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Home My WebLink About94-04668 .~~~~~~~~-...~~~~~---~.>"~'.~':~;.~~'~~~~ 8 ' ~-- _ M ... w '.' ~ ~ S IN THE COURT OF COMMON PLEAS ~ '=' OF CUMBERLAND COUNTY STATE OF ~ PENNA. ~ w '.' .', ~ 8 .R.. K,ENNflTHBOMGARDN);:R, 51.{.. N (), ..,~,6.~~..,........ ..........,...... 1994 :1 ,', * " 0;' Vel'SlIS ,', * ~ '.' NANCY J. BOMGARDNER ," ~ .' W ',' W <:> DECREE IN ~ 0 I V 0 R C E ..t 1..', I.( b P- AND NOW, ..".".,.~~..". 19~,~.. it is ordered and decreed that.,....... ~,.. .~~~.~~!I. .~l?~~~J?~~.~" .~~.'..",..... plaintiff, and.........,..,..... .~~~,"X .o!,..~9~G~~I?~~~,............... defendant, are divorced from the bonds of matrimony, .', * ~l ~ (~ i '.' ~ ~ w ... ~ ',' ~ 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; w '.' W 0;' ,', ~ NONE i ... i ~.' ...... ........ .................................. .,. ..... .......... ........, ............... ... ... ............ .......... to. ...... M .' w fo' W 0;' P. (,."u!e...-, e~. ""7 J. ,:, ~ ~ ~ ~ . <: ~______o______o.q__.__. . '0._. "'0." . 0 ~~~~*~..~~~.~.*******~** Prothonolnry , ~ .:+:. .:+:. .:+:. ':0:' .:+:. .:.:. .:+:. .:.:. .:+:. .:+:.' . ~ ~ i " ~ ,', ~ . 8 8 8 w 0;' ,', * ~ ,'~ * ~ I~ ,', ~ ~ ,'. ~ l!i w '.' ~ ~ ... ,~ ~ i '.' ~ * i '.' i '.' I~ i* ~ * ~~ "0' :* ~ ;~ I f I~ /',' r (. 1\ . a.....J-~,~. '0/'0;/4., H. KENNETH BOMGARDNER, SR. Plaintiff . . . . . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 94-4668 NANCY J. BOMGARDNER Defendant . . . . : CIVIL ACTION - LAW 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 section ( I 3301 (cl ( X I 3301 (dl (1) of the Divorce Code. (Check Applicable Section). 2. Date and manner of service of the Complaint: Personal Service on August 24, 1994 . 3. (Complete either paragraph (al or (b).) (a) Date of execution of the Affidavit of Consent required by section 3301(cl of the Divorce Code: By Plaintiff: ; by Defendant (bl (1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: 8/18/94 (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 8/24/94 . 4. Related claims pending: NONE . 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301(d) (1) (i) of the Divorce Code: 9/14/94 by regular mail . ~ /~ '\{~- ~ J ES M: BACH Attorney I.D. No. 18727 352 S. Sporting Hill Road Mechanicsburg, PA 17055 (717) 737-2033 Attorney for Plaintiff , . EEO~..LE.L (.I. ~.L) (717) 737.2033 SSO.L~ VNN3d 'ElI:lnaSOINVH03W avo~ lllH ElNI.L~OdS HJJ10S zse , MYl.LV I:lCTI3SI'llOO ONY A3Nl:lO.llV HOVS .... sa...vr JAMES M. BACH ATTORNEY AND COUNSELOR AT LAW 352 SOUTH SPORTING HILL ROAD MECHANICSBURG, PENNA 17055 " ," . .. - -.- '>'.- , . - '-- . .. rn kl . "~ ,. \/" r,) ',~', i .., '1 '1",' . f' . . ., I, I " , , ! f. ,. . -, Il. KENNETH BOMGARDNER; SR. IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.94- It& ~g Civil Civil Action - Law IN DIVORCE PLAINTIFF vs. I I I I : NANCY J. BOMGARDNER DEFENDANT 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 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 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 on the first floor of the Cumberland County Courthouse, 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 T"E RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAN~OT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administration Four th Floor Cumberland County Courthouse Carlisle, PA l70l3 (717) 240-6200 " '"'...........~""n.. H. KENNETH BOMGARDNER, SR. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL CIVIL ACTION - LAW va. NANCY J. BOMGARDNER DEFENDANT : IN DIVORCE COMPLAINT IN DIVORCE COUNT I AND NOW, comes the Plaintiff, by Attorney James M. Bach, and avers as follows: 1. plaintiff is H. KENNETH BOMGARDNE~ who currently resides at R.D.H2, Box 303B, Liverpool, PA 17045 2. Defendant is NANCY J. BOMGARDNER, who currently resides at c/o 3300 Hartzdale Drive, Camp Hill, PA J7011 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 10/29/85. 5. There have been no prior action of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised, Plaintiff does not desire counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce. 1 By: ~~ S M. BACH, ESQUIRE 35 South Sporting Hill Road Mechanicsburg, PA 17055 (717) 737-2033 Attorney for Plaintiff Attorney I.D. No. 18727 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. d~(L"1.- ~~..i; PIa nt ff r 2 /' H. KENNETH BOMGARDNER, SR. Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law : vs. . . NANCY J. BOMGARDNER Defendant : : No. : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within ,twenty days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on /~ January, 1992. and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 falsifications to authorities. Date: J~~~ &mO-A~_d~-,-~ Plaintiff fl '1J I~, ,~q?-- 7 ? ~ .. . NANCY J. BOMGARDNER Defendant Civil Action - Law In Divorce H. KENNETH BOMGARDNER, SR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least three years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in the counteraffidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S 4909 relating to unsworn falsification to authorities. Date: Defendant NANCY J. BOMGARDNER NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counteraffidavit. 5; .. !';I>a - ..... ~ ._:.r. _ ~~~..-?:f -f Uj";,'_' t" .... ~?U~'~ ":C "':\;~ cY) ..1_... 0." ,_,;!':i ;/~ ", n.:.' ~"= f"O .lil'~ _ .,','1 , .... '- <-. ::0 ~ ".:-' '.;l'" -" ~-~ \J ~ ~ 10\n\~ ~\"':) -.:::J ~~ .......... ~ ~ "- .......... ,.... ~ B )- """ '" ~ IF) 1'\'") '+ -- ~ ~~ t- I..Y:) H. KENNETH BOMGARDNER, SR. . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . NO. 94-4668 CIVIL . BOMGARDNER . NANCY J. . . CIVIL ACTION . Defendant IN DIVORCE CERTIFICATE OF PERSONAL SERVICE I, JAMES M. BACH, being duly sworn according to law, say that the Defendant herein was served a copy of said Complaint along with a Notice to Defend and Claim Rights, at 352 South Sporting Hill Road, Mechanicsburg, Pennsylvania 17055, on the 24th day of AUGUST , 19 94 , 11: 45 a.m pxm~ by handing to the Defendant a true and attested copy of the same and at the same time directing the Defendant's attention to the contents thereof and the "Notice to Plead" endorsed thereon. ~~LCL J ES M. BACH A ORNEY AT LAW H. KENNETH BOMGARDNER, SR. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 94- 4668 CIVIL TERM NANCY J. BOMGARDNER DEFENDANT CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCB DECRBE TO: NANCY J. BOMGARDNER H. KBNNETH BOMGARDNER the Court the attached 10/5/94 , 1994, be entered. , The PLAINTIFF, intends to file with Praecipe to Transmit Record on or after requesting that a final Decree in Divorce 4.tt--L MES M. BACH torney for Plaintiff You have been sued in an action for Divorce. i You have failed to answer the Complaint or file a counter-affidavit to the Plaintiff's affidavit. Therefore, on or after 10/5/94 , 1994, the PLAINTIFF can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court, an answer with your signature notarized or verified or a counter-affidavit by the above date, the Court can enter a final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce, and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. COURT ADMINISTRATION Fourth Floor Cumberland county Courthouse Carlisle, PA 17013 (717) 240-6200 H. XENNETH BOMGARDNER, SR., . IN THE COURT OF COMMON PLEASE OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. . CIVIL ACTION - LAW . . . NANCY J. BOMGARDNER NO.4668-1994 CIVIL TERM Defendant . IN DIVORCE . NOTICE OP BLECTION TO RETAKE MAIDBN NAMB Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in divorce from the above bonds of matrimony on the 13th day of October, 1994, hereby elects to retake and hereafter use her previous name of NANCY J. GRAMM. /1 &-lHA-J ~ [\,\("-II-l~Cl."-~I'-M-' N cy J. B gardner TO BE KNOWN AS: '-\\C-.t_\~,t, 1 ~.. ~~\A_~'-l'-' ~ -j Nancy J. Gramm COMMONWEALTl'n ~~ . PENNSYLVANIA~ SS. COUNTY OF ~m ) On the 3 n.t day of vj\ullfl"~ 1994, before me, a notary Public, personally appeared Nancy J. Bomgardner, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. &:\....k^"- t ~Lu;l Notary PUblic ,j NoIorial So3l Charlene R Qecdy, NoIaIy I'LllIio lllrdsbuIg Iloro. Peny CounlV MyComml..i6nE><pr/llSlW,.18,1996 I~''- '-~.tN..lof I aE <Xl' In' ......, --- ...., - <:3, :;,." ~ - ~ .~;, , U"Q'l::J~ c:..:,aO:lr' ~O<'>--t 14:CQ ~. ~ '"=:;j;! "'" Jv; ....;-.:..~ '~'~;t" i"... ~'Q. ...'" 0'-' ~ ~ \ ~ !':. ~ ~ ro ~ ~