HomeMy WebLinkAbout04-4393ROBERT WARFIELD,
Plaintiff
vs.
BONITA WARFIELD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO pV - y3Q3 CIVIL TERM
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 aze 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 mamage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Courthouse, 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, 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 HIIZE 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, PENNSYLVANIA 17013
TELEPHONE: (717) 249-3166
ROBERT WARFIELD, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO.Ut{ - ~I3 '~ CNIL TERM
BONITA WARFIELD,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, the Plaintiff, Robert Warfield, through his attorney, Dawn 5. Sunday, Esquire
files this Complaint in Divorce based upon the following:
I. The Plaintiff is Robert Warfield, an adult individual, residing at 133 West Locust Street,
Apt. 102, Mechanicsburg, Cumberland County, Pennsylvania 17055.
The Defendant is Bonita Warfield, an adult individual, residing at 1481 Jacobs Mill Road,
Hanover, York County, Pennsylvania 17331.
3. The Plaintiff and Defendant were married on June 28, 1986 in York County, Pennsylvania.
4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
5. There has been no prior action for divorce or annulment of marriage between the parties in
this or in any other jurisdiction.
6. Neither of the parties in this action is presently a member of the Armed Forces on active
duty.
7 The parties' marriage is irretrievably broken.
8. The Plaintiff has been advised of the availability of marriage counseling and that he may
have the right to request that the Court require the parties to participate in counseling, and
does not request counseling.
9. The parties plan to enter agreements for the resolution of their divorce and equitable
distribution issues through the collaborative process.
WI~EREFORE, the Plaintiff respectfully requests that the Court enter a decree of divorce
under Section 3301(c) or 3301(d) of the Divorce Code.
Respectfully Submitted,
Dawn S~ quir~
Counsel for Plaintiff 00
ID No. 41954
39 West Main Street
Mechanicsburg, PA 17055-6230
(717)766-9622
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. Section 4904, relating to
unsworu falsification to authorities.
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ROBERT WARFIELD,
Plaintiff
vs.
BONITA WARFIELD,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 04-4393
IN DIVORCE
NOTICE
CIVIL TERM
If you wish to deny any of the statements set forth in this affidavit, you must file acounter-
affidavit within twenty days afrer 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 November 20. 2002 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 unsworn
falsification to authorities.
,J /~/,
Date
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Robert N. Warfield laintiff
bb/divorces/Warfield notice 3.1.05
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF.~~° PENNA.
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Robert Warfield it
N O. 04-4393
VERSUS
Bonita Warfield
DECREE IN
DIVORCE
AND NOW, ~p r t~ ~ ~`` 2005, IT IS ORDERED AND
DECREED THAT Robert Warfield
AND BOnlta Warfield
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
PLAINTIFF,
DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD 1N TH15 ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None. All claims resolved by the terms of the attached
Marital Settlement Agreement dated March 11, 2005 which are
incorporated but not merged herein for enforcement purposes only.
BY THE COURT:
ATTE$~/: ~/ 1~ J.
IV!
PROTHONOTARY
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