HomeMy WebLinkAbout05-6786
II
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
DONALD J. BONAFEDE,
Plaintiff
CIVIL ACTION - LAW
NO. ot;; -L.1FIo (2cJ~tT0-'7\
LISA A. BONAFEDE,
Defendant
IN DIVORCE
II
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i You have been sued in court. If you wish to defend against the claims set forth in the
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I foregoing pages, you must take prompt action. You are warned that if you fail to do so, the
I case may proceed without you and a decree in divorce or annulment may be entered against
I you by the court. A judgment may also be entered against you for any other claim or relief
I 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.
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NOTICE TO DEFEND AND CLAIM RIGHTS
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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS 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 A venue
Carlisle, PA 17013
Telephone: (717) 249-3166
II
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
DONALD J. BONAFEDE,
Plaintiff
CIVIL ACTION - LAW
NO. Of; -Ie. ^/tPb CI ~~L <-rfR..~
LISA A. BONAFEDE,
Defendant
IN DIVORCE
NOTICE OF A V AILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302 (d) of the Divorce Code, you may request that the court require
you and your spouse to attend marriage counseling prior to a divorce being handed down by
the court. A list of professional marriage counselors is available at the Domestic Relations
Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept
as a convenience to you and you are not bound to choose a counselor from this list. All
necessary arrangements and the cost of counseling sessions are to be borne by you and your
spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
II
[,
DONALD J. BONAFEDE,
Plaintiff
vs.
LISA A. BONAFEDE,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
)
)
)
)
)
)
)
)
) IN DIVORCE
COMPLAINT IN DIVORCE
CIVIL ACTION - LAW
CL-u~fT 't/2.n-.
NO. Of; -1.o-7PIo
AND NOW comes the above-named Plaintiff, DONALD J. BONAFEDE, by his
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434 Spring House Road in Camp Hill, Cumberland County, Pennsylvania.
attorney, Samuel 1. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is DONALD J. BONAFEDE, an adult individual who currently resides
at 434 Spring House Road in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is LISA A. BONAFEDE, an adult individual who currently resides at
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing of
this Complaint.
4. The Plaintiff and Defendant were married on 15 March 1985 in Hershey, Dauphin
County, Pennsylvania. They are the parents of one child, Kristina M. Bonafede born 22 May
1990.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
II
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COUNT I - IRRETRIEV ABLE BRl~AKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the
Divorce Code of Pennsylvania.
[i
COUNT 11- INDIGNITIES
9u Plaintiff avers that the Defendant has committed such indignities to the person of the
Plaintiff as to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce
divorcing the Plaintiff and Defendant absolutely.
COUNT III - EOUIT ABLE DISTRIBUTION
10. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual names of
each of the parties hereto.
WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by
the Defendant, to equitably divide the property, both real and personal, owned by the parties
hereto as marital property.
~~Ll
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
Date: [LIt q I 0 S
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) IN THE COURT OF COMMON
) PLEAS OF CUMBERLAND
) COUNTY, PENNSYLVANIA
)
) CIVIL ACTION - LAW
)
) NO. 2005-6786
)
) IN DIVORCE
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DONALD J. BONAFEDE,
PLAINTIFF
vs.
LISA A. BONAFEDE,
DEFENDANT
ACCEPTANCE OF SERVICE
I hereby enter my appearance on behalf of the Defendant, LISA A. BONAFEDE and
accept service of the Complaint on her behalf in this matter.
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Date:
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Jo~ne Clough
Attorney for Defendant
Supreme Court ID #
24 North 32nd Street
Camp Hill, PA 17011
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DONALD J. BONAFEDE, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 2005-6786
LISA A. BONAFEDE, )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 29
December 2005 and served on the Defendant on or about 5 January 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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. Section 4904
relating to unsworn falsification to authorities.
eoLJDCp
Dated:
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DONALD J. BONAFEDE,
Plaintiff
vs.
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)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2005-6786
LISA A. BONAFEDE,
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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: AcceDtance of Service filed bv Plaintiff's
counsel indicatinl! service on or about 5 Januarv 2006
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c)
of the Divorce Code: By Plaintiff: 1 June 2006 By Defendant: 30 Mav 2006
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
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:
Ib\ Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with
the Prothonotary: Dated 1 June 206 and filed on or about 6 June 2006. Date
Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 30 Mav 2006 and filed contemooraneouslv herewith.
Date: 12 June 2006
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DONALD J. BONAFEDE, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 2005-6786
LISA A. BONAFEDE, )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 29
December 2005 and served on the Defendant on or about 5 January 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
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 in 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. Section 4904
relating to unsworn falsification to authorities.
S/3:J/20Dh
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
STATE OF
DONALD J. BONAFEDE,
.
VERSUS
USA A. BONAFEDE,
.
.
.
.
.
.
AND NOW,
.
.
DECREED THAT
.
.
AND
.
PENNA.
.
Plaintiff
No.
2005-6786
.
.
.
.
Defendant
DECREE IN
DIVORCE
DONALD~~~ONA~;
2006
, IT IS ORDERED AND
, PLAINTIFF,
LISA A. BONAFEDE
.
, 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;
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NONE
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;?~ PROTHOROTAR~
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