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Home My WebLink About07-0487 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW ~No. 07-4~7 c..rJl\+tr"- : IN DIVORCE NOTICE BRENDA K. BROWNEWELL, Plaintiff MARK D. ISENBERG, Defendant 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. 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW ~ No. 07"" Lf%'1 c-\ vi I ferl"\- BRENDA K. BROWNEWELL, Plaintiff MARK D. ISENBERG, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Brenda K. Brownewell, who currently resides at 777 Baltimore Pike, Gardners, Cumberland County, Pennsylvania, since June 2005. 2. Defendant is Mark D. Isenberg, who currently resides at 752 Petersburg Road, Carlisle, Cumberland County, Pennsylvania since November 2002. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six (6) months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married in a Common Law Marriage on July 9, 1993, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Neither party is a member of the armed forces of the United States of America. 9. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & WHARE Date: q-- Michael O. Palermo, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court 1.0. # 93334 Attorney for Plaintiff - VERIFICATION I verify that the statements made in this Complaint 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 falsification to authorities. Date: /'/d~ /()7 I ~-' / .~. ~..., . ~ ~ '4. ~ ~ - '- '-1) o.q - ....j <S" ~ 0\' ~ ....j ~ ~ C> "- ~ ~ o c <~ ;:-} r"'~ ~:l(;< '-- ;?~ -:J " ~ 25 0 -... " ~ ~ :;:: r11 :0 N -oFn w ~GO v (;j 5~' :::: (~ -H :7(-) ani " ~ '-'V :-JJ o -< ~ Brenda K. Brownewell, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION LAW :No. 191 - lJf7 Mark D. Isenberg, Defendant : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 Cd) OF THE DNORCE CODE 1. The parties to this action separated on August, 2003, 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. 9 4904 relating to unsworn falsification to authorities. Date: !j d5Jo 7 /7 o G -:;"::::". ~ ~--r\ ~.~ -=bQ ~ (-;?;Q, ...... ~.r -,.-, ~56 ';:::'(\i '9\ ..,. ~.2. o V' ~ ':.3 <-- "t"" ';.~....... ..- :?,. > - ,. MARK D. ISENBERG, Defendant : IN DIVORCE BRENDA K. BROWNEWELL, Plaintiff : IN THE COURT OF COMMON P : CUMBERLAND COUNTY, PENN : CIVIL ACTION - LAW v. : No. 07-487 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of I , 1. Grounds for divorce: irretrievable breakdown under ~ 3301(d) of the Divor~ I 2. Date and manner of service of the Complaint: Certified Mail/Return Receip i i Delivery, 1/30/07,2/13/07,2/18/07, not claimed. First Class Mail, 1/29/07,in t returned. Exhibit "A". 3. Related claims pending: None 4. ( 1) Date of execution of the Plaintiff's Affidavit required by ~ 3301 Divorce Code: 1/25/07 (2) Date of filing and service of the Plaintiff's Affidavit upon th~ espondent: i Filed 1/29/07, Served 1/29/07. 4. Date and manner of service of the Waiver of Notice to File Praecipe to lrr nsmit Record, a copy of which is attached: Served on Defendant by certified m~i return i receipt/restricted delivery on 1/29/07, not claimed and fust class mail on ~ returned. Exhibit "B" ~i Michael O.Palermo, Jr., Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID No. 93334 Date: February 27,2007 ~ -r}~r I''" . ~7 :'--7 0J -......., ,,"., ~t~ ..r:::~- '-"_ c;_~ ~:: -/" :::;, -< r--.) C.'::) C;1 --' -,-, ri oJ N .....J o -n .-l +:!J 1,1.-... L.-. -rJ'",,!,.,: --:, ~~~j ~:~~> -0 .,..,.....7'" -"" '-'1.?;.;:\ :c:::' (to '::~i )? ~ N CO BRENDA K. BROWNEWELL, Plaintiff , : IN THE COURT OF COMMON P~ AS OF : CUMBERLAND COUNTY, PEN1'i-r: YL VANIA : CIVIL ACTION - LA W v. : No. 07-487 MARK D. ISENBERG, Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Linda J. Jumper, Paralegal for Rominger & Whare Law Firm do hereby qe ify that I i I I served a copy of the Divorce Complaint upon the following by depositing same in ~ e United i States mail, postage prepaid, on January 29, 2007, at Carlisle, Pennsylvania. The ~ mplaint was also sent certified mail/return receipt/restricted delivery addressed as follows: Mark D. Isenberg 752 Petersburg Road Carlisle, P A 17013 Dated: February 27,2007 ~p,-.J ~ pi ~ 11'~ ppP ,~or ~1 or~llI" feD ~~ Joo1 cp., C-I),"'~' p t3 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ ~ Brenda K. Brownewell ~ ~ ~ ~ ~ Plaintiff VERSUS ~ MArk n T!';pnhPrg Defendant ~ ~ PENNA. No. 07-487 Civil Action DECREE IN DIVORCE ~ ~ :to ~ :to :to ~ ~ :to ~ AND NOW, -7Y? ~C..iV t- " ,.2007 , IT IS ORDERED AND DECREED THAT Brenda K. Brownewell , PLAINTIFF, AND Mrlrk n T!';pnhPrg , 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; ;f. ;f. ;f. ;f. None ;f. ;f. ~ ~ ~ ~ ;f. ~ ~ ;to ~ ;to ff. PROTHONOTARY ff. ;f. ~ ff. J. ..k~ ~ 0pu, ~r/ 'if" Z, ~ J,jW' pJ .' . . .' ... '.... '. ','. ,.,' . (0- b-C LO' P-[: