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Home My WebLink About09-1340IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Victoria Lynn Boehm Plaintiff c vs. No. Charles Justin Boehm Defendant 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, property or other rights important to you, including the right to demand marriage counseling. When the ground for divorce is indignities of irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary for Cumberland County: CUMbEV-LAy49 CQ%Ai3TJ COt49_T14014SE- 1 COUCTIAOUSE SQUAY-E. SU%TE 100 CAQ-u5LE , PA 1-1013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service Adams Co., Gettysburg: (717) 334-6781 Allegheny Co., Pittsburgh: (412) 261-0518 Armstrong Co., Kittanning: 724-548-3251 Beaver Co., Beaver: (412) 728-4888 Bedford Co., Bedford: 814-623-4833 Berks Co., Reading: (610) 375-4591 Blair Co., Hollidaysburg: (814) 693-3090 Bradford Co., Towanda: (570) 265-1705 Bucks Co., Doylestown: (215) 348-9413 Lackawanna Co., Scranton: (570) 969-9600 Lancaster Co., Lancaster: (717) 393-0737 Lawrence Co., New Castle: (724) 656-2143 Lebanon Co., Lebanon: (717) 274-2801 Lehigh Co., Allentown: (610) 433-7094 Luzerne Co., Wilkes-Barre: (717) 822-6712 Lycoming Co., Williamsport: (570) 327-2251 McKean Co., Smethport: (814) 887-3270 Mercer Co., Mercer: (724) 342-3111 Butler Co., Butler: (724) 284-5214 Cambria Co., Ebensburg: (814) 472-1636 Cameron Co., Emporium: (814) 468-3355 Carbon Co., Jim Thorpe: (570) 325-2481 Centre Co., Bellefonte: (814) 355-6796 Chester Co., West Chester: (610) 429-1500 Clarion Co., Clarion: (814) 226-1119 Clearfield Co., Clearfield: (814) 765-2641 Clinton Co., Loch Haven: (570) 893-4007 Columbia Co., Bloomsburg: (570) 389-5600 Crawford Co., Media: (814) 333-7324 Cumberland Co., Carlisle: (717) 249-3166 Dauphin Co., Harrisburg,: (717) 232-7536 Delaware Co., Media: (610) 566-6625 Elk Co., Ridgway: (814) 776-5344 Erie Co., Erie: (814) 459-4411 Fayette Co., Uniontown: (724) 430-1272 Forest Co., Tionesta: (814) 755-3526 Franklin Co., Chambersburg: (717) 261-3858 Fulton Co., McConnellsburg: (717) 485-4212 Greene Co., Waynesburg: (724) 852-5289 Huntingdon Co., Huntingdon: (814) 643-1610 Indiana Co., Indiana: (724) 465-3855 Jefferson Co., Brookville: (814) 849-1606 Juniata Co., Mifflintown: (717) 436-7715 Mifflin Co., Lewistown: (717) 248-8146 Monroe Co., Stroudsburg: (570) 424-7288 Montgomery Co., Norristown: (610) 279-9660 Montour Co., Danville: (570) 271-3010 Northampton Co., Easton: (610) 258-6333 Northumberland Co., Sunbury: (570) 988-4151 Perry Co., New Bloomfield: (717) 582-2131 Philadelphia Co., Philadelphia: (215) 238-1701 Pike Co., Milford: (570) 296-7231 Potter Co., Coudersport: (814) 274-9740 Schuylkill Co., Pottsville: (570) 628-1270 Snyder Co., Middleburg: (570) 837-4202 Somerset Co., Somerset: (814) 445-1428 Sullivan Co., Laporte: (570) 946-7351 Susquehanna Co., Montrose: (570) 278-4600 Tioga Co., Wellsboro: (570) 724-9281 Union Co., Lewisburg: (570) 524-8751 Venango Co., Franklin: (814) 432-9577 Warren Co., Warren: (814) 728-3440 Washington Co., Washington: (724) 225-6710 Wayne Co., Honesdale: (570) 253-5970 Westmoreland Co., Greensburg: (724) 834-8490 Wyoming Co., Tunkhannock: (570) 253-5970 York Co., York: (717) 854-8755 COUNSELING NOTICE UNDER Pa.R.C.P. RULE 1920.45(a)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6) Indignities Section 3301 (c) Irretrievable Breakdown Mutual Consent Section 3301(d) Irretrievable Breakdown Two-Year Separation where the court determines that there is not a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the Prothonotary Office of the Cumberland County court. CUM I?1E12-LAislP cow4ry Cou-TNousF. I COUK.TNOUSE SQUARE . SV%'TE kOO CAP-L-1-SE. , FA 11015 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Victoria Lynn Boehm Plaintiff VS. No. 09- f34'0 C t?J- 7?, Charles Justin Boehm Defendant DIVORCE COMPLAINT UNDER SECTION 33010 OF THE DIVORCE CODE 1. The Plaintiff is Victoria Lynn Boehm, who currently resides at 104 Ewe Road, Mechanicsburg, Pennsylvania 17055. She has resided at this address at least since January 2009. The Plaintiff previously resided at 919 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055 since April 2006. 2. The Defendant is Charles Justin Boehm, who currently resides at 919 Old Silver Spring Road, Mechanicsburg, Pennsylvania 17055. He has resided at this address at least since April 2006. 3. Both the Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 20, 2006, at Liberty Forge, Mechanicsburg, Pennsylvania, County of Cumberland. 5. Neither the Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Servicemember's Civil Relief Act of 2003 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, the Plaintiff intends to file an affidavit consenting to a divorce. The Plaintiff believes that the Defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, the Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. COUNT II REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) and 3323(6) DIVORCE CODE 1. Paragraphs 1 through 10 are incorporated herein and made a part hereof by reference as though fully set forth. 2. The Plaintiff and Defendant have reached an agreement on issues including alimony, property division, child support and child custody. WHEREFORE, the Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between the Plaintiff and Defendant into the final divorce decree, pursuant to Sections 3104(a) (1) and (3) and 3323(b) of the Divorce Code. I 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.C.S. §4904, relating to unsworn falsification to authorities. 3I2Io9 ??? ?? Date Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Victoria Lynn Boehm Plaintiff vs. No. Charles Justin Boehm Defendant DIVORCE VERIFICATION I 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 of 18 PA. C.S., §4094, relating to unsworn falsification to authorities. 312101 Date Plaintiff R? v 4 ?n (7) ` &-13qa AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . ss; The Plaintiff, being duly sworn according to law, deposes and says that she is the Plaintiff in the above captioned matter and that she personally knows that the Defendant is over the age of eighteen (18) years. The Plaintiff further avers that the Defendant is not in the Military Service or in any branch of the Armed Forces of the United States of America or its Allies or otherwise within the provisions of the Soldier's and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. SWORN and Subscribed to Before me thisj-?_ day of M.nr h , 2009. J- VICTORIA LYNN BOEHM OTARY PUBLIC COMMONWE LTH OF PENNSYLVANIA NOTARIAL SEAL JULIEANNE AMETRANO, Notary Public City of Harrisburg, Dauphin County My Commission Expires Feb. 22, 2011 t OFFICE C?r P, ,, Yf)j TARP 2909 APR 15 PM 12. t "ern . B/11y .i 6 ?L..} ? ??t? r Li, e.. c3W AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN . ss; I, VICTORIA LYNN BOEHM, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. VICTORIA LYNN BOEHM SWORN and Subscribed to Before me this r 2 _ day of PAAk C,NI .32009. 11? "- N PUBLIC OOMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JULIEANNE AMETRANO, Notary Public City of Harrisburg, Dauphin County My Commission Expires Feb. 22, 2011 RLED-OFFICE OF THE PROF ", QTARY 2089 APR 15 PM 12: 21 GUP? is v 1 >UNITY !fA PE N' A ti VICTORIA LYNN BOEHM, Plaintiff V. CHARLES JUSTIN BOEHM a/k/a JUSTIN BOEHM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-1340 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 minor 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, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 849-3166 Date: April 13, 2009 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 I % VICTORIA LYNN BOEHM, Plaintiff V. CHARLES JUSTIN BOEHM a/k/a JUSTIN BOEHM, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-1340 DIVORCE Defendant AMENDED COMPLAINT IN DIVORCE COUNT I - DIVORCE AND NOW, comes the Plaintiff, Victoria Lynn Boehm, by and through her counsel, Cunningham & Chernicoff, P.C., and seeks to obtain a Decree in Divorce from the Defendant, Charles Justin Boehm, and support thereof avers as follows: I . The Plaintiff, Victoria Lynn Boehm ("Plaintiff'), currently resides at 104 Ewe Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. The Plaintiff is a citizen of the United States of America. Plaintiff's Social Security Number is 193- 68-7807. 2. The Defendant, Charles Justin Boehm a/k/a Justin Boehm ("Defendant"), currently resides at 919 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. The Defendant is a citizen of the United States of America. Defendant's Social Security Number is 192-60-8801. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on May 20, 2006 in Cumberland County, Pennsylvania. 6. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the Court the parties to participate in counseling. WHEREFORE, Plaintiff, Victoria Lynn Boehm, hereby respectfully requests this Honorable Court to enter a Decree in Divorce from the bars of matrimony. COUNT II - EQUITABLE DISTRIBUTION 9. The averments of Paragraphs 1 through 8 are incorporated herein by reference as if fully set forth. 10. During the course of the marriage, the parties acquired marital property. WHEREFORE, Plaintiff, Victoria Lynn Boehm, hereby respectfully requests this Honorable Court to determine, divide, distribute and assign the marital property of the parties pursuant to Section 35 of the Divorce Code. By: Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Date: April 13, 2009 Attorneys for Plaintiff, Victoria Lynn Boehm F:\Home\KKNIGHT\DOCS\BOEHM.VICTORIA\Amended Complaint.WPD P.O. Box 60457 VERIFICATION I verify that the statements made in the foregoing Amended Complaint 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. VICTORIA LYNN BOEHM Date: 1W Gtich / 7 , 2009 FILED-4.j -cnC OF THE p^Dr, io,iDTARY 2009 APIA 15 PP4 12: 21 A.t 'a t u?1"?fY $J'Uo.c* P ATE/ VICTORIA LYNN BOEHM, Plaintiff V. CHARLES JUSTIN BOEHM a/k/a JUSTIN BOEHM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-1340 DIVORCE CERTIFICATE OF SERVICE I, Julieanne Ametrano, Legal Assistant, with the law firm of Cunningham & Chernicoff, P.C., hereby certify that a true and correct copy of the Amended Complaint in Divorce was served upon the Defendant, at the following address, on May 4, 2009 as evidenced by the Acceptance of Service attached as Exhibit "A": Mr. Charles Justin Boehm a/k/a Justin Boehm 919 Old Silver Spring Road Mechanicsburg, PA 17055 CUNNINGHAM & CHERNICOFF, P.C. Date: May 8, 2009 u ieanne Ametrano ar 0North Second Street risburiz. PA 17106-0457 F:\Home\KKNIGHT\DOCS\BOEHM. V ICTORIA\COS.Acceptance.wpd EXHIBIT `A' VICTORIA LYNN BOEHM, Plaintiff V. CHARLES JUSTIN BOEHM a/k/a JUSTIN BOEHM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-1340 DIVORCE ACCEPTANCE OF SERVICE I, Charles Justin Boehm a/k/a Justin Boehm, hereby accept service of the attached Amended Complaint in Divorce which was filed with the Cumberland County Prothonotary on April 15, 2009 to the above docket number and certify that I am authorized to do so. By: Charles ti Boe A a/k/a Justin e F:\IiomeIKKAIIGHT\DOCS\BOEHM. VICTORIA1Amended Complaint. WD FILCG? -;..t ?4 L. 'J,IC THE B ,. tr, -TAi 2009 MAY 1 I pr'" 1: 0 b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION VICTORIA LYNN BOEHM Plaintiff Vs File No 09-1340 IN DIVORCE CHARLES JUSTIN BOEHM a/k/a JUST BOEHM Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the -A-Plaintiff Defendant in the above matter [Select one o the following] prior to the entry of a Final Decree in Divorce, or ? after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of VICTORIA LYNN NEYHARD, and gives this written notic avowing her intention pursuant to the provisions of 54 P.S. § 704 Date 5 Z010,7 Signature Signature of n being resumed UUMMONW ALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS - On the 1 Gday of , 200?, before me, the Prothonotary or a Notary Public, personally appeared the above of t known to me to be the person whose name is subscribed to he within document and acknowledged that he/she executed the foregoing for the purpose therein contained In Witness Whereof, I have hereunto set my hand and official seal onotary or otary Public qOVAK Eft Proth. - 61 ANGRA L Wool (Rev. 4/01) r4ow PWAG _ CCOWW ComnNN?o?+IM?PNM ; i THE PROT 2009 Mill 21 tie 3 fr?::? r d- a` r' y c`u?`n; n q ?t k.h 12 ! 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