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Home My WebLink About09-1080- Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- I ?d CIVIL TERM Pernell J. Bobonick, Jr. Defendant 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, 1 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 N 1 Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- CIVIL TERM Pernell J. Bobonick, Jr. Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is T n Y n °'r , who currently resides at (20 0 ur P? '?j Cumberland County, Pennsylvania. 2. Defendant is 'Who currently resides at 7591 I T IQ r--,\ To, 15ck?o Ik UA 23157 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on JR n e. ? t at Ca ?-- I Is Le- I PA 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. s 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. n (J t ?. Date P1 n iff, Se I, fY, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Z/Z() Date: y P1 i iff, Se Assisted by: Michael A. Scherer, Esq. O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 CZ) Y °?N Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.09-? CIVIL TERM Pernell J. Bobonick, Jr. Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, TiffanWapner, Plaintiff, to proceed in forma ap uperis. I, Michael A. Scherer, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. i Mic ael Scherer, Esquire Attorney for Plaintiff O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 - -?-€ ,. ? r,? , ?-, ?a e ?'- ?? , _ ?i -' ,.. .}y (? .. ? ?i .;? ° ?-, '17 ".? Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- logo CIVIL TERM Pernell J. Bobonick, Jr. Defendant 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 days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on Auqtxs? AIk-111(and continued to live separate and apart for a period of two y (44s-. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I, ? Cl L - U\?? n , verify that the statements made in this Affidavit are true and correc to the best my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. Date Plain iff, Pf e FILED-1F #?; OF THE PROTHONOTARY 2009 JON 30 AM 10: 4 3 MAE! Tiffany L. Wagner Plaintiff V. Pernell J. Bobonick, Jr. Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 09- I D130 CIVIL TERM : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check ether (a) or (b): U/ (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): d (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. 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 delay. 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: Pernell J. bonick, Jr. 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. OF THE PF.PG j O":'NOT 2009 JUN 30 41M 10., 4 J Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 1080 CIVIL TERM Pernell J. Bobonick, Jr. Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, I accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Da Pe ell J. Bobo n' ; Jr., Defendant OF TNc , I)TARY 2009 JUN 30 AN 10: 4 3 CUPv1F;:. . -7-Y Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.09-1080 CIVIL TERM Pernell J. Bobonick, Jr. Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on February 20, 2009• 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. 4' G r Date:6zl/q Signature: 2C .- Ti ny agner, Plaintiff RLED-OFFICE CAF THE PPOTH(4 MARY 2009 JUN 30 AM 10: 1, J CuiY??G.Jwy L. i~f 4,' ?ir? i Tiffany L. Wagner IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09-1080 CIVIL TERM Pernell J. Bobonick, Jr. Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(4) 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. 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 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:66 Q O9 Signature: Tdfa"n agner, Plaintiff ICED-Ci FiCE Or THE PFY)THOMOTARY 2009 JUN 30 AM 10: 141 Tiffany L. Wagner Plaintiff V. Pernell J. Bobonick, Jr Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 10 80 CIVIL TERM 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. 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 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:0&/19/69 Signature: ernell J. Bobo ' , Jr., Defendant A.? RLED-tai ';C E OF THE VHCNOTARY 2009 JUN 30 AM 10'. 4 4 cuk PE.WILIONNIA Tiffany L. Wagner Plaintiff V. Pernell J. Bobonick, Jr Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 1080 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 Section 33010 of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on February 28, 200.9 3. Date of execution of the Affidavit of Consent required by Section 3301(6b of the Divorce Code: by Plaintiff, by Defendant, Ici - ZQ°el . 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(d) Divorce was filed with the Prothonotary: .(UM V1, (c) Date Defendant's Waiver of Notice in Section 3301(4) Divorce was filed with the Prothonotary: Plaintiff's Social Security Number: Defendant's Social Security Number: 184-62-8812 202-70-5683 ( T#anyL. Wagner '?r ' ;, "T r, / IV ii I IN THE COURT OF COMMON PLEAS OF Tiffany L. Wagner CUMBERLAND COUNTY, PENNSYLVANIA V. Pernell J. Bobonick Jr. NO 09-1080 DIVORCE DECREE AND NOW, 7,w 01 , it is ordered and decreed that Tiffany L. Wagner plaintiff, and Pernell J. Bobonick Jr. 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, Attest: h J. J rothonotary `n i 1. y r + a .`