HomeMy WebLinkAbout02-1264LORIE L. BOWSER,
Plaintiff
VS.
HARLAN E. BOWSER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. Civil Term
ACTION 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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
LORIE L. BOWSER,
Plaintiff
VS.
HARLAN E. BOWSER, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: No. Civil Term
:
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Loric L. Bowser, a competent adult individual, who has resided at 385
Peach Glen Road, Gardners, Cumberland County, Pennsylvania, since February 3, 2002.
2. Defendant is Harlan E. Bowser, Jr., a competent adult individual, who has resided at
245 Pine Grove Road, Gardners, Cumberland County, Pennsylvania, since 2000.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on February 15, 1992 in E1 Reno,
Oklahoma.
5. There have been no prior actions of divorce or for annulment between the parties.
6. 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.
7. Plaintiff and Defendant have two children together, namely, Chelsea D. Bowscr, d.o.b.
6/13/91, and Dalton L. Bowser, d.o.b. 4-22-92.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of thc A:mcd Forces of thc United States
of any of its allies.
10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plalntiffrequests the court to enter a decree in divorce.
I veri~ 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:
Respectfully submitted,
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
LORIE L. BOWSER,
Plaintiff
VS.
HARLAN E. BOWSER, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
L'~bq I:~ ~¥'~
: No. -1-22g Civil Term 2002
:
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF NOTICE TO
DEFEND AND COMPLAINT
AND NOW, this March 27, 2002, I, Jane Adams, Esquire, hereby certify that
on March 25, 2002, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT
were served, via certified mail, restricted deliver, return receipt requested, addressed to:
Harlan E. Bowser, Jr.
245 Pine Grove Road
Gardners, Pa. 17324
DEFENDANT
Respectfully Submitted:
J~n~-~dams, Esquire
I.D. 1~o. 79465
fl'7~South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
LORIE L. BOWSER,
Plaintiff
VS.
HARLAND E. BOWSER, JR.,
.Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 12~4 Civil Term 2002
:
: ACTION IN DIVORCE
:
PRAECIPE TO CORRECT NAME
TO THE PROTHONOTARY:
Please take note that the Defendant's correct name in the above-captioned matter is:
HARLAND E. BOWSER, JR.
Date:
//f~ang/Adams, Esquire
I.~/. No. 79465
36 South Pitt St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
LORIE L. BOWSER,
Plaintiff
VS.
HARLAND E. BOWSER, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
/~t. ~
: No. ~ Civil Tcrm 2002
:
: ACTION IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME.
TO the Prothonotary_:
Notice is hereby given that the Plaintiff in the above matter:
X prior to the entry of a Final Decree in divorce.
OR
after the entry of a Final Decree in Divorce
hereby elects to resume the prior surname of YOST and gives this written notice avowing her
intention pursuant to the provisions of 54 P.S. s704.
Date: G' ~0' O ~ L~LO~L. I~OWSER, Plaintiff
LORIE L. YOS~T ('/ J
Signature of Name be'ha~esumed.
COMMONWEALTH OF PENNSYLVANIA )
):SS
COUNTY OF CUMBERLAND )
On this, the (D~day of ~J'-t~ r~ {:' ,2002 before me, the undersigned officer,
personally appeared [.. o r'-'t ~ ]. , [2,g) c,~Se.~ known to me, (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and offi~ seals