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F TILESTlients\13671 Bohn, Kara\13671.1.dcom
Revised, 12/2/09 9:14AM
Katie J. Maxwell, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
KARA L. BOHN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 09- Ifov t4 111 /
CIVIL ACTION - LAW
MATTHEW C. BOHN,
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 the divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. Upon your request, the Court may require you and your
spouse to attend up to three sessions. A request for counseling must be made in writing and filed
with the Prothonotary within twenty (20) days of receipt of this Notice.
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.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
KARA L. BOHN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.09- ?0 C w;,l Ti.r.?.-
CIVIL ACTION - LAW
MATTHEW C. BOHN,
Defendant IN DIVORCE
DIVORCE COMPLAINT UNDER SECTION 3301(C) or
3301 (D) OF THE DIVORCE CODE
1. Plaintiff is Kara Bohn, who currently resides at 950 West Old York Road, Carlisle,
PA 17015.
2. Defendant is Matthew Bohn, who, currently resides at 950 West Old York Road,
Carlisle, PA 17015.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on April 28, 2007, in Newville,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a decree of divorce.
WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage
between Plaintiff and Defendant.
MARTSON LAW OFFICES
By
Katie J. 1, Esquir-
10 East V-s4treet
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
Date: December 2, 2009
VERIFICATION
The foregoing Divorce Complaint is based upon information which has been gathered by my
counsel in the preparation of the lawsuit. The language of the document is that of counsel and not
my own. I have read the document and to the extent that the document is based upon information
which I have given to my counsel, it is true and correct to the best of my knowledge, information and
belief. To the extent that the content of the document is that of counsel, I have relied upon counsel
in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities, which provides that if I make knowingly false
averments, I may be subject to criminal penalties.
KardBoliiT'
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Katie J. Maxwell, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
I.D. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
KARA L. BORN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 09-8402
CIVIL ACTION -LAW
MATTHEW C. BOHN,
Defendant IN CUSTODY
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Defendant in the above matter having been served with a
Divorce Complaint on December 4, 2009, hereby elects to retake and hereafter use her previous
name of KARA L. MACMILLAN and gives this written notice avowing her intention in accordance
with the provisions of the Act of December 16, 1982, P.L. 13 9, No. 2 Section 2, 54 Pa. C.S.A.
Section 704.
(Sign tur arrted name)
Kara L. Bohn
(Sig to o be kn wn as)
Kara L. MacMillan
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
:SS.
On the/~~~ay of ,~`/~~.C , 2010, before a Notary Public, personally appeared
Kara L. MacMillan, 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 WHEREOF, I have hereunto set m~~fiand and Notaria,,~.~e~l.
/ ,r
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Victoria L. Otto, Notary Public
Carlisle Borough, Cumberland County
My commission expires December 20, 2010
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KARA L. BOHN
v.
MATTHEW C. BORN
DIVORCE DECREE
AND NOW, I•l ~~ ~~, ~~U , it is ordered and decreed that
KARA L. BOHN ,plaintiff, and
MATTHEW C. BORN
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.
NO. O9r$402
By ourt,
Attest: .1
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Prothonotary
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