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Home My WebLink About95-01546 , ":~::'llCo' 'ollC-: "lito: __:'.~.; '~'...: xc< :'..._:'.:~. .:~: .x"~.: "...;. .:.>: ',:.>: ":c-,'X"X>:c<>*~>:c.;;'*)llCo:)llC<~=-~ ~ ~ " ~ ~ DECREE IN ~ DIVORCE.-r ,/~~/J)-(.~ U ()J '1' r; ~ ." .. " ""..., , ., '. 19., ~(i,.. It Is ordered and ~ " v ~ ~ ;,: ~ , ill " S ~ " ~ ~ ~ ~ ~ " ~ " $ $ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF * PENNSYLVANIA ....' .D.IW;J:[), ..~J;:.E;. . BO.SIj/\RT ". .......,....,..... ".... II II N ll. ..}.~::).~.4.9., ,~J.YI.~... 19 II II II ~ ~ ~ ......IJ~I3R.I\,...I\I':l.N.,..B.o,s.!i!lRT,. .......,..,........ ~ ...'".,."",."."",.. Defendant S ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ .., ~,~ " ........................... ...................... ......... ~ .~ .. ~ ft ~ ~ S ; ~ ~,w,;; ~ '7~?ji~..c; : ~j:/ .' '.. ~"." r ...,:;../.p:". ~~h~~ol.ry ., ~ ,'. ~ . . . . . :.......... ....CO... _____... .. .....:;;...:;~'".:.:.-~.:.::::.::~.*~~~"':i~-::;:...._'::;;:--<<...~:.;-..;::-;::~~ .......,'...................,...., ." ..,..,. .... .,J'JqJf.I.t:Ut...,.,.. " Versus AND NOW" , decreed that".., ,Q~y~,q" ,e ~p,B,~qtj:".,.".,..,.,..".",.. plaintiff, and... " " " . p,~qJ;"~.l\I)\l, ,~q~\1f1,r;t" ..., ,. ,...., , , ,....,.,.., 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; None ........ ................................., .... ..... ......................., ~ ~ ;.; ~ ~ ~ ~ ~ ~ " $ ~ ~ ~ ~ iii , ~ .' iii , ., ::: ! I , I ~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95 - 1546 CIVIL TERM I: I I I I, I ~ . " DAVID LEE BOSHART, plaintiff DEBRA ANN BOSHART, Defendant CIVIL ACTION - IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the fOllowing information, to the Court for entry of a divorce decree: 1. The marriage of Plaintiff and Defendant is irretrievably broken under section 3301(c) of the Divorce Code. 2. Plaintiff's Complaint in Divorce under section 3301(c) of the Divorce Code was filed on March 24, 1995, in the Office of the Prothonotary of Cumberland county, Pennsylvania, and was served on the Defendant herein by certified mail, return receipt requested, restricted delivery, on March JO, 1995. 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 January 30, 1996; by Defendant December 27, 1995. (b) (1) Date of execution of the plaintiff's Affidavit required by section 3301(d) of the Divorce Code: ; (2) Date of service of the Plaintiff's Affidavit upon the Defendant lAW 11IIU I', M^'II.lN II Mt'-^I.l.11 4. Related claims pending: None. , 5. Date and ~anner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached, as required by Pa. R.C.P Nos. 1920.42(d) (1) and 1920.73(a)(1): Service by mail upon Keith B. ! i I, DeArmond, Esquire, attorney for Defendant, on January 22, 1996. Date: February 16, 1996 ~}L-~fb~ Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiff IAWllllltl'. M^ltI.IU It. Md-'^I.I.11 -2- .~ r.... . j,- (~ ,. , - Il'!'- , - :.i~ r .' - ,. -' rt~. i.-,: .. 1._.... ..:; -- (,;::;, ~ ",j (", '''' ,) ", I. ~. - , , ., ; tJ..: c,. ~ i'~'.-l 1,_ j 4. '"'- I', - : , ' II') -' L I 'J -. .. DAVID LEE BOSHART, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW j, !: I, NO. 95 - 1546 CIVIL TERM DEBRA ANN BOSHART, Defendant CIVIL ACTION - IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE TO: DEBRA ANN BOSHART, Plaintiff KEITH B. DeArmond, Esquire David Lee Boshart, Plaintiff, intends to file with the Court the attached praecipe to Transmit Record on or after February 13, 1996, requesting that a final decree in divorce be entered. Date: January 22, 1996 ~~(tk? Marlin R. McCaleb Attorney for Plaintiff I AllY "II II L:. M^,H.I~~" P.hl",\Ll:Il :- r-- (,. ,-.: (..~ I " II r! ~.? -. j ,,... elC' - r,,; , ; - l_,_ w...; ,. C.l - ~,', J. t_.. 1 :.l /-" " \.0- . , J.'__. li!, , r..:", f'; i...;,. , " 'J k OA.. II. .':.' <;! :...:, .', . l.J .. ~ i 1L 1i 1 U"> ,- >- 0 en 0 - "'.. \I) ., - 0 = hl~:", ;_';~.I I() '::r r6 "- E~~~. 0 ~ l'f) r" N 0 ~ ,-::) :r to l() t?)-;';;~ .:: ('6 ('<) N ~~ ~~ ;~~; c-- n - w ~ - ::II~!~I~I ~ , ~ +\ N -. ....~.... ~ ,,- '" c:J ex: oc.;. -. x:: ~HS ~~ "' "' ~ 0 H>'l ~ l;.l -I-l ~ ll<11l l;.l ~ ' . ~ffi '0'1 ~ '" ti it Eo< -I-l 'tl j UJ ~ I:: @ ill< H OM l:J ~ ll. ~ 0 ~ H III l;.l ~ u ffi z f:J ~ o . ~ r:; .r-i . QJ Ii: lJ - )( z ~~ Eo<ll< Eo<j:l H .. ~ a: 4: 0 LU CJ ~ ~ i 0 k1:i CD a. ~ ffiadli I j ~ 4: a: 0 .::} 11l . 11l z ~ ~CJ :z: 0 III 0 . 01 ~ :r It _ 0 11l :>- 11l CJ u. N z ~I H \f) . Eo< - rz:I ~ ~ X CJ 1 rz:I u '" .:: t!7 H ~ H C; j:l ril Eo<~ ~ H . ~ gj 0 ~CJ CJ :z: j:l j:l , . 1(,'.\'11111"-, ,,",^IIIIt~ II M,l ^llll DAVID LEE BOSHART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. q~J' II-)q (,~ CIVIL TERM CIVIL ACTION - IN DIVORCE DEBRA ANN BOSHART, Defendant NOTICE TO DEFEND ~ND CL~IM 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. If the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at cumberland country Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CL~IM FOR ALIMONY, DIVISION OF PROPERTY, L~WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ~NNULMENT IS GRANTED, YOU MAY LOBE THE RIGHT TO CL~IM ~NY OF THEM. YOU SHOULD T~KE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ~ L~WYER OR CANNOT ~FFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland Country Court One Court House square Carlisle, Pennsylvania (717) 240-6200 House 17013-3387 / ')'.' /4 t~L>( ~(/(J~L Marlin R. McCaleb Attorney for plaintiff 1~,W 01'" t " M"'IUrlll MICAI UI DAVID LEE BOSHART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NO. CIVIL TERM DEBRA ANN BOSHART, Defendant CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is DAVID LEE BOSHART, who currently resides at 117 Victoria Drive, Mechanicsburg (Lower Allen Township) , Cumberland County, pennsylvania 17055, since August 31, 1994. 2. Defendant is DEBRA ANN BOSHART, who currently resides at 127 Seventh street, Borough of New Cumberland, Cumberland County, Pennsylvania 17070, since June 1, 1980. J. Plaintiff and Defendant have been bona fide residents in the Commonwealth of pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on November 18, 1972, in the Borough of Mechanicsburg, Cumberland County, Pennsylvania. 5. There has been a prior action of divorce or annulment between the parties, filed in the Court of Common Pleas of Cumberland County, Pennsylvania, on April 19, 1989, to No. 1387 civil 1989, which action was dismissed pursuant to Pa.R.J.A. No. 1901 on October 26, 19~3. ~ 6. The marriage is irretrievably broken. -1- tA'.';lIlll.I'- M^,H IU II Md..\tlll DAVID LEE BOSHART, IN THE COURT OF COMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . vs. CIVIL ACTION - LAW : NO c('- CIVIL TERM . J. I'J/II" DEBRA ANN BOSHART, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING David Lee Boshart, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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. , Date: ?J)tl1:c!-. ;LY , 1995 }9,} :I( ~C >(~L iJvlitM:~ David Lee Boshart, Plaintiff >- !l;; ,.:~ u,O r..-. r-! iL- e-..... ~.~i-.): ,- r: .It:; lI!!-'.' ,.:..: ll. v <::) "'"J r- ~~ ; _,5.- '_l..'. '~J;.:: , ~~: :.~;,::~ ,,':.; i/ ;i~- ! qd.! -~ :.:..., u " - - ,- ~~ '0 - I' J;; k. '0 C) DAVID LEE BOSHART, I'lain\in' : IN TIlE COURT or COMMON PLEAS or : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-1546 CIVIL TERM VS, : CIVIL ACTION - LAW DEBRA ANN BOSHART, Defendant IN DIVORCE AFFIDA VIT OF CONSENT I. A Complaint in Divorce under Section 3301(c} of the Divorce Code was filed on March 24, 1995, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3, I consent to the entry of a final Decree of Divorce, 4, 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 verilY 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, Date: /.;)-.;27 -?.f' ,/Q-,,~c-~_ At/f)yf r ; Debra Ann Boshart, Defendant >- co t: ~!; I.() I'" UJ~'1 8 .~:) gc: i:~ ~'~ IJ-~ .-... ~.J :-'':' .1- .. h;'': ~,~l ~J 9c Co) '-,', '0 ::';"..i ~." "J ..1:.: Eel': -, rr-.- I j,"'ij r~: .. l ~Cl.. -, t'. ..:: (J \.r:... ::'1 t,;;) U ,._~..... DA VID LEE BOSIIART, Plaintilr : IN TilE COURT OF COMMON PLEAS : OF CUMBERLANDCOUNTY. PENNSYLVANIA vs, : NO, 95-1546 CIVIL TERM : CI VII. ACTION - LA W DEBRA ANN BOSHART, Defendant : IN DIVORCE I).:FENI>ANT'S COlINTER-AFI1I1>A VIT (lNI>ER SECTION 330((dl OF TilE mVORCE COIlE I. Check cither (a) or (b): _ (a) I do not oppose the entry ofa divorce decree, _X_ (b) I oppose the entry ofa divoree decree because (Check (i), (ii) or both): _ (i) The parties in this action have not lived separate and apart lor a period of at leiisttwo years, _X_(ii) The marriage is not irretrievably broken, 2, (Check either (a) or (b) ): ---"- (a) I do not wish to make any claims lor economic relie!: I understand that I may lose rights concerning alimony, division of property, lawyer's Ices or cxpenses if I do not Il.., claim them belore a divorce is granted, _X_ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights, I verily that the statements made in this counter-atlidavit are true and correct. I understand thatlillse statements herein arc made subject to the penalties of 18 Pa, C, S, Section 4904 relating to unsworn lillsiliclltion t authorities, Date:L'lil.' 'It,; % 1''/(/,' I ' /.. ..1/., ()!I Debra Ann Boshart <"/1'/- NOTICE: If you do not wish to oppose the entry ofll divorce decree IIl1d you do not wish to mllke IIny e1l1im for economic relief. you need not file this eounter-lIflidllvit. o ~~ ll<1Il ~~ i:1ll< ~~ 00 Ii !~ t-lt) ~ E-t .., ~.~ t) I l2: o t-l ~ .., t-l ~ ci t) l2: . , . ' un """ - >-,.. ~~.. ._ r: l,il ~~,: ,..~ ~~~~,~ ; '1J~'F:: L'';.:'" .1. t, ~ ,;) ~~ ::c- O- m "" - v.:> <t: .... ..a lI-l lI-l ... .jJ .~ III r-l ll< . ~ III o III ~ .., Q t-l ~ Q . 1Il :> .jJ ~ 'tl ffi lI-l Ql Q . E-t ~ III o III !j t-l ~ III r:.. o E-t t-l ~ Q t-l r:.. ~ 11\ ~ ~ ~~ '" ~ ~ ~ h~~ i:lU ~ Iii 11\ ~ fi Z Z ~ ~ BU 5 ~~~ B~~ ~ '" m It _ U II.. N Z ~ : l;l ~ ~ ~ f5 Q . .. ,'" .... II j' . . It...... 1.1'" I M^lllltt It t.l.t .'\1111 " . DAVID LEE BOSHART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 9.5- /5-1./& CIVIL TERM CIVIL ACTION - IN DIVORCE vs. DEBRA ANN BOSHART, Defendant AFFIDAVIT OF SERVICE MARLIN R. McCALEB, Esquire, certifies and says: that he is the attorney for David Lee Boshart, the Plaintiff in the above-captioned action; that on behalf of said plaintiff, he did file Plaintiff's Complaint in Divorce and Notice and Affidavit under section 3301(d) of the Divorce Code in the Office of the Prothonotary of Cumberland County, Pennsylvania, on March 24, 1995; that pursuant to Rule No. 412 of the P~nnsylvania Rules of Civil Procedure, he did serve said Complaint and Notice and Affidavit upon Debra Ann Boshart, the Defendant herein, by depositing a true and attested copy of said Complaint, properly endorsed with Notice to Defend and Claim Rights, and a true and attested copy of said Notice and Affidavit in the mail in the post office at Mechanicsburg, Cumberland county, pennsylvania, on March 24, 1995, properly addressed to the said Defendant at her place of residence at 127 Seventh street, New Cumberland, Pennsylvania, 17070, with proper postage attached, certified United States mail (receipt no. Z 115 690 635, return receipt requested, restricted delivery); that thereafter he did receive said return receipt card bearing the signature of Debra Ann Boshart, the Defendant .. , " ' I: I' herein, and indicating receipt of said copy of the Complaint on March 30, 1995; that the said certified mail receipt and return receipt card are attached hereto and made a part hereof, marked Exhibit "A". t': , 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. Date: Ifr...J.5 , 1995 ~d ttd- Marlin R. McCaleb ,,\"" llll II I'. t...,^uur'll t\.1d .\\ LII -2- D^VID LEE BOSH^RT, IN TIlE COUR'r OF COHMON PLEMi OF Plaintiff CUMBERL^ND COUNTY, PENNSYLV^NI^ CIVIl, ^CTION - L^W VS. NO. 1546 CIVIL 1995 DEBR^ ^NN BOSH^RT, Defendant IN DIVORCE s'rNrus SHEET (" U-l..l "~... co"" ,...fJ.r.c......7' ....(.....~&....~ ~ ';l.11(.(9~ l~.Q.u . OFFICE OF DIVORCE MASTER CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240.6535 E. Robert Elicker, II Divorco Mastor Tracl do Colyer Oil/co Managor/Roportor West Shore 697.0371 Exl, 6535 November 27, 1995 Keith B. DeArmond, Esquire DeARMOND & DeARMOND 2800 Market street Camp Hill, PA 17055 Marlin R. McCaleb, Esquire Frankeberger Place 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 RE: David Lee Boshart vs. Debra Ann Boshart No. 95 - 1546 In Divorce Dear Mr. McCaleb and Mr. DeArmond: By order of Court of President Judge Harold E. Sheely dated November 17, 1995, the full-time Master has been appointed in the above referenced divorce proceedings. A divorce complaint was filed on March 24, 1995, raising grounds for divorce of irretrievable breakdown of the marriage. Accompanying the divorce complaint was an affidavit under section 3301(d) averring that the parties have lived separate and apart for a period in excess of two years, since June 15, 1988. The Defendant filed a counter-affidavit on May 1, 1995. The counter-affidavit does not dispute that the parties have been separated for a period in excess of two years so it appears that grounds for divorce are not at issue. The Defendant further stated that she wished to raise economic relief; however, no economic claims have been raised. I am writing to counsel to inquire as to what counsel would like me to do in this case. I will schedule a hearing but before doing so, I would like to know what testimony counsel are going to offer on the issues which counsel will identify. I point out that the counter-affidavit in my opinion does not in and of itself raise economic claims. / Mr. McCaleb and Mr. DeArmond, Attorneys at Law 27 November 1995 Page 2 Please advise within ten (10) days of receipt of this letter so I know how you want me to proceed in this case. Very truly yours, E. Robert Elicker, II Divorce Master I 'I: i I 'I I DAVID LEE BOSHART, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. 1546 CIVIL 1995 DEBRA ANN BOSHART, Defendant IN DIVORCE CONFERENCE WITH COUNSEL AND PARTIES TO: David Lee Boshart Marlin R. McCaleb , Plaintiff , Counsel for Plaintiff Debra Ann Boshart Keith B. DeArmond , Defendant , Counsel for Defendant A conference has been scheduled at the Office of the Divorce Master, 9 North Hanover street, Carlisle, Pennsylvania, on the December, 1995, at 2:00 20th day of p.m., with counsel and the parties to discuss the outstanding economic issues to determine if there is a basis of settlement of claims. If issues remain after the conference a hearing will be scheduled at another date. Very truly yours, Date of Notice: 12/11/95 E. Robert Elicker, II Divorce Master . -,., , .. . . j' ":, .'-. --,..:;..~~ ,J ., ' ., . ,.,' " . " " , . ." I'" DAVID LEE BOSHART, IN THE COURT OF COMMON PLEAS OF plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. . NO. 95 - 1546 CIVIL TERM . DEBRA ANN BOSHART, Defendant . CIVIL ACTION - IN DIVORCE . PRAECIPE TO TRANSMIT RECORD To the prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. The marriage of plaintiff and Defendant is irretrievably broken under section 3301(C) of the Divorce Code. 2. plaintiff's complaint in Divorce under section 3301(C) of the Divorce Code was filed on March 24, 1995, in the Office of the Prothonotary of Cumberland County, Pennsylvania, and was served on the Defendant herein by certified mail, return receipt requested, restricted delivery, on March 30, 1995. 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 January 30, 1996; by Defendant December 27, 1995. (b) (1) Date of execution of the plaintiff's Affidavit required by section 3301(d) of the Divorce Code: ; (2) Date of service of the Plaintiff's Affidavit upon the Defendant 1..'1\"0' 11I11LV. Related claims pending: None. M^I~LH' II t.llCM.I:1t 4. roo i l I i I \ I \ AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 24, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. Date: tho I , 1996 (I ./J "j: ,d / .l- AlJr./'("f!. ,'I...e[ ~':!ML David Lee-Boshart, Plaintiff ~r;l ~~ P<tIl ~~ ~P< ~~ 00 ~u !i ;~ i ~ ~ ~ I~ ~11; tj- ,ell I l{) ~ i:l 0 u :z: . , , ..,.. en - ,- :>- ~~~:: u,~-, -:.;:' ~:~~~:: t.J t- ~,...:-. "~: ,;-::.'~: "". "'- ;:' I I ~.: ,; ~ :.::t,. ,. :'J .~_~u = e.- N :r N - N co: .~ = l;.i l;.i .... +l d .... III -r-i ;P< tIl o III ~ Q H ~ Q . III :> +l ~ 'tl @ l;.i -Ill ;Q tIl o III ~ ~ III i:il Q ~ ~ f:l i:il Q o ~ '" '" o ~ .. "' t; z 5 1IJ ~ .. ~ \1 ~ ffi z OJ z li a ~ ffi l&l ~ CD ~ ffi B . , :t ~ ~ z :> .. 01 ill It _ u '" N Z .. :t hi ~ tj H ~ o :z: ~ ~~ u ~ Ii: ~~ ~ j ~ -- " .... .' ~ , . ., DAVID LEE BOSHART, Plaintifl. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-1546 CIVIL TERM VS, : CIVIL ACTION - LAW DEBRA ANN BOSHART, Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 24, 1995, " 2, The marriage of PlaintilT and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint, 3, I consent to the entry of a final Decree of Divorce, 4, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted,' . '. , I verilY that the statem,ents made in this affidavit arc true and correct, I understand that false statements herein arc made subject to the penalties of 18 Pa,C,S, Section 4904 relating to unsworn falsification to authorities, Date: /,;J-.;2'J -9'? ,t~lktd r , Debra Ann Boshart, Defendant ~e- ~1/1~//('~ sr"0e- ~//ItJ.'/ld ATTORNEYS AT LAW 2800 MARKET STREET CAMP HILL, PENNSYLVANIA 17011 (717) 730,9394 KEITH B. DoARMOND JACKIE J. DoARMOND December 27, 1995 E, Robert Elicker, II, Divorce Master 11 N, Hanover Street Carlisle, PA 17013 RE: Boshart v, Boshart Dear Mr, Elicker: This letter will confirm the understanding which was reached during the December 20, 1995 hearing, I have enclosed a copy of my client's Affidavit of Consent, I agree to file this document within thirty (30) days of the date of execution, with the understanding that the divorce will not be finalized for a period of six (6) weeks from the date of the December 20 hearing, I hope that the production of this document will allow the cancellation of the December 28, 1995 hearing, Thank you for your cooperation, Very truly yours, DeArmond & DeArmond ttk glJ~L Keith B, DeArmond, Esquire KBDllm Enclosure cc: Marlin R, McCaleb, Esquire !)l THE COURT OF CO~!MON PLEAS OF CL~ERLAND COUNTY. ?~ISYLVIltIIA DAVID LEE eOSIIART, CIVIL ACTION - LAI; IN DIVORCE Plaintiff vs. I 1 DEeRA ANN eOSIIART, I, ~O. 95-1546 CIVIl, Jl.J!l TF.nM Defendant ~OTION FOR APPOI~~T OF )~STER (Plaintiff) (R~RRRHRRRx, following claims: moves ehe court to appoint David Lee Boshart a master with respect co the ( x) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite ( ( ( ( ) ) ) ) Distribution of Property Support Counsel Fees Cas ts and Expenses and in support of che motion states: (1) Discovery is complete as co ehe claims(s) for which the appointment of a master is requested. (2) The defendant (has) (~alxn~x) appeared in (by his attorney, Ke i th B. DeArmond (3) The staturo!:'; ground(s) for divorce <.w breakdown and continous separation for more than two vears. (4) Delete the inapplicable paragraph(s): (~~X~~~UX%xx~=xx~~~~ (~X~~~UU~XkaKX~K~r-~~~-~x~~~~~ che action ~) ,Esquire). (are) irretripunhlp ~~ (c) The action is contested ~ith respecc :0 the following claims: whpt:hpr t-hp ron rr~ l1Q" ; Q i r1""prrl nu:\h1 l' hrnvnn (5) The action (tRXR~~>>) (does not involve) complex issues of law or fact. The hearing is e.'t'pected to cake four 141 (hours) (days). Additional infor.nation. if any. relevant to ehe motion: N/A &x!laliiVt Attorney for (Plainc~::) (~ (6) (7) Date: November Ji' 1995 ....'ID NOW \ 1-17 is appointed master wich ORDER Al'?OI~n~G :,lA.STER .19.:.Ll..., ':. , ,-: l I,', d respect co the following claims: Esquire, I: L 1"-1< c/\ {.I->..,o \.J (L'-- r !ly 7kcourt: ". ('- 1/\ \(I.-<-~ ~. / . J ,~. , .,..... /". . ' ." ..- .' . ... d:>e, (}1ft/ilOilo" &: f2>C.C/!tIllDlld AnORNEVS AT LAW 2800 MARKET STREET CAMP HILL. PEW~SYLVAN1A 11011 17171 13().9J94 I(,,!h B O,Aftnond J.c_" J CeArmond , ,. " .~ '. a. ,'. l...i -" <.D <Jl DAVID LEE BOSHART, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VS, NO, 95-1546 CIVIL TERM DEBRA ANN BOSHART, Defendant CIVIL ACTION - IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Defendant in the above maller, having been granted a Final Decree in divorce from the bonds ofmatrinlllny having been entered on the 28th day of February, 1996, hereby elects to retake and hereafter use her previous name of Debra Ann Wertz, 1~/.I1'd //; ,e.4:/v<"7:- (Signature - married name) ~Jerh.) STATE OF PENNSYLVANIA ss, COUNTY OF CUMBERLAND On the lJltL day of 4 v: ) , 1996, before, a Notary Public, personally appeared Debra Ann Boshart, 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 Notarial Seal. 9:&on--: Notary Public ,j ~ ~ ... ----0, , \l '~ ........ '~ - , ...,. ''d 'I >- I"~) .' i Ilt: l :'10, fl.:-, I.'., (y ! ~ r: u~. . ' . . ;: ~ l.~. ,I I"- ,'\ ::','.," l.>.. l." I'., I.,,' '."j '~~ ... ~.....~~ -- ~ '-8 '" ~ '"'\-:::. \ - {} .~ \ 1'--.. "- '----