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Home My WebLink About06-3883 . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Ximena R. Boyer Plaintiff No. Dl-- JPPJ C~(,)~L~~ Civil Action - Law Jeffrey E. Boyer Defendant 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 ordered 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office or the Prothonotary at the Cumberland County Court House, 1 Courthouse Square, Carlisle, Pennsylvania 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 TIllS 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. NAME: PROTHONOTARY OFFICE OF CUMBERLAND COUNTY ADDRESS: 1 COUTHOUSE SQUARE CARLISLE, PA 17013 PHONE: (717) 240-6195 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Ximena R. Boyer Plaintiff No. VS. Civil Action - Law Jeffrey E. Boyer Defendant DIVORCE NOTICE AS TO COUNSELING YOU ARE HEREBY NOTIFIED THAT COUNSELING IS AVAILABLE AND MAY BE REQUESTED BY EITHER PARTY. UPON WRITIEN REQUEST MADE TO THE PROTIIONOTARY'S OFFICE IN THE CUMBERLAND COUNTY COURTHOUSE, 1 COURTIIOUSE SQUARE, CARLISLE, PENNSYL VANIA, 17013, BOTII PARTIES WILL BE PROVIDED A LIST OF QUALIFIED PROFESSIONALS WHO GIVE COUNSELING SERVICE. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. D/--df>P.J (!t~IL'-r~ Ximena R. Boyer Plaintiff Civil Action - Law Jeffrey E. Boyer Defendant DIVORCE : COMPLAINT AND NOW comes the Plaintiff, Ximena R. Boyer, Pro Se Harry M. Ness, Esquire, and files this Complaint based upon the following: 1. Plaintiff is Ximena R. Boyer, date of birth: December 16, 1968, an adult individual with the current mailing address of30 Ashburg Drive, Mechanicsburg, PA 17055. 2. Defendant is Jeffrey E. Boyer, date of birth: January 27,1962, an adult individual who currently resides at 4756 Brian Rd. Mechanicsburg, P A 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 24, 1995 and separated on September 30, 2005. 5. There have been no prior actions for divorce or annulment between the parties. 6. This action is not collusive. 7. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully submitted, . VERIFICATION This verification is made subject to the penalties ofPa.e.S. Section 4049 relating to unsworn falsification to authorities, which provides that if! knowingly make false averments, I may be subject to criminal penalties. Dated: 1/ S/ 00 r , (') ,...-.., ~:) .fQ. 1.::,,;) ~ C" c:~ ,1 (,.", - -- , .-1 ..0 ~~ P 1'--:' ~' ....... ,...., , ~ ~ , -.... . 9? Ire: ........ :-:~.I ........ ~ :\j - c' -< " ~ iB Acceptance of Service October 21,2006 Ximena R. Boyer Plaintiff No. 06-3883 Civil Term vs. Civil Action - Law Jeffrey E.Boyer Defendant Divorce I, Jeffrey E. Boyer, the Defendant in Case No. 06-3883 Civil Term, accept service of this Divorce Complaint filed on July 11, 2006, by PlaintiffXimena R. Boyer. I have signed and submitted the AFFIDAVIT OF CONSENT and WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE on October 20,2006. I consent to a final decree of divorce without further notice. (~05( ~ ~ ~ g? o ~ {'..) c.iJ ~ '~:Q \1 . r:: rn ~c ;:)b :-t; -\"1 .~~ o .:::-\ -:-,. ~ -0 :;.:; '" .- N - I I ! I I vs. I I I I' I I ! ! i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2. ;><I M'&JA (<. B c..lf e:rZ_ Plaintiff No. o~ - 3883 C'V\L I'C:i<-M 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. II I. II II Ii I \ I I I I I I i II t ! I, 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 f 18 Pa.C.S, Section 4904 relating to ! unsworn falsification to authorities. i I I I ! I ! I , i , i ! i, Civil Action - Law 3U:-fR~'--f E. &'-{~t1- Defendant Divorce AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ,-lI-l..DoLo The marriage of Plaintiff and Defendant i~ irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. 3. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 2. I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 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. 3. Q c_ ~ -U(:~_i '~JL S';f:" (13 :'~\ Gt~: ;2 -" ~ -<. ---------"."~'~'"' ~ <= = Cf"' o o -1 N C> o -n =t!::n n'l hi ~y C~IO -T. ::::-n 40 om ~ ~ -0 --,. ~... o N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -X'M.ErJA ((. (3c..ycf7- Plaintiff No. o~ - 3883 C I v, '-- TC:l'Z.fV\. vs. Civil Action - Law --::m1R €.~ E:. j30 Y t:"fZ.... Defendant Divorce I , , I AFFIDAVIT OF CONSENT A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ,-II-Lot> to The marriage of Plaintiff and Defendant iiiJ 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 I intention to request entry of the decree. I II 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. i I L ! I II II ! 1 WAIVER OF NOTICE OF INTENTION TO REQUEST I! I ENTRY OF A DIVORCE DECREE III UNDER SECTION 3301(c) OF THE DIVORCE CODE I 1. I consent to the entry of a final decree of divorce without notice. I 2. I understand that I may lose rights concerning alimony, division of property, ! I lawyer's fees or expenses ifI do not claim them before a divorce is granted. I I 3. I understand that I will not be divorced until a divorce decree is entered by the II Court and that a copy of the decree will be sent to me immediately after it is filed II with the Prothonotary. III 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 I I unsworn falsification to authorities. 1. 2. ~/5.~ ( f t i II I! i I [ i r I Ii i: /j67~~ o c -;:I'" 4:~_. \:J \~~,-, c;~~ ~-~.: ~:-::;; \~ ::::t -< ~ c:::> er- e::> ("") -t f') o -q :1- ~ :2- ':~ -,...,("1 "0....\ '0 """""\-\.i :r: -t' 120 3m ~ ;.c:. - .' o N PLA'NT\ff X I N. iZ..r-JA r<-. {So'1'ffL IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. D ~ rE:t-J D A rJT :::...i crilL ~ Y E. is 0 L! E7<-- PRAECIPE TO TRANSMIT RECORD CIVIL DIVISION NO. d(, -3883 CIVIL TERM 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) 3301 (d)( 1} of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: l-\ \ -COOln S"'~(Z. v($ I,.J Pc::.:- 5 0 ,J 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: by plaintiff \ 0 -""La - '----00 Co ; by defendant \ 0 -La - -z..<Ju(" (b) (1) Date of execution of the affidavit required by ~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: (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: I 0 - "'Z... 6 - 7..00 ~ Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: \6 -LO- 7..00 ~ i~~ -------- ~ ::o? ~~ .~- ~ ....-\ ~e :9:>\3 .;::.-., ,l-) ':::-1"-;'. -r:'':'''\ ~~"""'~.."') ....0 '0;(_ ~f\ -::;t. 'q, t:~ .~ ~ ~ <a 0- <fS ;.....\ ~ ;+!'t;;lift; ;f. ;f. ;f. '" ;Ii ;Ii ;f. ;Ii ;Ii ;f. '" '" ;Ii '" ;Ii ;f. '" '" ;f. ;f. ;f '" ;f '" ;f ;Ii ;Ii;f.;Ii;liff.;Ii;li;f.;f.;Ii;liff.;liff.ff.;f.;Ii ;f.ff. ;f.;f.ff. ft; ff. ;f.;f.;f.ff. ;Ii;f.;Ii ff.;f.ff.;f. ff.ff.;f.;f.;f. ff.ff.ff.;Ii;li;li;liff.;liff.;f;li;f;li;f;f~ff.ff.;Ii;f~ ff. IN THE COURT OF COMMON PLEAS : ;f OFCUMBERLANDCOUNTY . DECREED THAT XI ME""f'JA rz. 13 CJL(I:::...R . AN 0 3UfT'lZL( c= f;CJy~lL- STATE OF -.-PLA'~T\F~ f' f'-\ EJ-..; A ((. ~(J1EY2- VERSUS Dt..ITr--J DA tVT -::lGFR c.'1 E. i3 0 Lj l::J(._ AND NOW, PENNA. No. o<.o-3B83 DECREE IN DIVORCE O~ ;;-5' ;;r / ~:3o/J #1 · ~ , IT IS ORDERED AND , PLAI NTI FF, , 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; r-J 0 r-J S. J. PROTHONOTARY ;f.;f.;f.;f.~;f.;f.;f.ff.ff. ff.ff.;f.ff.;f;f.~ff.ff.ff.;f.ff.ff.;f.ff. ff.;fff.;f.ff.;f.ff.ff.;f.ff.;f.ff. .~ ~ ~ ~ ?rl'1C'~/ /fft/ ~ ~ ~~ ~ 'l(J.1C' ell . .- ~ "" ., ~ ... .- ~ . '.