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HomeMy WebLinkAbout10-3464T' „ 20 Ii 0 1-;".Y 25 IF i'I I : L J TERI RENEE TROY, IN THE COURT Ol VCOMAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. t, Z q 2?- vs. Civil Action - Law MICHAEL RAE BOWER, 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 foregoing 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 also 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania, 17013 SCHRACK & LINSENRACH LAW OFFIC 17S IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 e k? 4 ?? 3 ?? ?4 2.s. 118 TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. MICHAEL RAE BOWER, . No. Civil Action - Law Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. SCHRACK & LINSENBACH I.AW OFFICES TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE -§3301(c) or (d) COMPLAINT UNDER § 3301(C) OR (D) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, TERI RENEE TROY, by and through her attorney, Brian C. Linsenbach, and files the within Complaint in Divorce and represents as follows: 1. Plaintiff is TERI RENEE TROY, who currently resides at 9 Camelot Lane, Newville, Pennsylvania 17241. 2. Defendant is MICHAEL RAE BOWER, who currently resides at 654 Mahonoy Valley Road, Duncannon, Pennsylvania 17020. 3. Plaintiff and Defendant are both bona fide residents of the Commonwealth of Pennsylvania, Cumberland County, for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on July 14, 1996, in Newport, Pennsylvania. 5. There are two children born of this marriage, namely: Logan Michael Bower, son, born on July 10, 1993; and SCHRACK & LiNsENsAcH LAW OFFICES Asher Quinn Bower, son, born on December 8, 2002. 6. Neither Plaintiff nor 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. 7. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. 10. The causes of action and sections of the Domestic Relations Code under which Plaintiff is proceeding are: a. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. b. Section 3301(d). The marriage of the parties is irretrievably broken. The parties are living separate and apart and, at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce, SCRRACK_& LINSENRACH LAW OFFICES divorcing Plaintiff and Defendant. Respectfully Submitted, Brian C. L' ach, Esquire (87360) Attorney for Plaintiff Schrack & Linsenbach Law Offices 124 W. Harrisburg Street P.O. Box 310 Dillsburg, PA 17019 Telephone: (717) 432-9733 Fax: (717) 432-1053 TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE -§3301(c) or (d) VERIFICATION I verify that the statements made in the foregoing 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. zTERI Pl ntiff Date: 4 -'al- it:) SCHRACK LiNsENBAm LAW OFFICES #,F 'Y C' it-?.t?" '??12 tiAR I S A? it - 38 ?U4?B NNS ,VAN ATY PE TERI RENEE TROY, Plaintiff VS. MICHAEL RAE BOWER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . No. 10-3464 Civil Term Civil Action - Law IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Pursuant to Pa. R.C.P. 401(b)(1), please reinstate the Divorce Complaint in the above- captioned matter. We have attached the original attempt at service, which was returned unclaimed. Date: °? / ?-- - Brian C. Linsenbach, Esquire (#87360) STONE, DUNCAN & LINSENBACH, PC Attorney for Plaintiff 8 N. Baltimore Street Dillsburg, PA 17019 Telephone: (717)432-2089 Fax: (717)432-0158 Q?{ $ l1. 75?n' ct Ck? as7q HARRISBURG STREET 0mcF- BOX 310 ,6, PA71709-031(3"` r???C ja 1 ! ¦ Gompi+ itgrns 1, 2, and 3. Also complete i item d if fte>rlcted Delhrery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. r ¦ Attach this card to the back of the maiipiece, or on the front if space permits. A X ? Agent O Addressee B. Received by ( Printed Name) C. Date of Wiva'y 1 Artiole Addressed to: D. Is delivery addmes We?ent from item 1? 13 Yes . If YES, enter delivery address below: 0 No Michael Bower 654 Mahanoy Valley Road Duncannon, PA 17020 3. Service Type W?Osl8 Mail 0 E*ess Mall ? Regle wW )W Return Receipt for Metchaxibe 0 homw man ? C.O.D. 4. Restricted Delivery? (ExUS Fee) 0 Yes 2. Article Number 7007 0220 0003 3292 3071 (r os . 1 DC r- !2ft1 1 Gn1v..ar.i 7AAA n•,.:,e•.u.. n-a...•, o_?_?? 7007 o==o 0003 329E'--3071 I MICHAEL R. BOWER 654 MAHAWOY VALLEY ROAD DuNreNNON. PA 17020 NIXIE 178 DE 1. DO 08/1.0110 RETURN TO SENDER UNCLAIMED UNABLE TO FORWARD SC: 170190310101++ 1*0419-00t7`79-01-4.7 -r•••••:••?"_`} s..:'?"' { ``{ f I)I!1lfill)If111111111111111lI}?'1!!I'lI1?? 11 .. ?s-•'?'"'a'•? f ?1 ?0?•? li1)ilitlTl"Itlt 1 AOTAJ? ` (-1,Je41OFRLAND COUNT"! F?t?NSYLVANIR TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE CERTIFICATE OF NOTICE I, BRIAN C. LINSENBACH, ESQUIRE, of the law offices of STONE, DUNCAN & LINSENBACH, P.C., certify that I have served a Divorce Complaint and Praecipe to Reinstate Complaint by Process Server, Brenda I. Ferrell, on April 6, 2012, at 1:55 p.m. Service was completed on April 6, 2012, a copy of the Affidavit of Process Server is attached. I verify that the statements made in this Certificate of Service 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. S r? Z ate BRIAN C. LINSENBACH, ESQ. (87360) STONE, DUNCAN & LINSENBACH, P.C. 8 N. Baltimore Street Dillsburg, PA 17019 (717) 432-2089 Office (717) 432-0158 Fax AFFIDAVIT OF PROCESS SERVER I declare that I am a citizen of the United States, over the age of eighteen and not a party to this action. And that within the bounds of the state where service was effected, I was authorized by law to erf)!Wan____ said service. SERVICE: I served NAME OF PE ,ON / ENTITY BEING SERVED with the (documents) t" I e i r I 2. ?D Ivtpla Un-? by servin o rr VG at HOME S n nC?v?v?oe1 l?D BUSINF-19 ON 141, OF SERVICE: AT_? SS p. w? . PERSONALLY DELIVERING COPIES TO THE PERSON/AGENT B G SERVED. BY LEAVING COPIES AT THE DWELLING, HOUSE OR USUAL P ACE OF ABODE OF THE PERSON BEING SERVED, WITH A MEMBER OF E HOUSEHOLD, EIGHTEEN OR OLDER AND EXPLAINING THE NATURE OF THE PAPERS. DESCRIPTION: AGE3-5 SEX RACE HAIR 2 U, WGT ?? - GLASSES - OTHER- Lo ! NON- SERVICE: AFTER DUE SEARCH, CAREFUL INQUIRY AND DILIGENT ATTEMPTS AT THE ADDRESSES, I HAVE BEEN UNABLE TO EFFECT SERVICE OF PROCESS UPON THE PERSON / ENTITY BEING SERVED FOR THE FOLLOWING REASONS: THIS PERSON IIS) OR (IS NOTI IN THE IL MARY HEREIN IS TRUE AND CORRECT, DATE: y1 T S SIGNATURE OF PROCESS SUBSCRIBED AND SWORN BEFORE ME -r 4NAQRZP?UBLIC COMMONWEALTH =L-AVEdue, ENL?ANIA EAT' Public rnbct 1 TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term Q 7 -03t VS. Civil Action - Law; ?a rn-? x? -•c ?rn MICHAEL RAE BOWER, CD r-- :z -- z Defendant : IN DIVORCE -= NOTICE f If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within twenty (20) days after this Affidavit has been served on you, or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on August 17, 2006, 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 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 unworn falsification to authorities. Date: TERI E TROY, Pla' tiff r k«+ ,-?!?IBERLJJ@ COUNTY PENNSYLVANIA TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, BRIAN C. LINSENBACH, ESQUIRE, of the law offices of STONE, DUNCAN & LINSENBACH, P.C., certify that I have served a Divorce Complaint and Praecipe to Reinstate Complaint by Process Server, Brenda I. Ferrell, on April 6, 2012, at 1:55 p.m. Service was completed on April 6, 2012, a copy of the Affidavit of Process Server is attached. I verify that the statements made in this Certificate of Service 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. ate BRIAN C. L NBACH, ESQ. (87360) STONE, DUNCAN & LINSENBACH, P.C. 8 N. Baltimore Street Dillsburg, PA 17019 (717) 432-2089 Office (717) 432-0158 Fax AFFIDAVIT OF PROCESS SERVER OF SERVICE: AT (SS p. w? PERSONALLY DELIVERING COPIES TO THE PERSON/AGENT B G SERVED. BY LEAVING COPIES AT THE DWELLING, HOUSE OR USUAL P ACE OF ABODE OF THE PERSON BEING SERVED, WITH A MEMBER OF HOUSEHOLD, EIGHTEEN OR OLDER AND EXPLAINING THE NATURE OF THE PAPERS. DESCRIPTION: AGE SEX-RACE HAIR w WGT-- S GLASSES?_ OTHER_ ?o NON- SERVICE: AFTER DUE SEARCH, CAREFUL INQUIRY AND DILIGENT ATTEMPTS AT THE ADDRESSES, EFFECT SERVICE OF PROCESS UPON THE PERSON E ENBEEN TITY BEING TO SERVED FOR THE FOLLOWING REASONS: PE . ON (ISl OR (IS NOT) IN TRW Mn- LT A RY i 111? " A nV YTXTv,r. r. ....? ???' HEREIN IS TR rF AND nu FCT DATE: , 5- SIGNATURE OF SUBSCRIBED AND SWORN BEFORE ME PROCES* N ARY PUBLIC COWAoNWEALTfi of PENNSYLVANIA ublic c?y Al 1 13 E17 NAME OF PFAeniv i vxTTT.r., r.-- with the (docum I declare that I am a citizen of the United States, over the age of eighteen and not a party to this action. And that within the bounds of the state where service was effected, I was authorized by law to erfo said service. SERVICE: I served 'd ONO IL 2012MAtY 17 P 3: L- E_' CIJIlBERLANID CCUII s 'RK115YLV ,'!NIP'\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 10-3464 Civil Term Civil Action - Law IN DIVORCE CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true and correct copy of the foregoing Affidavit under Section 3301(d) of the Divorce Code was served by first-class mail to the following: Michael Rae Bower 654 Mahanoy Valley Road Duncannon, PA 17020 Date BRIAN C. LINSE BACH, ESQ. (87360) STONE, DUNCAN & LINSENBACH, P.C. 8 N. Baltimore Street Dillsburg, PA 17019 (717) 432-2089 Office (717) 432-0158 Fax TERI RENEE TROY, Plaintiff VS. MICHAEL RAE BOWER, Defendant ti TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, `uz Defendant IN DIVORCE . rte. 7?r= NOTICE If you wish to deny any of the statements set forth in this Affidavit, ?trius file ` Counter-Affidavit within twenty (20) days after this Affidavit has been served oja?yo?t- or=1 statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on August 17, 2006, 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 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 unworn falsification to authorities. Date:, y:, TERI E TROY, Pla' tiff TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE Yom.,': ? G % r, ""1 e NOTICE OF INTENTION TO REQUEST ENTRY OF .,y ?a - SECTION 3301(d) DIVORCE DECREE ? O TO: Michael Rae Bower 654 Mahanoy Valley Road ^ ' - Duncannon, PA 17020 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the §3301(d) Affidavit. Therefore, on or about June 6, 2012, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Telephone: (717) 249-3166 Date: , / W?"01 Z _ Respectfully submitted, Brian C. Linsenbach, Esquire (#87360) STONE, DUNCAN & LINSENBACH, PC Attorney for Plaintiff 8 N. Baltimore Street Dillsburg, PA 17019 Telephone: (717)432-2089 Fax: (717)432-0158 TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law -=' MICHAEL RAE BOWER, - m r o ?y <:....'.. Defendant IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301( ° r a OF THE DIVORCE CODE w" c? 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check: (i), (ii) or both): (i) The parties of this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-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: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this Counter-Affidavit. a 2 9 F, TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true and correct copy of the foregoing Notice of Intention to Request Entry of Divorce Decree and Counter-Affidavit was served by first-class mail to the following: Michael Rae Bower 654 Mahanoy Valley Road Duncannon, PA 17020 Da BRIAN C. LI SENBACH, ESQ. (87360) STONE, DUNCAN & LINSENBACH, P.C. 8 N. Baltimore Street Dillsburg, PA 17019 (717) 432-2089 Office (717) 432-0158 Fax TERI RENEE TROY, Plaintiff VS. MICHAEL RAE BOWER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 10-3464 Civil Term Civil Action - Law _s IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: Michael Rae Bower 654 Mahanoy Valley Road Duncannon, PA 17020 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the §3301(d) Affidavit. Therefore, on or about June 6, 2012, the other parry can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Telephone: (717) 249-3166 Respectfully submitted, Date: ill Z o I L f..?- ?? Brian C. Linsenbach, Esquire (#87360) STONE, DUNCAN & LINSENBACH, PC Attorney for Plaintiff 8 N. Baltimore Street Dillsburg, PA 17019 Telephone: (717)432-2089 Fax: (717)432-0158 M TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . No. 10-3464 Civil Term VS. . Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(dZ OF THE DIVORCE CODE I. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check: (i), (ii) or both): (i) The parties of this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-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 unworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this Counter-Affidavit. i,011'111 01N, CCUINF' 11 S 1 L VA N1 A TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, , Defendant IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: April 6, 2012, by Process Server. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: May 8, 2012. Date of filing of the Section 3301(d) Affidavit with the Prothonotary: May 11, 2012. Date of service of the Section 3301(d) Affidavit upon the Defendant: May 15, 2012. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of Section 3301(d), along with Defendant's Counter-Affidavit under Section 3301(d), a copy of which is attached: May 17, 2012, by first-class mail Brian C. Linsenbach, Esquire Attorney for Plaintiff Stone, Duncan & Linsenbach, PC 8 N. Baltimore Street Dillsburg, PA 17019 (717)432-2089 Fax: (717)432-0158 FILED-OFFICE OF THE PROTHONOTAR'yi' 2012 JUL -3 AM 11: 10 CUMBERLAND COUNTY PENNSYLVANIA TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant . IN DIVORCE CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date, a true and correct copy of the Plaintiff's Affidavit under Section 3301(d), the Defendant's Counter-Affidavit under Section 3301(d), and the Notice of Intention to Request Entry of Section 3301(d) Divorce Decree was served by first-class mail to the following: Michael Rae Bower 654 Mahanoy Valley Road Duncannon, PA 17020 z r2- Da a BRIAN C. LINSENBACH, ESQ. (87360) STONE, DUNCAN & LINSENBACH, P.C. 8 N. Baltimore Street Dillsburg, PA 17019 (717) 432-2089 Office (717) 432-0158 Fax TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . No. 10-3464 Civil Term VS. . Civil Action - Law MICHAEL RAE BOWER. Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, yi?::nust` Counter-Affidavit within twenty (20) days after this Affidavit has been served oaf; yo 3' or =tie' statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on August 17, 2006, 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 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 unworn falsification to authorities. -4 Date: ----z - . t? TERI E TROY, Pla' tiff TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . No. 10-3464 Civil Term VS. . Civil Action - Law MICHAEL RAE BOWER, Defendant . IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check: (i), (ii) or both): (i) The parties of this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this Counter-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 unworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this Counter-Affidavit. TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: Michael Rae Bower 654 Mahanoy Valley Road Duncannon, PA 17020 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the §3301(d) Affidavit. Therefore, on or about July 22, 2012, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 Telephone: (717) 249-3166 Date: Respectfully submitted, Brian C. Linsenbach, Esquire (#87360) STONE, DUNCAN & LINSENBACH, PC Attorney for Plaintiff 8 N. Baltimore Street Dillsburg, PA 17019 Telephone: (717)432-2089 Fax: (717)432-0158 ILED-OFFICE 1' FhOTHONOTARY 2012 JUL 24 AM 11: 48 CUMBERLAND COUNTY PENNSYLVANIA TERI RENEE TROY, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff , No. 10-3464 Civil Term VS. , Civil Action - Law MICHAEL RAE BOWER, Defendant : IN DIVORCE AMENDED PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a di decree: 1. Grounds for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: April 6, 2012, by Process Server. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: Date of filing of the Section 3301(d) Affidavit with the Prothonotary: Date and manner of service of the Section 3301(d) Affidavit upon the Defendant: 2012, by first-class mail. 4. Related claims pending: No economic claims raised. 5. Date and manner of service of the Defendant's Counter-Affidavit under Section 3301( a Notice of Intention to Request Entry of Section 3301(d) Divorce Decree, a copy of which is aw July 2, 2012, by first-class mail. Brian C. Linsenbach, Esquire Attorney for Plaintiff Stone, Duncan & Linsenbach, PC 8 N. Baltimore Street Dillsburg, PA 17019 (717)432-2089 Fax: (717)432-0158 2. IZ2.1j L TERI RENEE TROY, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10-3464 Civil Term VS. Civil Action - Law MICHAEL RAE BOWER, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE TO: Michael Rae Bower 654 Mahanoy Valley Road Duncannon, PA 17020 You have been sued in an action for divorce. You have failed to answer the Complaint file a Counter-Affidavit to the §3301(d) Affidavit. Therefore, on or about July 22, 2012, other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your notarized or verified or a counter-affidavit by the above date, the court can enter a final decree divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Date:- j L'2 r l -_T- Respectfully submitted, Brian C. Linsenbach, Esquire (#87360) STONE, DUNCAN & LINSENBACH, PC Attorney for Plaintiff 8 N. Baltimore Street Dillsburg, PA 17019 Telephone: (717)432-2089 Fax: (717)432-0158 IN THE COURT OF COMMON PLEAS F CUMBERLAND COUNTY, PENNSYLVA IA TERI RENEE TROY V. MICHAEL RAE BOWER NO. 10-3464 DIVORCE DECREE AND NOW, / , -, it is ordered and decreed TERI RENE TROY , plaintiff, and MICHAEL RAE BOWER , 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 n claims remain indicate "None.") NONE By the Court, Attest: J. P othonotary ?3• l2 • red ar) wo,4&c l /V / ?rY?s act f j Ce cc??r „ail t'd dF' li'`-