The URL can be used to link to this page

Home My WebLink About05-5335Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) CLEVE A. BONAWITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW GAYNOR G. BONAWITZ, 05 - Y3 3SCIVIL TERM 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 against you and a decree in 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 with 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 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 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 a'/ BY / //?/V Andrew C. Sheely, Esquire PA. I.D. No. 62469__----- 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Shealy, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) CLEVE A. BONAWITZ, Plaintiff V5. GAYNOR G. BONAWITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 05 - S3 3S'CIVIL TERM IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is CLEVE A. BONAWITZ, an adult individual who currently resides at 3620 Brookridge Terrace, Apartment 105, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is GAYNOR G. BONAWITZ, an adult individual who resides at 3910 Church Street, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 29, 1990 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. This action is not collusive. 10. The parties separated on or about September 21, 2005. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. Respectfully submitted, Date: October // , 2005 Aotl 0 (S 2 Andrew C. Sheely quire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 2 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: October /, , 2005 V` Cleve A. Bonawit Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) CLEVE A. BONAWITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW GAYNOR G. BONAWITZ, 05 -'-33? CIVIL TERM Defendant IN DIVORCE AFFIDAVIT Cleve A. Bonawitz, being duly sworn according to law, deposes and says: (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 Domestic Relations 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.A. Section 4904 relating to unsworn falsification to authorities. leve A. Bon h? ?' ? ? i J vi ?i A. c-? `{ tT,l?u? 1) ? !S .?7 1t N ? r N ?. a ? cn 'z:i d Andrew C. Sheely, Esquire 127 S. Market Street P.D. Box 95 Mechanicsburg, PA 17055 PA ID No. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) CLEVE A. BONAWITZ, Plaintiff Vs. GAYNOR G. BONAWITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 05 - 5335 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that he caused a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon GAYNOR G. BONAWITZ, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt cardM, on October 1 2005. ANDREW C. SWORN to, and subscribed before me ir this /I' 'Clay of October, 2005. Nota Public My Commission Expires: NOTARAL SEAL BECKY M. KNISELY, Nolry ptft MY BE"%wM? T ¦ Complete items 1, 2, and 9. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Att>ch this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Received by (Please Print 96arty) B. Date of Delivery -'VA. o-?Y-•s C. Sin u x 0 Agent dresses D. Is delivery ackinets Brent from item 1? 0 Yes ' ??L ?•_.? below: 0 No Gaynor G. Bonawitz 1 r RESTRICTED DELIVERY DELIVER FOR ADDRESSEE ONLY Y 3910 Church Street 3. Service Type Camp Hill, PA 17011 KCertified Mail 0Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) )(Yes 2. Article Number (Copy from service label) 7001 2 510 0000 3029 4190 PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 r I Mechanicsburg Main Post Office MECHANICSBURG, Pennsyl vania 170553459 4134870055-0096 10/12/2005 (800)275-8777 05:15:05 PM Sales Receipt -- Product Sale Unit Final Description Qty Price Price CAMP HILL PA 17011 $0.60 First-Class Restricted Delivery $3.50 Return Receipt (Green Card) $1.75 Certified $2.30 Label Serial #: 70012510000030294190 Issue PVI: $8.15 Total: $8.15 Paid by: Personal Check $8.15 Bill#: 1000400968623 Clerk: 18 C3 0 s CMP HILL PA 17011 P PLt Postage $ fg.60 O PIP Certified Fee Retury aeceipt Fee (Endorsement Required) C f / ? C3 Restricted Delivery Fee $3.50 ' Q C3 (Endorsement Required) ` N O? Total Postage 3 Fees $ ?' 15 N Sent To Gaynor G. Bonawitz rl v ----------------------------- Street. APf N. or PCaoxNo. 0;3910 __.----- _--__.--__.. ----- Church St. r_ ----------------- - Ciry, stare. ZfPaG ---------_p --- r Cam Hill PA Postq,ark Pr4a N ricte 011 - All sales final on stamps and postage. - Refunds for guaranteed services only. Thank you for your. business. Customer Copy r -- c r _ C G .. ?L C' -G Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) CLEVE A. BONAWITZ, Plaintiff VS. GAYNOR G. BONAWITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 05 - 5335 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 12, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: Cleve A. Bonawitz C tT' r G rn T i r '_ l . Vi l . N in e _"Cl m .. CLEVE A. BONAWITZ, Plaintiff VS. GAYNOR G. BONAWITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 5335 No. 05-535' CIVIL ACTION -LAW DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 12, 2005. I acknowledge that I accepted service of the Complaint in Divorce on October 14, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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: Signature: f`?f Gayno G. Bonawitz f1 C t? o -7n g?. 71.T c rn r " ?' S .. N T7 h c r, Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) CLEVE A. BONAWITZ, Plaintiff VS. GAYNOR G. BONAWITZ, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 05 - 5335 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A 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 decree 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : IcS? eve A. Bonawitz N ?rT, .try. G - ? m ?T ? 121 I"D CLEVE A. BONAWITZ, Plaintiff VS. GAYNOR G. BONAWITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA X35 No. 05-5353 CIVIL ACTION - LAW DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 unworn falsification to authorities. Dated: SignatureT;f ' Gaynor G. Bonawitz Ca .r' N CLEVE A. BONAWITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW GAYNOR G. BONAWITZ, 05 - 5335 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Acceptance of Service by counsel filed October 18, 2005. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on June(S , 2007 and by Defendant on June 15, 2007. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 4. Related claims pending: None. 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: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary.June 2-7 , 2007. Date Defendant's Waiver of Notice in Section 3301 (C) Divorce was filed with the Prothonotar .June Z1 2 0 &? Andrew C. Sheel squire Attorney for Plaintiff Q A c, y ... Fn N n N C7'+ ?G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CLEVE A. BONAWITZ, -PLAINTIFF VERSUS GAYNOR G. BONAWITZ, DEFENDANT NO. 05 5335 DECREE IN DIVORCE AND NOW, ?u,l?, /V J.oo7 IT IS ORDERED AND CT,R.VR. A. RONAWTT7 DECREED THAT AND GAYNOR G. BONAWITZ ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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 BY THE COURT: J J. ATT t: 119 PROTHONOTARY J ? Ica ..d lam/ 41- . ()" L_/ t L o !-/ 1