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HomeMy WebLinkAbout10-2745`I rlf:, '? l 2010 AF R 23 P 3-- 21 ? ITY HEATHER M. BURGARD, Plaintiff V. JASON L. BURGARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 10 - ?- Yr CIVIL TERM : IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any, money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION 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, PA 17013 Phone: (717) 249-3166 (800) 990-9108 g 35d. D1) "f/7 Ck 111k "* I p - )-yl d 7 7 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. HEATHER M. BURGARD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JASON L. BURGARD, : NO. 10 - ?-? </r CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Heather M. Burgard, an adult individual, who resides at 11 Robin Drive, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Jason L. Burgard, an adult individual, who resides at 417 Old York Road, Dillsburg, Pennsylvania 17019. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 30, 2008, in Newville, Cumberland County, Pennsylvania. 5. Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: ko Respectfully submitted, Rominger & Associates Karl ominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Heather M. Burgard VERIFICATION 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 unworn falsification to authorities. Date: '? '? `?pl U Heather M. Burgard, Plaintiff ' HEATHER M. BURGARD, Plaintiff v. JASON L. BURGARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 10 - 2745 CIVIL TERM : IN DIVORCE K a J' AFFIDAVIT OF CONSENT 1. A (Complaint in Divorce under Section 33v 1(c) of the Divorce Code '@_s fila C_ on April 23, 2010. Z 1J c? .T7 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. i? nate? CJ l1 /C ? 7V He they . Burgard, Plaintiff HEATHER M. BURGARD, Plaintiff V. JASON L. BURGARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 10 - 2745 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 330t(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. "[7 iTi r t' U( c 'C3 w n +.J t-r1 2. [ understand that t may lose rights concerning alimony. division of property, lawyer's fees or expenses if t 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 tiled 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 unswom falsification to authorities. i Date: Wthere M. Burgard, Plaintiff HEATHER M. BURGARD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JASON L. BURGARD, : NO. 10 - 2745 CIVIL TERM c' Defendant IN DIVORCE r T1 AFFIDAVIT OF CONSENT ?` - T t_, r C7 53; C. La 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code w s fileQl -< on April 23, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. u ?... Jason L. Burgard, Plaintiff HEATHER M. BURGARD, Plaintiff V. JASON L. BURGARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 10 - 2745 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. C <y 10 C? Mr.. Z -' cn : . r' `- c- G...J CD w .J i.J T1 P9 M .7 Tj .? rn _C 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 tiled 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: --% 4 Jason L. Burgard, Plaintiff Heather M. Burgard IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Jason L. Burgard NO. 2745-2010 DIVORCE DECREE AND NOW, (DIS-Woar tl , 16M ., it is ordered and decreed that Heather M. Burgard , plaintiff, and Jason L. Burgard , 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, /3 .,/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Heather M. Burgard Plaintiff VS. Jason L. Burgard Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME 2010 Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the ~~ day of ~ ~ , hereby elects to resume the prior surname ~f Heather M. Myers and gives this written notice pursuant to tl DATE: i j0 COMMONWEALTH OF PENNSYLVANIA . SS. COUNTY OF CUMBERLAND On the _ day of ~ ~ , 2010, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. [n Witness Whereof, [have hereunto set my hand and rcial seal. CpMMONVVEAI.TH OF PENNSYLVANIA ~ Not ry Public Tamrnie L Peters. NolaryPubNc CarifMe Born, Glnrberlartd tauxY My Gaon Ekes Sept 8.2011 tAMrtIK, hnrnylwnlrr M~oalratbn of Notaries FILE NO. 2745 ~~~~Q-~~Fi~~ ~t ~~~ P~o~or~~~~~ zato oc~ ~ ~ ~~t ~~ 2~ rur~e~~~~ ~~u~~r~° ~.~~~~~ ~~ ~ ~~ ~~~