HomeMy WebLinkAbout06-6631
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LOUIS BOHL-FABIAN,
Plaintiff
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. Of.. -1..1,3/ f/(~iLT~
vs.
AMY BOHL-FABIAN,
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
foregoing 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 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 of 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:
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,
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
Telephone: (717) 249-3166
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vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LOUIS BOHL-FABIAN,
Plaintiff
NO.
AMY BOHL-FABIAN,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY 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
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LOUIS BOHL-FABIAN,
Plaintiff
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. D'- - /,1..31 elC)~L ~
vs.
AMY BOHL-FABIAN,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, LOUIS BOHL-FABIAN, by his attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is LOUIS BOHL-FABIAN, an adult individual who currently resides at
115 B. South 24th Street in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is AMY BOHL-FABIAN, an adult individual who currently resides at
121 South 27th Street in Camp Hill, Cumberland County, Pennsylvania.
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 18 June 1988 in Murrysville,
Pennsylvania.
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.
COUNT I - IRRETRIEVABLE BREAKDOWN
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.
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COUNT II - EQUITABLE DISTRIBUTION
9. 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.
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Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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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:
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LOUIS BOHL-FABIAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
AMY BOHL-FABIAN,
Defendant
NO. 06-6631 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE
I hereby enter my appearance for the Defendant, Amy Bohl-Fabian, in the above-
captioned action. I acknowledge receipt of a true and correct copy of the Complaint in
Divorce filed in the above action on behalf of the Defendant on ~eVY\'tfd-.!12006.
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LOUIS BOHL-FABIAN,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
AMY BOHL-FABIAN,
Defendant
NO. 06-6631 CIVIL TERM
I N DIVORCE
PRAECI PE
TO THE PROTHONOTARY:
Please withdraw Plaintiff's divorce action and the complaint previously filed in this
Date: 9 February 2007
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Attorney for Plaintiff
Supreme Court 10 # 1 7225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
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CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon counsel for
the Defendant by regular mail, postage prepaid, addressed as follows:
Kristin Reinhold, Esquire
5922 Linglestown Road
Harrisburg, PA 17112
Date: 9 February 2007
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