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Home My WebLink About02-0927DANA L. BOWMAN, PLAINTIFF SCOTT E. BOWMAN, DEFENDANT IN THE COURT OF CO~H~ON P?.~.~S CUMBERLAND COUNTY, PENNSYL%'ANIA .o. IN DIVORCE NOTICE TO DEFENDAND 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 DANA L. BOWMAN, PLAINTIFF VJ SCOTT E. BOWMAN, DEFENDANT IN THE COURT OF CO~ON PLEAS IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Dana L. Bowman who resides at 226 Susquehanna Avenue, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Scott E. Bowman who resides at 2404 New York Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant have been a bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 29, 1984 in Dauphin County, Pennsylvania. 5. The parties have been living separate and apart since April 16, 1999. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. There were where three children born of this marriage, Scott Ernest Bowman, Jr., DOB 08/10/85; Jayson Robert and Joshua Scott Bowman, DOB 08/20/95. 9. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 10. The Plaintiff has been advised of the availability of counseling 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. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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 unsworn falsification to authorities. Date: Dana L. Bowman DANA L. BOWMAN, PLAINTIFF SCOTT E. BOWMAN, DE~'"'-NDANT IN THE COURT OF CO~4ON PLEAS CU~4BEBLAND COUNTY, PENNSYLVANIA IN DIVORCE NOTICE TO THE DE~'~.NDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 16, 1999 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. Date: Dana L. Bowman DANA L. BOWMAN, PLAINTIFF Vo SCOTT E. BOWMAN, DEFF/qDANT IN THE COURT OF CO~ON PLEAS CUMBERLAND COUBT~, PENNSXLVANIA NO. 2002 - 927 CIVIL TEP/~ IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce and Plaintiff's 301{d) Affidavit was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on February 23, 2002 pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on February 25, 2002. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 · ,2, encl Item 4 if RestriCted Delivery is desired. · Print your n~ne and ~ldress on the reverse · Attach this card to the ber, k of the meJtPleCe, r'l Insured Mell I-I F_xpm~s M~I [] Rettvm Receipt for Memhandlse [] C.O.D. 4. Restricted Delivery? (Extra Fee) ~ Yes 2. Article Number (Copy from service label) A PS Form 3811, July 1999 Domestic Retur. Receipt 102595-00-M-0952 DANA L. BOWMAN, PLAINTIFF V. SCOTT E. BOWMAN, DEFENDANT IN THE COURT OF CO~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 - 927 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVI~ I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that Plaintiff's Notice of Intention To Request Entry of Divorce Decree and Defendant's Counter-Affidavit Under Section 3301(d) of the Divorce Code was served upon the Defendant by depositing the same in the United States mail, first class, postage pre-paid on March 18, 2002, to the address to which he received the complaint in divorce. The envelope was not returned by the postal authorities. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA (717) 731-1461 17011 2 EAST MAiN STREET SHtREMANSTOWN,PA 17011 q omas D. Gould ATTORNEY AT LAW (717) 731-1461 FAX 761-1974 March 18, 2002 SCOTT E. BOWMAN 2404 NEW YORK AVENUE CAMP HILL, PA 17011 Re: Divorce Dear Mr. Bowman: Enclosed is Plaintiff's Notice of Intention to Request Entry of Section 3301(d) Divorce Decree and Defendant's Counter- affidavit. You need to take no action for your divorce to be completed. Sincerely, ~homas D. Gould enclosures cc. Dana L. Bowman DA~IAL. BOW~%N, P~INTIFF SCOTT E. BOW~%N, DEFENDANT IN THE COURT OF CO~ON PLF2~ C~ COUNTY, PENNSYLVANIA NO. 2002 - 927 CIVIL TEP/~ IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: SCOTT E. BOWMAN YOU have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit. Therefore, on or after April 8, 2002, the plaintiff 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. 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. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 DANA L. BOWMAN, PLAINTIFF V. SCOTT E. BOWMAN, DEFENDANT IN THE COURT OF CO~N PLEAS C~4BERLAND COUNTY, PENNSYLVANIA NO. 2002 - 927 CIVIL TERM 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 to 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 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: SCOTT E. BOWMAN DANA L. BOWMAN, PLAINTIFF Vo SCOTT E. BOWMAN, DEFENDANT IN THE COURT OF CO~ON PLEAS C%~BERLAND COUNTY, PENNSYLVANIA NO. 2002 - 927 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d) (1) of the Divorce Code. 2. Date and manner of service of the complaint: U.S. Mail, Restricted Delivery, February 25, 2002. 3. (a) (1) Date of execution of the affidavit required by section 3301(d) of the Divorce Code: February 21, 2002; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on February 22, 2002, served February 25, 2002. 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: U.S. Mail, March 18, 2002. Thomas D. Gould Attorney for Plaintiff iN ThE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF j~~~ PENNA. DANA L. BOWMAN, NO. 2002 - 927 CIVIL TERM Plaimtiff VERSUS SCOTT E. BOWMAN, Defendant DECree IN DIVORCE AND NOW,~ DECREED THAT DANA L. BOWMAN AND SCOTT E. BOWMAN , 2002 , IT IS ORDERED AND , PLAINTIFF, , 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; NONE PROTHONOTARY