 202325 61 West Louther Street 61 West Louther Street Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-8749 Attorneys for Plaintiff BENJAMIN C. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLOTTE M. BLOSSER, Defendant No.: CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Cindy L. Hribal, Esquire., counsel for Plaintiff, hereby certify that a copy of the Complaint for Divorce, directed to Defendant, Charlotte M. Blosser, was served upon Defendant at Defendant's residence, 76 Country View Estates, Newville, PA 17241, this 'J'-b-day of 2008, by first-class mail, postage prepaid, and certified mail, return receipt requested, pursuant to Pa. C.R.P. 1930.4(c). r.> ' w s Mi l vi l .' x`51 f f i "` \`J{ c 1 ? 1 O f? BENJAMIN C. BLOSSER Plaintiff V. CHARLOTTE M. BLOSSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5257 CIVIL ACTION - LAW : In Divorce PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Charlotte M. Blosser, the Defendant, in the above captioned matter. September 19 2008. Christina Ferreira Certified Legal Intern Anne ac on d-Fox, Es Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ° C ...- i C/1) r='t r ....r i. Z 0 STEPHANIE E. CHERTOK, ESQUIRE CINDY L. HRIBAL, ESQUIRE PA Supreme Court ID: 52651 PA Supreme Court ID: 202325 61 West Louther Street 61 West Louther Street Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff BENJAMIN C. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLOTTE M. BLOSSER, Defendant No.: Q IR sc?? CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about May, 1998 and have continued to live separate and apart to the present. 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. § 4904 relating to unsworn falsification to authorities. Date:-// c7 - fl V r C/, •i??.-t i Benj in C. Blosser PJ w- ?m ms's Fri STEPHANIE E. CHERTOK, ESQUIRE CINDY L. HRIBAL, ESQUIRE PA Supreme Court ID: 52651 PA Supreme Court ID: 202325 61 West Louther Street 61 West Louther Street Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff BENJAMIN C. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLOTTE M. BLOSSER, Defendant No.: 08-5257 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 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:, C)w 20 tZ 4944 t &Z 11 + 44"Jot 4, Charlotte M. Blosser `?: C? " ?, ?? t, .. ? 1Y ?t . ? x'y.? ? C,+' "p .+"' STEPHANIE E. CHERTOK, ESQUIRE CINDY L. HRIBAL, ESQUIRE PA Supreme Court ID: 52651 PA Supreme Court ID: 202325 61 West Louther Street 61 West Louther Street Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff BENJAMIN C. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CHARLOTTE M. BLOSSER, Defendant No.: 08-5257 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 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: %?- O,J:- U" Benja m C. Blosser C-l n.? BENJAMIN C. BLOSSER, Plaintiff V. CHARLOTTE M. BLOSSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 0,?- Ya 5--7 CIVIL ACTION - LAW 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(d) (1)) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: September 13, 2008, by Certified and Regular mail. 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 ; by defendant. b. (I) Date of execution of the affidavit required by §3301(d) of the Divorce Code: November 20, 2008 . (2) Date of filing and service of the plaintiff's affidavit upon the respondent.- Filed on 1V0v1eiwbY 21 , 2-ocV , Served cv, ?c?„ C,er2o 2.ceg 4. Related claims pending: N/A 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 plaintiff's Waiver of Notice was filed with the prothonotary: ,a 1,-% ,2008. Date defendant's Waiver of Notice was filed with the prothonotary: -*@ her 7(1(1Q_ pace v?, her ?.?S, 2vp? . -,..: ? 'Alto ey for Plaintiff -10 _s..: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN C. BLOSSFR PLAINTIFF V. CHARLOTTE M. BLOSSFR NO, OR-5257 DIVORCE DECREE AND NOW, A , Z.To f , it is ordered and decreed that BENJAMIN C. BLOSSFR , plaintiff, and CHARLOTTE M. BLOSSF.R , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, N-j _ ,0,1f. -gel ,,3° A j£,-f/ BENJAMIN C. BLOSSER, Plaintiff VS. CHARLOTTE M.BLOSSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5257 CIVIL ACTION -LAW In Divorce NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Defendant in the above matter, a Divorce Complaint having been filed on September 8, 2008, hereby elects to retake and hereafter use her previous name of Charlotte Bishop, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Charlotte M. Blosser I& I Charlotte M. Bishop SS. On the day of ??? , 2009, before me, a Notary Public, personally appeared Charlotte M. Blosser, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal. NOTARY PUBLIC NOTARIAL LINDA M. CARVER NOTARY PUBLtC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES DEC. 22, 2010 OF THEY , OTH .., IARY 2009 APR -2 Pit t: 25 Cum- itkji ,u