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Home My WebLink About96-03079 ~ " E \l ~ ~ \) '~ ~ lit ')., I: d I u ( C ~. ,~ ,~ J J I, 1 I , 1 " I, , 1 " , ' I I' "I " ,I ! I' " 1 'I, " , 1 ' 'I , . 't I " " " " ,1 " I' " " , " '!, " " , I, " " :' '" , , , " , . I' " ,I , ' ,', ,I' , ; ~i , ' ;J' , ' { f. ~. 1 ~ 'J I.;j j -n -4:\ X ,- .~ R 0 '8 () (,) ri (:J Ij rJ ..(' ~ ' , ~ I.,) (~ ,,- , ~ if) \.(~ ~ 0' ' , l.() If) 'J- I'(l C-- - ':A 'll Il ::;, (t, ~ .~ r<.J " , . . - . . ! z ;::. S c ~ ~ ~Iii~ ~ ~ i ~~~ E :: . ~ ~ ~ ~ ~ a: ID 16 l ... C\j II " :Ii po ::) ~ .., ~, it II <( t , . RENEE BRENNEMAN, I IN THE COURT OF COMMON PLEAS Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. I NO. q!s.' " 30'7 q C I ,,,I........V Tl'.'\(1",\ JAMBS R. BRENNEMAN, I CIVIL ACTION - LAW Defendant I IN DIVORCE ~CE TO DEFEND AND CLAIM ~~ 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 ~elief 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 irretrievable breakdown of the marriage, you counseling. A list of marriage counselors Office of the Prothonotary atl Office of the Prothonotary Cumberland County Court House Carlisle, PA 17013 is indignities or may request marriage is available in the 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. Court Administrator Fourth Floor Cumberland County Court House Carlisle, PA 17013 Telephone No. 717-240-6200 I RENEE BRENNEMAN, IN THE COURT OF COMMON PLBAS " Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ! v. NO. 9'- . .]o1C, C,l,d ~"I JAMBS R. BRENNEMAN, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT gmrnT...l DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) or THE DIVORCE CODI. 1. Plaintiff is Renee Brenneman, an adult individual who is sui juris and resides at 16 Valley Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is James R. Brenneman, an adult individual who is sui juris and resides at 1805 Willow Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Both 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. The Plaintiff and Defendant were married on April 1, 1995 in Boiling Springs, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c) I The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believeD that Defendant may also file such an Affidavit. B. Section 3301(d) I ThJ marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on or about January 15, 1996. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT II CUSTODY 9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference as though set forth in full. 10. Plaintiff seeks custody of the following child: Name: James R. Brennoman, Jr. Agel 1, born December 24, 1994. 11. The child was born out of wedlock. The child is presently in the custody of Renee Brenneman who resides at 16 Valley Street, Carlisle, pennsylvanla. The mother of the child is Renee Brennoman, currently residing at 16 Valley Street, Carlisle, Pennsylvania. She is married to James R. Brenneman. The father of the child is James R. Brenneman, currently residing at 1805 Willow Road, Carlisle, Pennsylvania. He is married to Renee Brenneman. 2 12. The relationship of Plaintiff to the child is that of mother. The Plaintiff currently resides with her son, James R. Brenneman, Jr., her minor son, Tyler Lebo, age 2 and grandmother, Esther Lebo. 13. The relationship of Defendant to the child is that of father. It is believed that father currently reoides with his mother and father, Mr. and Mrs. Russell Brenneman. 14. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of the Conunonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 15. The best interest nnd permanent welfare of the child will be served by granting the relief requested because mother is and has been the primary caretaker of the child and continues to reside with him in a loving and stable environment. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. 17. Plaintiff requests the Court to grant physical and legal custody of the child to her. 3 RENBE BRBNNEMAN, Plaintiff v. I IN THB COURT OF COMMON PLEAS I DAUPHIN COUNTY, PENNSYLVANIA I I I I I NO. '1(.. 101'1 CluJ - , l.L'..... JAMBS R. BRBNNEMAN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT RlNII BRBMMIHAN, being duly sworn according to law, deposes and saysl 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 Offioe, 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 by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4909 relating to unsworn falsification to authorities. /};) .:/ / /' ..' .I' ~. ,', . . ". ,I," / I { '-" ,.....~ .Ie f i '~/" _ I/K' .J/'.- RENEE BRENpEMA ' . 6 \, } COtIIrIIONWIMJ" Of' 1It"",,,,WHl.. oeP'M'hIIH' Of ",,wH VITA&. ....COMa \ "lot IUNY HO COONIV ] DIVORCI o R.CORD 0' OR ANNULMINT (CHEC~ ONE) 0 "ATI 'Ill NUMIIA It TI'U DATI HUSBAND 1 NAME ,'lfll} rAlH1*J (lll'l (Moll/It) rD.,} ..., 3 AISIDINCI JAMES 5',",01"1> ll. C/t)I. 8oto Of"" DRENNEMAN C(Jj,"~ 51'" 2 DATI "" alATH . PlAC. "" BIRTH 1 USUAL OCCUPl\TION n 1 n ~ _..15- tlt.lI Ot'~ CocmlryJ 1805 Willow & NUMII" Of THIS WAR,UlOI 1 Road Carlisle . filiAtE WHITl! IiU Cumberla d P CAliisle, PA BLACk o OTHIR (lSpeelf)) o WIFE W 1 r LEBO 10 MIIlICENCE RENEE S/,..,."RO C/f)I.1on).0I11wp _ BRENNEMAN Ct)Un~ Ir,,. . DATI "" I'ATH II PlACE "" BIRTH 14 USUAL QCCUPl\TION /S"" Of FOI'f9I Coult'ry) . WIDtH NAM! ('IfII} (MIdd"j (I...t) (MonM} rOt,) ..., 16 Valley UP NUMItIA CW THIS MARRIAGE Street Carlisle, Cumeerland, e RACE WHITE Ja PA Carlisle. PA 1 aLACK o OTHIRI6pt(:IP)o) o fi Sales Associate I/ai tress 'I DATI Of! (Uott''') (0"1 THill ......,.... 04 I' DECAII QRANTED TO HUIIAND WI'E 01 ~,/ 95 IS PlACE Of , THIS MARRIAQE ",A HUMItfR 0' CHIlDRlt4 THIS MARRIAGE 1 (County} (S,.,. or F~ eou"'f)') Cumberland County, PA 118 NUMBER Of DEPENDENT I. PI....INTI" CHIL.DREN UNOEIlI I. HUSBAND WIFE 1 D o D OTHER t8f*lry) o I/O NUMBIA OF HUSRAND WIPE SPLIT CUSTODY OTHER 18lMclry, CHILD~EN TO 0 0 0 CUSTODY OF " DATIOFDECRIiE (Month' (DIY' t"'.r) . SIr.\NIITUAI 0' TRANSCRIBING CURl< 2t LEGoll GROUNDS FOR DIVOACE OR ANNULMINT No Fault - 3301(c) DATI REPORT 61NT tMonth} 10 VITAL RECORDS (DlYJ (...~