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HomeMy WebLinkAbout10-4607STEPHANIE BORING : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLY-?A N _ V. : NO. 10 - 4W7 CtV`t(?erM z JOSEPH F. BORING : CIVIL ACTION - LAW G Y 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 maybe 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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, PA 17013 1-800-990-9108 717-249-3166 hn F. King, Esquire •oo P a Any e? 19d(o p# air, y JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 4076 Market Street Camp Hill, PA 17011 Tel.: (717) 695-2222/Fax: (717) 695-2207 STEPHANIE BORING Plaintiff V. JOSEPH F. BORING Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Stephanie Boring, who currently resides at 122 N. Pitt Street Carlisle, PA 17013. 2. Defendant is Joseph F. Boring, who currently resides at303 W Bridge Street Westover, PA 16692. 3. The parties 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 November 5, 2005, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The parties separated on January 14, 2010. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Date: -01jit I JOHN F. KING LAW, P.C. ? 1-1? & -7 ?I' ohn F. King, Esquire 4076 Market Street Camp Hill, PA 17011 (717) 695-2222 VERIFICATION I, Stephanie Boring, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Step anie Boring \IJ Dated: July (.0 , 2010 STEPHANIE BORING : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 10-4607 : ~ -°n JOSEPH F. BORING :CIVIL ACTION -LAW `~=~ ~ -+ Defendant : IN DIVORCE ~~-' ~ ° ~ ~ .~ ~ --~ -~ r'" ~~ ~ ~~ PRAECIPE TO TRANSMIT RECORD ~ ° ~ ~ o ~ ~ ~~ ~ ~ ~ ~r'' To the Prothonot ~ -< or, ~ Transmit the record, together with the following information, to the court for entry of a divorce decree: Grounds for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: certified restricted mail on July 16, 2010. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff 10/18/2010; by Defendant 10/18/2010. 4. Related claims pending: There are no related claims pending. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date Plaintiff s Waiver of Notice was filed with the Prothonotary: 10/25/10 Date Defendant's Waiver of Notice was filed with the Prothonotary: 10/25/10 J hn F. King, Esquire Attorney for Plaintiff STEPHANIE BORING : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 10-4607 JOSEPH F. BORING :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS: COUNTY CUMBERLAND Personally appeared before me, a Notary Public, in and for said Commonwealth and County, John F. King, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Joseph Boring, by Certified Mail, Restricted Delivery, on July 16, 2010, as evidenced by the attached ail car King, Sworn and subscribed to before me this day of ~~ , 2010. -~ Notary Public ~ e ~ ~~ r- q rnr -r~r~ N~Iry ~Ne c c~ _° ~ ~ iNLI 801l~i10l1. C{M~MO Z0/4 MI !b M E a o . t~ N . My Corti D ~ ~ o ---f c,s 24 -f U7 ~7 -< STEPHANIE BORING Plaintiff v. JOSEPH F. BORING Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4607 ~-, , C ~ ,~ c CIVIL ACTION -LAW ~n°4., o ~ IN DIVORCE ~ ~ - -' -~ ~' a I. .,. n c A° ~ ~ 0 ~ A~ .~.. --~i ~ -<' c.n CERTIFICATE OF SERVICE I hereby certify that I am this ~ day of July, 2010, serving the foregoing divorce complaint upon the person and in the manner indicated below which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Service by First Class Mail restricted certified mail addressed as follows- Joseph Boring 303 W. Bridge Street Westover, PA 16692 S Semans _o ru .. a Postage $ V7 t7 Certified Fee 0 O Return Receipt Fee (Er~orsement Required) ~ Restricted Delivery Fee ~ (Endorsement Required) o Total Postage & Fees $ ..0 O ntTo O or PO Box No. ~,~i ^ Compierte ttbrs~s 1, 2, and 9. Also oompie~e ibam 4 If RestdCted DeNverY is desired. ^ Prfnt your Warne and address on the reverse ~ that we can return the card to you. ^ Attach this Card'tc'~;the back of the rrtailpiece, or ~ the frprft ~ space perrrtits• 1. Article Aed to: ~s ~r"~ ~~ t~~5z 2. Article Number PS Form 3811, February 2004 a slgneAt.e X c~ 'T't --+ ~~ ~,.' ~~ c~ --r ' ~° z°~~*,~ Q~ --t>r`~' D ~o r'1 A~J~ B. Retx~~ivetii~ ( ~ea A-ar--e) C. Date of DelMery ,Tnsr~ti t~/~ ` 7 ~~ ra D. b deNvery address dMerertt t>fom Item 1? ^ Yes M YES, erKer delivery address below: ^ i`lo , r 3. lSlps Certllled Mail ~ Express Mall ^ Registered O Return Receipt for Mericttertdise ^ Irteured Mail ^ C.O.D. 4. Restricted DeHver)!t (Exba Fee) Yes 7006 Ob~ti 0005 1039 9276 Domestic Return Receipt to~a~o2-M-tsgo STEPHANIE BORING : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 10-4607 JOSEPH F. BORING :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 13, 2010. 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. 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: `p - ~ B'~Zp~a ' `y"' "" Stephanie Boring ' c ~ c> -'~ ~~ ~ ~ ~ ~-n ~ n ' Cts ~- -'G A N r9 'C3 q "C O f_ "'r 0 s _n ly' ~-7 ~p ~ ~ "p'i ~"_ D ~ W ~ T`r1 ~ ~ ~ ~ ~ STEPHANIE BORING Plaintiff v. JOSEPH F. BORING Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4607 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C1 ANI~ 3301(D~ 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 1 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. 4. 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: ~ O - ~ $ ' ZO)O ~ - ~ a Cj -'~ tephanie Boring --~_~ o --~ ~ ~rn C°-~ x rn -~„ ~ r --~ r ~ ~ ~ ~, ~ ~ c~ ~° ~~ x c-a ~ ~ `*~ ~ ~ w ~~ _ ....° ° D ~ STEPHANIE BORING : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 10-4607 JOSEPH F. BORING :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIllAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 13, 2010. 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. 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: ~~i ~~/D c-s ~ ,~, ~ ~ ~ -~~ a~ °o -i _ ~' ~ ° --a ~~:.. -a cn r" ~ ~, ~ ~ rn ~ c~ ~~ ~ ~© ` ~ .~ ~ *~ ~~ ~ ~~ ca ~~ --i '"~ o r„ 2- ~ -< STEPHANIE BORING Plaintiff v. JOSEPH F. BORING Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4607 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER. 3301(0) AND 3301~D) 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. 4. 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. ~r Date: /O ~ _ __ Joseph F. Boring c~ ~ ° ~ ~ -*~ -p ~ ~ --c ~~ c~ ~~ ~ c-~ ~ ~ --+ `~ rn ~~ ~ ~~ .~ ~~ ~a p~ ~~ ~ ~ C~ ~ ~ -t; STEPHANIE BORING V. JOSEPH F. BORING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4607 DIVORCE DECREE AND NOW, 0 G~ . 30 Z D f 27 , it is ordered and decreed that STEPHANIE BORING JOSEPH F. BORING bonds of matrimony. plaintiff, and defendant, are divorced from the 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, n~ ~ ~~. STEPHANIE BORING Plaintiff V. JOSEPH F. BORING Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 10-4607 CIVIL ACTION - LAW IN DIVORCE of 6? %z yj cY)C NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, prior to the entry of a Final Decree in Divorce, or xx_ after the entry of a Final Decree in Divorce dated October 30, 2010, hereby elects to resume the prior surname of Y1 1 O , and gives this written notice avowing her intention pursuant to the provisions of 54 P.A. 704. Date: Signature f!4- K Z-Lr l Sf COMMONWEALTH OF PENNSYLVANIA COUNTY OF Signat e of name being resume : SS On the day of Ov 6 C."/- , 2010, before me, the Prothonotary or the Notary Public, personally appeared the abbove a Fiant 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 purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. I& 41jaW6