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Home My WebLink About01-5635HAROLD S. IRWIN~ II1~ ESQUIRE AI'rORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF PHILLIP D. BUNTY, Plaintiff STEPHANIE M. BUNTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA iCIVIL ACTION ~_ W NO. 01 - 5/~ CIVIL TERM : IN DIVORCE NOTICE 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 property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. ^ list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 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, Pennsylvania 17013 717-243-3166 PHILLIP D. BUNTY~ Plaintiff STEPHANIE M. BUNTY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 01 - ,~ ~/' CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Phillip D. Bunty, an adult individual residing at 174 CME, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Stephanie M. Bunty, an adult individual residing at 401 North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on June 23, 2000, in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. Pursuant to the Divome Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. September 26, 2000 ~/PHILL~ D. BUNT~/Piaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 PHILLIP D. BUNTY, Plaintiff STEPHANIE M. BUNTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's Office, 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. September 26, 2001 ~H ILLIP/D BUN'W, 1~3~t,ff HAROLD $. IRWIN, III, ESQUIRE ATTORNEY ID NO. 2gg20 35 EAST HIGH STREET CARLISLE PA t'7013 (717) 243-6090 ATTORNEY FOR PLAINTIFF PHILLIP D. BUNTY, Plaintiff STEPHANIE M. BUNTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENN8YLVANIA : : CIVIL ACTION - LAW : NO. 01 - 5635 CIVIL TERM : : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i} NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about October 2, 2001, by certified mail "restricted delivery", addressed to the defendant at 401 North Bedford Street, Carlisle, PA 17013, certified mail, return receipt No. 7000 1670 0010 9168 0125. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. October 3, 2001 Attorney for ! ~2~0 ~9~6 0~00 0L99~ OOOL PHILLIP D. BUNTY, : IN THE COURT OF COMMON PLEAS OF Plaintiff STEPHANIE M. BUNTY, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO. 01. ~ CIVIL TERM : : IN DIVORCE STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this 18th day of October, 2001, by and between PHILLIP D. BUNTY (hereinafter referred to as "Father") and STEPHANIE M. BUNTY (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WlTNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of one (1) child, namely, Samantha Jo-Marie Bunty, bom September 5, 2000; and WHEREAS, the parties wish to enter into an agreement relative to the custody and partial custody of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have joint legal custody of the child; however, the parties agree that the Father shall have control of all decisions effecting the education of the child. 2. Father shall have pdmary physical custody of the child, subject, however, to the Mother's rights of visitation and temporary physical custody on every Tuesday and Thursday and every other Friday through Sunday evening. 3. The parties agree to cooperate fully to coordinate these temporary physical custody times as well as to share holiday time. Father shall always have the child on Father's Day and Mother will always have the child on Mother's Day. 4. The parties shall have reasonable telephone contact with the child while the child is in the other parent's custody. 5. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health, welfare and well being of the child is protected. 6. The parties shall do nothing that may estrange the child from the other parent or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the other parent. 7. The parties shall share the income tax personal exemption for the minor child in accordance with the terms of their marital settlement agreement dated October 18, 2001. 8. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 9. The parties agree that in making this agreement there has been no fraud, concealment, 3verreaching, coercion or other unfair dealing on the part of the other. 10. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. WITNESSETH: Date: J~ ~L PHILLIP ~. BUNTY (~) (SEAL) ~M.~)' COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND : PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this 18th day of October, 2001, PHILLIP D. BUNTY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~lotary PublJc~~ COMMONWEALTH OF PENNSYLVANIA .. :SS: COUNTY OF CUMBERLAND : PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this 18t' day of October, 2001, STEPHANIE M. BUNTY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal My Commission Exp!res Sept. 23 2002 OCT 1 9 Z00i HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA t70t3 (7t7) 243-6090 ATTORNEY FOR PLAINTIFF PHILLIP D. BUNTY, Plaintiff STEPHANIE M. BUNTY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBBRLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW NO'. 01- ~'~=~ CIVIL TERM : IN DIVORCE ORDER OF COURT AND NOW, this .~_ day of October, 2001, upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. PHILLIP D, BUNTY~ : IN THE COURT OF COMMON PLEA8 OF Plaintiff V. 8TEPHANIE M. BUNTY, Defendant i CUMBERLAND COUNTY, PENNSYLVANIA ; CIVIL ACTION - LAW ; NO. 01 - 5635 CIVIL TERM : · ' IN DIVORCE D__EFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, 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 Prothonotary's Office, 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 counseling pdor to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. March, ~ , 2004 STEI;fHANIE M. BUNTY PHILLIP D, BUNTY, : IN THE COURT OF COMMON PLEA8 OF Plaintiff V, 8TEPHANIE M. BUNTY~ Defendant i CUMBERLAND COUNTY, PENN8YLVANIA CIVIL ACTION. LAW NO. 01 - 5635 CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 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 Prothonotary's Office, 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 counseling prior to a divorce decree being handed down. 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 unswom falsification to authorities. March 9, 2004 ~HILdF'D. BUN:I~ NATHAN C. WOLF, EECIUIRE AI'rORNBY ID NO. 87380 84 BOUTH PITT STREET CARLISLE PA 17013 (7~7) ~L~-e0~0 ATTORNEY FOR PLAINTIFF PHILLIP D. BUNTY, -' IN THE COUNT OF COMMON PLEAE OF Plaintiff v. STEPNANIE M. BUNTY, Defendant : CUMBERLAND COUNTY, PENNEYLVANIA ; : CIVIL ACTION. LAW ; NO. 01 - 5635 CIVIL TERM : : IN DIVORCE pLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divome Code was filed in this matter on or about September 26, 2001 and served upon defendant on October 2, 2001 (see Affidavit of Service filed October 5, 2001). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. March b~ , 2004 PHILLIP D, BUNTY~ · ' IN THE COURT OF COMMON PLEA8 OF Plaintiff V. STEPHANIE M. BUNTY~ Defendant CUMBERLAND COUNTY~ PENNSYLVANIA CIVIL ACTION. LAW NO. 0t - 5835 CIVIL TERM IN DIVORCE DEFENDANTS AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about September 26, 2001 and served upon defendant on October 2, 2001 (see Affidavit of Service filed October 5, 2001). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. March _~, 2004 ~ ~ EP~qANIE M. BUNTY PHILLIP D. BUNTY~ : IN THE COURT OF COMMON PLEA8 OF Plaintiff V, 8TEPHANIE M. BUNTY~ Defendent CUMBERLAND COUNTY~ PENNSYLVANIA CIVIL ACTION - LAW NO, 01 - EE3S CIVIL TERM IN DIVORCE _WAIVER OF NOTICE OF INTEi~TiON TO REQUE& ~ KNTRY OF A DIVORCE DECR~-~ N_U _f SE TIO OF 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 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. 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 unswom falsification to authorities. March ~ , 2004 PHILLIP~D. BuN'I~Y ~ J ~ PH' ' m D, BU;4 ~'-(, Plaintiff 8TEPHANIE M. BUNTY, Defendant : IN THE COURT OF COMMON PLEA8 OF ~ CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO, 0t. 5635 CIVIL TERM IN DIVORCE Al NOTI F NT __F~LTRY QF A D!VORCEDECR N T NU_ KR T O H R O 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose dghts conceming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 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. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. March 9, 2004 STEF~IANIE M. BUN'FY HAROLD 8. IRWlN~ III, ESQUIRE ATTORNEY ID NO. 20020 e4 8OUTH Prrr STREET ~ARLISLE PA 17013 (717) 243-e0~0 AI'FORNEY FOR PLAINTIFF PHILLIP D. BUNTY~ Plaintiff v. 8TEPHANIE M. BUNTY, Defendnnt IN THE COURT OF COMMON PLEAS OF CUMBERLAND ¢OUNTY~ PENNSYLVANIA CIVIL ACTION - LAW NO. 0t - 5~35 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECOR_r] To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divome: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about October 2, 2001, defendant's counsel was served with a copy of the divorce complaint via regular mail, addressed to the defendant's counsel. (See Acceptance of Service previously filed.) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: March 9, 2004. By the defendant: /'~,~¢~ ~. (b)(1) Date of execution of the affidavit r6quired by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None March ~ ,2004 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: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: March,~, 2004 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: /'~,,~/-~ OF CUMBERLAND IN THE COURT OF COMMON PLEAS COUNTY STATE OF ~ PENNA. Phillip D. Bunty, Versus Stephanie M. Bunty, ii' Defendant NO. 01 - 5635 Civil Term DECREE DIVORCE AND NOW .... ~//-~' 2004 it is ordered and decreed that Phillip D. Bunty, .................................................. plaintiff, and Stephanie M. Bunty, ......................................................... , defendont, 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