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Home My WebLink About09-8056HOWARD P. BERND, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. C-vl KATHERYN J. BERND, Defendant IN DIVORCE NOTICE TO DEFEND 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 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY ATTORNEYS•AT.IAW 26 West High Street Carlisle, PA SAIDIS, FLO ER & LI Carol J. Lindsay, sq ire Attorney Id. 446 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff HOWARD P. BERND, Plaintiff KATHERYN J. BERND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 69 , 8-6 S-4, IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE The Plaintiff is Howard P. Bernd, an adult individual, residing at 116 West Keller Street, Mechanicsburg, Pennsylvania. The Defendant is Katheryn J. Bernd, an adult individual, residing at 114 South Frederick Street, Mechanicsburg, Pennsylvania. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this The Plaintiff and Defendant were married on May 14, 1988 in Mechanicsburg, Cumberland County, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance SAIDIS, with §3301 of the Pennsylvania Divorce Code. FLOWER & LINDSAY S, ATIORNM AT.1AW 26 West High Street Carlisle, PA Carol J. Lindsay, s Attorney Id. 44698 26 West Hig reel Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. ?`-COJ rj-??"J Howard P. Bernd Date: / l - / gy -09 SAMIS, FLOWER & LINDSAY AT"MRNM-AT•IAW 26 West High Street Carlisle, PA p?'}run1?n,? 2099 MO 11 19 Pill 3:33 9 33 5,j fd a- -7 S?Jd15 61 e ?- i6 S fr)- ,eo ?- 3 3 1? 5-7 -7 0 4: ' ALP, HOWARD P. BERND, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW : NO. 09-8056 KATHERYN J. BERND, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Jane E. Adams, Esquire, counsel for Defendant, accept service of the Complaint in Divorce in the above-captioned matter and acknowledge that I am authorized to do so. I I /'C-s o q 6y__4? Date 9&eEE:?&. Adams, Esquire FLOWER ? LIlVDSAY ATMRNEYS-AT-1AW 26 West High Street Carlisle, PA Al FD-a:)FFICE OF THE P70 ri' , 2009 NOV 25 AM 11: 53 / l HOWARD P. BERND, IN THE COURT OF COMMON PL~S ,,,, Plaintiff CUMBERLAND COUNTY, PENN~VA~A ~~w a v. CIVIL ACTION -LAW ~'~~~" ~"' NO.09-8056 ~~~;;: t KATHERYN J. BERND, ~-= ~~,~ ~ ~ Defendant IN DIVORCE -t~ ~~ ~ ~ PLAINTIFF'S AFFIDAVIT OF CONSENT +f~ 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on November 19, 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 in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: 1 ~ ~ ~ Howard P. Bernd PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERS 3301 (c) 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 SAIDIS, FLOWER ~ LINDSAY 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. 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: 1 ~ (r (~ ~ 0 ~~_ ~ ~ ~~ Howard P. Bernd