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HomeMy WebLinkAbout05-5436 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005 - SL(J6 Ct'u~LI8u-v) DOUGLAS E. WONDERS, Plaintiff BONNIE L. WONDERS, 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 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNeY~VANIA 2005 - S'''I~ {.. C;v~L ~ IN DIVORCE DOUGLAS E. WONDERS, Plaintiff BONNIE L. WONDERS, Defendant COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Douglas E. Wonders, who currently resides at 632 Lynes Road, Dillsburg 17019 (Monroe Township), Cumberland County, pennsylvania, since 1981. 2. Defendant is Bonnie L. Wonders, who currently resides at 290 Wyatt Street, Harrisburg, Dauphin County, pennsylvania, since October 2005. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 29, 1999 in Williams Grove, Monroe Township, 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. 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. 8. Plaintiff requests the court to enter a decree of divorce. 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: J 01, 1( 0 tJ" I I 4~ ~ ~~/ , glas E. Won ers ) Shu a t Court . 19373 35 East High Street, suite 203 Carlisle, PA 17013 (717) 241-4311 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005- S'f3to Cunl/eLM DOUGLAS E. WONDERS, Plaintiff BONNIE L. WONDERS, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint. A true and correct copy thereof has been delivered to me by Dale F. Shughart, Jr., Esquire. Date: October.l /, 2005 gf~ 1--Wc~~ Bonnie L. Wonders '.:;l \-<- ~. CT'" ,-/------------ DOUGLAS E. WONDERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005- 5436 CIVIL TERM BONNIE L. WONDERS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on October 18, 2005 and served on October 21, 2005. 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety 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: January 20, 2006 ~~- Bonnie L. J W~4~ Wonders Sworn to and subscribed before me this ~()nday of January, 2006. g~~C~~~ (j NOTARIAL SEAl BONNIE L. COYlE, NOTARY PUBlIC BORO Of CARUSLE, CUMBERLAND CO, PA MVCOMMISSlON EXPIRES OCTOBER 17, 2006 --.--,,-. 0 c-> 0 .::;::.> ~~~; c.:::> -11 c-" c,_ --1 ~..,: ~=~ !'-, -r'dJ :'~)'-'; c=, (.,) ~,,::::'l {'..) 5:t \..(') -< DOUGLAS E. WONDERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005- 5436 CIVIL TERM BONNIE L. WONDERS, Defendant 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 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 unsworn falsification to authorities. Date: /- ~O oG l5~jw.~ Bonnie L. Wonders o TI ,,- CJ =? rll2:~ iT (.)) r-..,) ...c' DOUGLAS E. WONDERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005- 5436 CIVIL TERM BONNIE L. WONDERS, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on October 18, 2005 and served on October 21, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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: January 20, 2006 'C/L ' ,/~ C4~~ ~Uglas E. Wonders Sworn to and subscribed before me 02.d:/:11. day of January, 1 this 2006. NOTARIAl SEAL BONNIE L COYlE, NOTARY PUBLIC BORO Of CARUSLE, CUMBERLAND CO, PA 1M COMMISSION EXPIRES OCTOBER 17, 2006 r' 7.! ~, (~ C:-::-,.> ~. '- :';,.. ."'-,- P~) co (;'..: ':..:) --;! :D .< Z'O ..C' DOUGLAS E. WONDERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005- 5436 CIVIL TERM BONNIE L. WONDERS, Defendant 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 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 unsworn falsification to authorities. Date: ! )u /O-h ~ <r?i/~- ouglas E. Wonders '"-" r~? ;:,:::~ ~;;"" ~ :-:;! (- ~< ~- N o -0 -- t.':: 1'-' \D DOUGLAS E. WONDERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005- 5436 CIVIL TERM BONNIE L. WONDERS, 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. Ground for divorce: irretrievable breakdown under ~ (3301(C)) of the Divorce Code. 2. Date and manner of service of the complaint: Divorce Complaint was served by Acceptance of Service by the Defendant on October 21, 2005. 3. Date of execution of the by ~ 3301(c) of the Divorce Code: by defendant January 20, 2006. affidavit of consent required by plaintiff January 20, 2006; 4. Related claims pending: resolved. None, all claims have been 5. Date plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: January 20, 2006. Date defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: Januar 20 2 ../ Dale F. r. Supreme 19373 35 East High reet, Suite 203 Carlisle. PA 17013 (717) 241-4311 Attorney for Plaintiff 9. ~; c:.:r" o -;\ c__ ~~~ \" o ~ -- ~ C..^? ~ v^' ;Ii "':ti "" ~:tO . . . :ti~ ~~:ti:ti~~:ti~:ti~ ~~ :ti~~~~ ~~~ "" ~~~~~ ~:ti "'~~"'~~~"'~:ti~~~~:ti ~~~~ '+'+;:1::'" Of.;+: . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS . . OFCUMBERLANDCOUNTY . PENNA. . . . . . . . . . . STATE OF DOUGLAS E. WONDERS No. 2005- 5436 CIVIL TERM PLAINTIFF . . . . VERSUS . . . . . . . . . . . . . . BONNIE L. WONDERS. DEFENDANT DECREE IN DIVORCE . . . . . . . ')..~ AND NOW, JANUARY 2006 , IT IS ORDERED AND . . . DOUGLAS E. WONDERS DECREED THAT , PLAINTIFF, . . . . . BONNIE L. WONDERS AND , 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 . By THE COURT: ,-t,- t ~\ ATTEST: J. ~~ PPOTHONOTAPT . . . . . . . "-"'..--- ./ .. .. .. ;F.;+i "''''''' :+: ;to;!;"'''' ;f;f. 'tOOf. Of. "'''''''Of''' :t' '+'+::f. 'f.:i''l';f.;t.'f.'fo! "'Of 'f''f.:t''f' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . + + . . . . . . . . . . . . + . . . . . . . . . . . . . . .' (.i) ~? -fZ. ~7f' t}1,Y'-)--(;'/..~? At. / 'f / r1?1/h'/}~' ~v2 /?,Jj,,','?,I(;;) ;C',,') /}(l?C I 7- /:? r' / ' . J ' .. . . . .