Loading...
HomeMy WebLinkAbout01-0624 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWANDA M. BARD, v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant # (1- (,YI CIVIL TERM 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 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, 17013. 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, Pennsylvania 17013 717-249-3166 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA LOWANnA M. BARD, v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant # CIVIL TERM AFFIDAVIT OF MARRIAGE COUNSELING I, Lowanda M. Bard, 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 Prothonotary's 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 unsworn falsification to authorities. Dated: q?D \6 I c1~ /11.~ Lowanda M. Bard, Plaintiff Sworn and subscr~b~qhto befortL me this .c~""''- of aO.'Y\UCI...~ ~4\ .vY\O-\IlOIJ Notary Public day , 20QL. MOTAIllAL IPl bIk CMOl A. /If:1IIICHI, _ 1'u CaIlilIe ...... c...b iond ~ , .......... """" 28. 2003 ""CoAa I c- -.-- _ -- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWANDA M. BARD, v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant # 0/. (.;J.<( CIVIL TERM COMPLAINT IN DIVORCE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW COMES, Lowanda M. Bard, Plaintiff, by her attorney, Ruby D. Weeks, Esquire, who avers as follows: 1. Plaintiff, an adult sui juris, is Lowanda M. Bard, a U. S. citizen, who currently resides at 323 Airport Road, Shippensburg, CUmberland County, Pennsylvania 17257, since February 5, 2000. 2. Defendant, an adult sui juris, is Richard E. Bard, a U. S. citizen, who currently resides at 15 Irvin Drive, Shippensburg, Cumberland County, Pennsylvania 17257, since November 1997. 3. Plaintiff and Defendant have been a bona fide resident(s) 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 June 16, 1990, in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 6. Neither party is a member of the Armed Forces of the United States. 7. The marriage is irretrievably broken. 8. Plaintiff and Defendant have lived separate and apart since February 5, 2000. 9. 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. 10. Plaintiff requests the Court to enter a decree of divorce. COUNT I - IRRETRIEVABLE BREAKDOWN 3301 (c) of the Divorce Code 11. Paragraphs 1 through 10 are hereby incorporated by reference and made a part hereof. 12. The marriage is irretrievably broken. a. Plaintiff and Defendant have lived separate and apart since February 5, 2000. 13. Plaintiff has been advised as to the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 14. Plaintiff requests the Court to enter a decree of divorce. COUNT II - REQUEST FOR DIVISION OF PROPERTY UNDER SECTION 53502 OF THE DIVORCE CODE 15. Paragraphs 1 through 14 are hereby incorporated by reference and made a part hereof. 16. The parties purchased or otherwise obtained during the course of their marriage property which is considered "marital propertyll. 17. Upon entry of a divorce decree, such property should be divided equitably as is just and proper. WHEREFORE, plaintiff prays that a decree in divorce be entered divorcing plaintiff from the bonds of matrimony between the said plaintiff and defendant. a. As to Count I, in the alternative, should Defendant execute an Affidavit consenting to a divorce because the marriage is irretrievably broken, that a decree in divorce be entered divorcing Plaintiff from the bonds of matrimony between the said Plaintiff and Defendant. b. As to Count II, that this Court determine marital property and order an equitable distribution thereof. c Such other additional relief as the Court deems necessary and appropriate. 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. Date: \\~\D \ .~~ ,42. &u4 Lowanda M. Bard, Plaintiff R&~~re A;~~r~~~~~or Plaintiff 10 West High Street Carlisle, PA 17013 (717) 243-1294 _"",.""",,_"',' ,,- -z:~" r. r-, :'1111""11""1""" "'!!"'t\'<I(!!'" . i\ COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND and says that the facts contenned in the foregoing Complaint are CLue and The above named, LO'.tJanda M. Bard, being duly sworn according to J d'N I deposes correct, and the complaint is not D1ade out of tevity or by collusion bet'Neen her and the said Defendant for the mere purpose of being freed and separated tram each other, but that it is broll'-:Tht in sincerity and in truth to~::: che cause mentioned in the said Complaint. I y>'.' / r,;;l ,~J<,hIJ.1 Lowanda M. Bard, 'J /l1 l';;C'k~J , PlaintiU sworn and SUbsc~d to bef~ me this ' day of \'\,1","-\(\ ".0( , 2oLL. C"~-.(\\i\~':>c~ ': Notary Publfc \tJftI,---."__.II". .. , "'''AII''' (::~ II.. ~\OllIl) ILl rl;eoolilll,lJorco.O,. i .~~:..~~.~~! ."......, M I' ,'!iJ:tJ. ',N,").tI1 II , ~1!~<il~HI 'C '.:1-1 II~ lfNr ~ "" .."...... 1- .~ "~~,, I ',i~ ,,, d ~ ..-,.--"...,...--.----"., tfOJr~~ ~I !il;"J. CAlOI I MClfll =,,/, -, I~>',,", Carlile lcl~"'" C ;f!: ~H ;,,:; C IAv (:6",^, ~~'<:r1, E- ~,;"., ;" " ;1 II "" II III! II -I'I '-II" 1_;;" '''II ) "'< OH "'~ ,L'l ..::1><:.: . ~~j ~ ~ ... Ol>l, 15 !-< ... i'" ." 0: ..::I ., o . ~ ~ H :Ii A tJ><H > ." "'~t H H i " Q tJ M 00< 12; ... !-<tJ..::I H ~ ~3H o > .. ..::I tJ t1 f;jgj ;~ ~. ~. ~ ~ LOWANDA M. BARD, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA sv. :CIVIL ACTION - LAW :IN DIVORCE RICHARD E. BARD, Defendant :#01-624 CIVIL TERM AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA R.C.P. 1920.4 (a) (l) (ii) COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND I, RUBY D. WEEKS, ESQUIRE, Attorney for Lowanda M. Bard, being duly sworn according to law, depose and say that a true and correct copy of the Divorce Complaint was served on the Defendant, Richard E. Bard, at 15 Irvine Drive, Shipp ens burg , PA 17256, by mailing the same to him by certified mail, restricted delivery, postage prepaid, No. 7099 3400 0018 5048 7687, on January 31, 2001. Service was accepted on February 2, 2001. RUbY~~ Sworn and subscribed to before me this ~l day of .lfl V.\JJJ.LLr 20QL. ~~~!j) 10J\Jl CL< j U NOTAlIlAl.SfAl-=-- CARol A. ~. NoIa.y PlIllIic .... C<ri,J". " ....... e..",~..h.,,,, Cownty .. ~ ~~~L::~ June 28. 1003 =='':''''''~",.....--,.c.'"''''c",.,_"'..,..,..,,d .. '" ::s- o U'l Postage $ $0.55 U. Certified Fee Return RoceiptFae $1.50 tCJ (Endorsement ReqLJlred) 8 Re~trjcled Delivary,Fee $3.20 C (Et1.dorsement ReqUired) C Total Postage & Fees $.7.15 -------.----J ~ 'f'ont' N.me (P'J5:~~7:)M~"db~~"'e1~'..= .,-si IlJ?Ji1J~~,x No 'l)r; u,.:f...._________ IT" i:2.I.I<-J,)LOC_.___. \.-1 "")c c ti, -"r"a~e:z(p~ - , Cf,..V l"- CARLISLE MPO CARLISLE. PennsylvanIa \10132935 01131/2001 (7\1>243-3531 11:15:48 AM <'-- -" .., l"- Product Description Sales Receipt Sale Unit Oty Price Final Price SHIPPENSBURG PA 17257 First-Class 'estricted Del J very eturn Receipt ertit i ed Label Senal #: $i $: $ $: 7099340000185048' Issue PVI: $~ al: :J by: ) 1ge Due: = $', $lC -$, ~J 11#: Clerk: 1000400114749 09 ~- Thank you for yOU[- nus i ness - + ""l,".JllZlalf.lItIOl"..- · Complete items 1, 2, and 3. Also compiete item 4 if Restricted Delivery is desired. · AWlt your name and address on the reverse Ie) tnat we can return the card to you. · _h this card to the back of the mailpiece. or on the front if-space permits, 1. Micte Addressed to: ~ic.,hRKD E ~#-,e-b 15 ~u)tJe Ue.iue... 6h; ~s..J.vG) 911 i#f:l D ligen! Dlldd_ Dves DNo 2. 7)q9ber(Co~trcY\ico~1 ~ ~'i ~I "S Fon-n 3611. July 1999 ~ Return Receipt 3. ~ice Type Certified Mall 0 EX/J~ Mai! Aeglst&reO 0 Return Rooelpt for MerctWdM a rnsured Mail D C.O.D. 4. Restricted Delivery? (EXtra Fee) Yes l02595-00-M-0952 c\ 5 -,..: -.'1 O.J' ~ 'V ::5 -< C'I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a v.m. NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated approximately February 4, 2000, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted. 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. Dated: 1j..-IY~o3 Riif:ar~~ant C) C. ..-.0 c=' ~~ r'~ ';1 :? -n 1'11P .-_rel :~1Y (;~l; '- ::: _.\ en c.:.:." . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . .. . . :+;;+;,.,;t; :t:;t;:t: :+;:f.,ldf.:l' ;+; Of. ;Ii:+; .. . .. . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Lowanda M. Bard No. 01-624 VERSUS Richard E. Bard DECREE IN DIVORCE AND NOW, , 2004 , IT IS ORDERED AND DECREED THAT Lowanda M. Bard , PLAINTIFF, AND Richard E. Bard , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; By THE COURT: ATTEST: PROTHONOTARY . 'f :f;t; :l' !'Ii .. . . . 'f.'f;t;;t;:+::+: ". . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a v.m. AFFIDAVIT OF NON-MILITARY SERVICE PURSUANT TO PA.R.C.P.1920.46 Defendant, Richard E. Bard, being duly sworn according to law, deposes and says that he is the Defendant in the above-captioned matter; that he personally knows the Plaintiff, Lowanda M. Bard, is over the age of eighteen years; and that the Plaintiff is not in the military service or in any branch ofthe armed forces of the United States or its allies or otherwise within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress of 1940 and the amendments. 4;;;;!dd Richard E. Bard, Defendant Sworn to and subscribed before me this ~ day of r- f InnJa n 1 ' 2004. ~f" Cl ?"dukl'J NOTARIAL SEAL . I PAMELA A SWITALSKI. Notary Public !hlppensburg, Cumberland County My CommjSSiOn_~xpir~S Feb~~~004 .,.... --c;-:-c r-il, o ~~; " ~, ~:.... -"j --- ....~ ~ "" r-rl c.:,) r, ":'1'1 .--1 :1:~ f"llr iTl ~.'I -1~) (, ,'j --, -:... r:-? <::) -.l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a v.m. AFFIDAVIT OF SERVICE STATE OF PENNSYLVANIA COUNTY OF FRANKLIN Personally appeared before me, a Notary Public, in and for said State and County, Jeffrey S. Evans, Esquire, who, being duly sworn according to law, deposes and says that he did serve Defendant's Affidavit, Affidavit of Non-Military Service, and Notice of Intention to Request the Entry of Divorce Decree in the above-captioned matter on the Plaintiff, Lowanda M. Bard, by mailing a true and attested copy of the same to her attorney of record, Ruby D. Weeks, Esquire, at her mailing address of 10 West High Street, Carlisle, Pennsylvania 17013, by regular, first class mail on January 16, 2004 at the post office in Waynesboro, Pennsylvania. / BY{ J effre Atto Sworn to and subscribed to before me this ~ day of T..eDu.ClUj Not6u~ltO ~ ~. ~~ ,2004. NOTARIAL SEAL Kelly V. High, Notary Public Washington TownshIp. Franklin County My Commission Expires Nov. 29, 2004 ,- ,~_. c -! c~ I ,- ,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Lowanda M. Bard, Civil Action - Law Plaintiff #01-624 Richard E. Bard, Defendant In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD Transmit the record together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301( d)(1) ofthe Divorce Code. 2. Date and manner of service ofthe Complaint: Service ofthe Complaint in divorce was made on the Defendant, Richard E. Bard, by mailing the same, certified mail, return receipt requested, deli ver to addressee only, a tme and attested copy of the Complaint for Divorce to the Defendant on January 31, 2001, as evidenced by the Affidavit of Service filed in this cause. The Divorce Complaint was dated January 30,2001. 3. Date of execution of Defendant's Affidavit required by Section 3301( d) of the Divorce Code: Defendant's Affidavit was executed on December 18, 2003. Date of service of Defendant's Affidavit upon the Plaintiff: Service of the Defendant's Affidavit required by Section 3301(d) of the Divorce Code together with Notice to Plaintiff was made on the Plaintiff, Lowanda M. Bard, by mailing a true and attested copy of said documents to the Defendant's attorney of record, Ruby D. Weeks, Esquire on January 16, 2004, as evidenced by the Affidavit of Service filed in this cause. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d)(1)(i) of the Divorce Code: Notice of Intention to Request Entry of Divorce Decree was served on the Defendant's attorney ofrecord, Ruby D. Weeks, Esquire, by mailing the same to her, on January 16, 2004 as evidenced by the Affidavit of Service filed in this case. Respectfully submitted, Dated:~b!~ ~ endant r..) :.-t c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lowanda M. Bard, Plaintiff Richard E. Bard, Defendant Civil Action - Law #01-624 In Divorce a v.m. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Lowanda M. Bard, Plaintiff RubyD. Weeks, Esquire I 0 West High Street Carlisle, PA 17013 Richard E. Bard, the Defendant, by his attorney Jeffrey S. Evans, Esquire, intends to file with the court the Praecipe to Transmit Record on or after February 20, 2004 requesting that a final decree in divorce be entered. Respectfully submitted, /' , B~ Jeffrey, Atto . efendant 2081 East Main Street Waynesboro, PA 17268 r' ,.~ " , < " -. .., L) C:.., LOWANDA M. BARD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY, PENNSYLVANIA V. RICHARD E. BARD NO. 2001-0624 CIVIL ORDER OF COURT AND NOW, this 4TH day of MARCH, 2004, it appears to the Court that Plaintiff's complaint requests inter alia, the equitable division of marital property. We are not prepared to enter a final decree in divorce until Plaintiff's counsel withdraws that claim or the matter is bifurcated after petition and hearing. ce Court, I Edward E. Guido, J. Auby D. Weeks, Esquire 10 West High Street Carlisle, Pa. 17013 .> /Jeffrey S. Evans, Esquire 2081 East Main Street Waynesboro, Pa. 17268 :sld D3-0Y-O'l \/;!'),\//\ 1, J..s~ ,if J?!d ,^lHr;C-r'_~: ('!..r,n:.~-::':i/.tIJ II : II ~IV 11- (,Ji'W ~OOZ -'1(",. ',''''' I'O"J <II' -1(" /.I.,'~-,f':\...!tU~ J :Jill _, ) JJ!:J~o-O:Jl!:1 LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 3D, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer I s fees or expenses if I do not claim them before a divorce is granted. 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. Dated: /U' 31-0::-' rI~ ;tr ~ LOWANDA M. BARD, Plaintiff Sworn and SUbS~~ to beforeu.2ts day 5' of Or. , 20~ . ,~-;(/~ Notary Public COMMONWEALTH OF PENNSYLVANIA NotariaJ SeeI Wanda K Hunter, NctaIy PublIc CadI8le Boro, Coolbedand County MyConvnioolon Expkes May 10, 200S Member, Pennsylvania A.800latlon of Notan.. " , LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S 3301 ec) 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 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: /0,,31- 0--:; c(~/vtB~ LOWANDA M. BARD, Plaintiff " < RECEIVED SEP 1 6 2005 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWANDA M. BARD, v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #Ol-624 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 30, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 4. I understand that I may lose rights concerning alimony I division of property, lawyer I s fees or expenses if I do not claim them before a divorce is granted. 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. Dated: '1', y- 00 ~,/ lV RICHARD E. BARD, Defendant Sworn and subscr~~d to before me this ~'day of -Sof\e<<\'Q.a~ 20dS ~~c\j. ~~ NOTAAlALSEAl V' k8lIy V. High. Notaty PublIc .W,I,'lIl1.n Township. FIaIIIcHn County My CommissIon Ellp/Ne Nov.l!9. 2008 ~.. , ',I ; ~;"". ..,".' RECEIVED SEP 1 G 2005 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWANDA M. BARD, v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER ~ 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 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: t'/- $-0 '; #~ Iii RICHARD E. D, efendant __c, __I (.) C': Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWANDA M. BARD, v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM PRAECIPE TO WITHDRAW COUNTS IN DIVORCE TO THE OFFICE OF THE PROTHONOTARY: Please withdraw the previous requests for Count I and Count II to be withdrawn, in the above captioned divorce action since these matters have been satisfactorily resolved between the parties. / " 'II ..~ J,y~ Ch) L,ciu~ Ruby D. W~~kSI ~squire Attorney for Plaintiff Dated: il' (- 0 ~ cc: Jeffrey S. Evans, Esquire C) ,..., ~ = c = -~ en - ~ ;:;;ili] ::z: ~~~. <:::> ,.,,:n -< r I -om ;116 \"-) ~C" "'" :2:fi ).0,.... ~2(-) ;::~j :x .P'c - iSm - ~ .. u.-t C) ~ Ul :..:; LOWANDA M. BARD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTy, PENNSYLVANIA v. CIVIL ACTION - LAW IN DIVORCE RICHARD E. BARD, Defendant #01-624 CIVIL TERM PRAECIPE TO TRANSMIT RECORD 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 Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: January 31. 2001. bv certified mail, restricted delivery. 3. Date of execution of the affidavit of consent required by Section 3301 (cl of the Divorce Code, by the plaintiff on October 31. 2005; by the defendant on September 8. 2005. 4. Related claims pending: NONE 5. Date plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: October 31, 2005. Date defendant's Waiver of Notice in 9 3301(c) Divorce was filed with the prothonotary: October 31, 2005. Date: November 1, 2005 \'. ", <:;' ...., ( .',-- "J, .l.-',jC, _.....~ , /' L--,-f (j - ", ..;,~ ,_r " ^-W' L~\f-7 RUBY D. WEEKS, Attorney for the Plaintiff C) ,..., (- = 0 = ~, ", .. ::;::: .-J 0 :J_ :::n .q;::;: fl1p- I 15m !'oJ ';)~ --0 ~:tJ ~ ;.:rC'" ~ ~'.5fT1 ~ j::! :n Cf' .< + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + :++ + :+ Of :+ :+ ++ + + +++ ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++~ + + + + + + + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF LOW ANDA M. BARD, PLAINTIFF VERSUS RICHARD E. BARD, DEFENDANT PENNA. #01-624 CIVIL TERM No. DECREE IN DIVORCE tJ~ 8" )-oo)'c?l<l:o("p. WViANDA M. l'>AlUI I AND NOW, 1"1 , ]T ]S ORDERED AND B *rU:J DECREED THAT LowANbA. ~. AND . PLA] NT] FF, RICHARD E. BARD , DEFENDANT. ARE D]VORCED FROM THE BONDS OF MATR]MONY. THE COURT RETA]NS JUR]SD]CT]ON OF THE FOLLOW]NG CLA]MS WHICH HAVE YET BEEN ENTERED; BEEN RA]SED OF RECORD ]N THIS ACT]ON FOR WHICH A FINAL ORDER HAS NOT NONE //-j BC~~ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +'+'+++++++:+++:+++ ATTEST: ~~ ( 'PROTHONOTARY + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + J. ~:; fr" ~ ~ ~J;f, YJ pi . J! rr(1 ~ p.~ -kW.pO .9J' h/'j/ ... .. .