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HomeMy WebLinkAbout10-2740I . r• F11 4 R 2010 APR 23 Ph 2* 16 JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 737-5890 Attorney for Plaintiff BREE BOND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V, :NO. 1o- a1 4b CIvi(-'er-m CHRISTOPHER BOND, CIVIL ACTION -LAW 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. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, 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 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 35 a . oo PO A r7-4 c??' as3a R* ayl oco8 BY: JOANNE HARRISON CLOUGH, ESQUIRE Attorney I.D. No. 36461 3820 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorney for Plaintiff BREE BOND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. CHRISTOPHER BOND, CIVIL ACTION -LAW Defendant IN DIVORCE AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en ]as paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende, el caso purde proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra por la Corte. Una decisi6n puede tambi6n ser emitida en su contra por caulquier otra queja o compensaction reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted. Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 1-800-990-9108 BREE BOND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. CHRISTOPHER BOND, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) 1. Plaintiff is Bree Bond, an adult individual who currently resides at 2465 Bladestone Trail, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Christopher Bond, an adult individual who currently resides at 100 South First Street, Unit F, Lemoyne, PA 17043. 3. 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 June 22, 1996 Charlottesville, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Solders' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. Plaintiff avers that there are three (3) children of this marriage under the age of eighteen years, namely Ava, Bond, age 6, Kailyn Bond, age 4, Tori Bond, age 4. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, Plaintiff respectfully requests this Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, Date: l v? l? JOANNE HARRISON CLOT H, PC n Joanne Harrison Cloug squire Attorney ID No.: 3646 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Plaintiff Bree Bond VERIFICATION I, Bree Bond , 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 herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: 7 i Bree Bond BREE BOND, Plaintiff v. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA?NI c._ NO. 10-2740 7 CIVIL ACTION - LAW IN DIVORCE CHRISTOPHER BOND, Defendant .. y:1 (AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 23, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the 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 the decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of m4age counselors and that I may request the Court to require my spouse and I to participate in couinseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statement's 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 authoriti s. i Date: JI/ B BOND ti BREE BOND, Plaintiff v. CHRISTOPHER BOND, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA -.; NO. 10-2740 'w -- ? CIVIL ACTION - LAW !A ?YI c!7 f ) ' j r.."1 , IN DIVORCE f-w ;E OF INTENTION TO REQUEST ENTRY IVORCE DECREE UNDER c) OF THE DIVORCE CODE 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: BREE BOND BREE BOND, Plaintiff V. CHRISTOPHER BOND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA M i.W.,3 r . Yw NO. 10-2740 CIVIL ACTION - LAW IN DIVORCE e 74 AFFIDAVIT OF CONSENT ` 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 23, 2010. 2. The marriage of plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the 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 the decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. Date: CH PHER BOND BREE BOND, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-2740 CHRISTOPHER BOND, CIVIL ACTION - LAW Defendant IN DIVORCE; 1 J; c_> WAIVER OF NOTICE OF INTENTION TO REQUEST ENT OF DIVORCE DECREE UNDER § 33 lfc) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand thati, I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I db 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 arelmade subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE: 3/070 J/ C ST R BOND ?., „r JOANNE HARRISON CLO GH, PC 7cl '. r wxj - rR J BY: JOANNE HARRISON C OUGH, ESQUIRE = Attorney I.D. No. 36461 _ 3 820 Market Street 117 _ Camp Hill, PA 17011 , Telephone: (717) 737-5890 '0 Attorney for Plaintiff BREE BOND, Plaintiff V. CHRISTOPHER BOND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-2740 CIVIL ACTION -LAW IN DIVORCE P ECIPE TO TRANSMIT RECORD UNDER § 3301 (c) OF THE DIVORCE CODE 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 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: (a) Date of service: May 13, 2010 (b) Manner of service: First Class US mail. Affidavit of Service filed: June 2, 2010 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: (a) By the Plaintiff: signed on March 9, 2011 and filed simultaneously with this document. (b) By the Defendant: signed on March 9, 2011 and filed simultaneously with this document. (c) Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (d) By the Plaintiff. signed on March 9, 2011 and filed simultaneously with this document. (e) By the Defendant: signed on March 9, 2011 and filed simultaneously with this document. 4. Related claims pending: NONE r DATED: Joanne Harrison Clougl Attorney ID No. 36461 3820 Market Street Camp Hill, PA 17011 (717) 737-5890 Attorney for Bree Bond Bree Bond IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW IN DIVORCE Christopher Bond NO. 10-2740 Defendant QUALIFIED DOMESTIC RELATIONS ORDER ("QDRO") 1. The parties hereto were husband and wife, seek this Order in conjunction with a Decree of Divorce dated 1 2-?z 1 I 2. This Order creates and recognizes the existence of an Alternate Payee's right to receive a portion of the Participant's benefits payable under a Section 403(b) plan made available through his employer, subject to Internal Revenue Code section 414(p). The Court enters this QDRO pursuant to its authority under the 23 P.C.S.A. §3502. 3. This QDRO applies to the Lancaster General Hospital 403(b) Plan ("Plan") 4. The Participant's name, mailing address, Social Security number, date of birth and account number are: Bree D. Bond 423 Talon Drive Mountville, PA 17554 Social Security #: See Addendum Date of Birth: See Addendum Oppenheimer Contract #: See Addendum 5. The Alternate Payee's name, mailing address, Social Security number and date of birth are Christopher Bond 87 Morning Glory Lane Manheim, PA 17545 Social Security #: See Addendum Date of Birth: See Addendum The Alternate Payee shall have the duty to notify the Plan Administrator in writing of any changes in this mailing address subsequent to the entry of this Order. 6. The portion of the Participant's plan benefits payable to the Alternate Payee under this QDRO is $25,000.00 of the Participant's total account balance accumulated under the Plan. The Alternate Payee's award shall not be adjusted for earnings, gains or losses. If the Participant's account is less than $25,000.00 at the time of transfer to Alternate Payee's account, then Alternate Payee shall receive the entire account balance. QDRO Page 2 7. This QDRO does not require the Plan to provide any type or form of benefit the Plan does not otherwise provide. 8. This QDRO does not require the Plan to provide increased benefits. 9. This QDRO does not require the Plan to pay any benefits which another order previously determined to be a qualified domestic relations order requires the Plan to pay to another alternate payee. 10. The Plan shall transfer, by lump sum payment, the amount designated in Paragraph 6 of this QDRO as soon as administratively feasible following the date the Plan receives the Order. The funds shall be placed in the Alternate Payee's Oppenheimer IRA Account #0076211067936, by way of tax-free transfer between qualified plans, pursuant to divorce. 11. All payments made pursuant to this order shall be conditioned on the certification by the Alternate Payee and the Participant to the Plan of such information as the Plan may reasonably require from such parties. 12. It is the intention of the parties that this QDRO continue to qualify as a QDRO under Code section 414(p), as it may be amended from time to time, and that the Plan shall reserve the right to reconfirm the qualified status of the order at the time benefits become payable hereunder. 13. In the event that the Plan inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this order, the Participant shall immediately reimburse the Alternate Payee to the extent that she has received such benefit payments and shall forthwith pay such amount so received directly to the Alternate Payee within ten (10) days of receipt. In the event that the Plan inadvertently pays to the Alternate Payee any benefits that are assigned to the Participant pursuant to the terms of this order, the Alternate Payee shall immediately reimburse the Participant to the extent that he has received such benefit payments and shall forthwith pay such amount so received directly to the Participant within ten (10) day of receipt. 14. After payment of the amount required by this QDRO, the Alternate Payee shall have no further claim against the Participant's interest in the Plan. 15. The Alternate Payee assumes sole responsibility for the tax consequences of any distribution of funds to him subsequent to the tax-deferred transfer of $25,000.00 to his IRA. 16. The Alternate Payee's right to the amount assigned to him under this QDRO shall not be affected by the Participant's death (whether before or after benefit payments to the Alternate Payee have commenced). In the event of the Alternate Payee's death prior to the commencement of benefit payments to the Alternate Payee pursuant to this QDRO, the Plan shall pay the remaining benefits under this QDRO as soon as practicable to any beneficiary designated by the Alternate Payee and recorded with the Plan. If no designated beneficiary survives the Alternate Payee, benefits shall be paid to the Alternate Payee's estate. QDRO Page 3 17. The Court shall retain jurisdiction with respect to this Order to the extent required to maintain its qualified status and the original intent of the parties as stipulated herein. EXECUTED this 7 day of 4 r.A- a I/ . CONSENT TO ORDER: Plaintiff/PaAtcipant 15ate BY THE COURT Judge en nt/Alternate Payee ate Attorney or Plaintiff/ Date Attorney for Defendant/ Date Participant Alternate Payee ?oa.nne NcLrr?son CI oogh , ? ? (?(?'?`''?'" (? 'Tl "*' rr P T1 F: C,o f"" 1 J C7 ADDENDUM TO DOMESTIC RELATIONS ORDER For Submission to Plan Administrator Only Due to the Federal Privacy Act, many state courts prohibit the inclusion of personal data in public records to prevent identity theft. Therefore, please forward the following information sheet to Plan Administrator when submitting the court certified copy of the Domestic Relations Order. Do NOT file the Addendum with the court. Participant Information Name: Bree Bond Address: 423 Talon Drive Mountville, PA 17554 SSN: 162-70-9969 Date of Birth: November 19, 1973 Oppenheimer Contract No.: 00762 7620977306 Participant Attorney's Information Name: Joanne Harrison Clough, Esquire Address: 3820 Market Street Camp Hill, PA 17011 Alternate Payee Information Name: Christopher Bond Address: 87 Morning Glory Lane Manheim, PA 17545 SSN: 184-66-6824 Date of Birth: March 13, 1971 Alternate Payee Attorney's Information Name: Thomas Gould, Esquire Address: 2 East Main Street Shiremanstown, PA 17011 Phone Number: (717) 737-5890 Phone Number: (717) 731-1461 The court certified copy of the Domestic Relations Order and this Addendum should be sent to: Oppenheimer Funds Services 12100 East Iliff Avenue, Suite 300 Aurora, CO 80014