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Home My WebLink About07-0639Katherine A. Procopio 141 East Main Street Mechanicsburg, PA (717)691-9112 k~rocopio@comcast. net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. PROCOPIO, Plaintiff v. No. 2007 - p (~ 3 9 ~r ~- I +cr~ CIVIL ACTION -LAW MICHAEL J. BRUNNER, Defendant 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 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 Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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, Pennsylvania 17013 (717) 249-3166 Date: February 1, 2007 By: Katherine A. Procopio 141 East Main Street Mechanicsburg, PA (717) 691-9112 Pro Se Katherine A. Procopio 141 East Main Street Mechanicsburg PA (717)691-9112 k~rocopio @comcast. net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. PROCOPIO, Plaintiff No. 2007 - Q (0 3 y L? v ~ 1 f~ ~~ v. MICHAEL J. BRUNNER, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Katherine A. Procopio who currently resides at 141 East Main Street, Mechanicsburg, Cumberland County, Pennsylvania since December 2001. 2. Defendant is Michael J. Brunner who currently resides at 1059D York Road Dillsburg, York, County, PA since December 1, 2006. 3. Plaintiff and Defendant have been a bona fide resident(s) in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 2006 at Baltimore City, Baltimore County, Maryland. 5. There have been no prior action of divorce or for annulment between the parties. 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 requires the parties to participate in counseling. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on or about December 1, 1006. WHEREFORE, Plaintiff requests this Honorable Court enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted, Date: February 1, 2007 By: Katherine A. Procopi 141 East Main Street Mechanicsburg, PA (717) 691-9112 Pro Se VERIFICATION I, Katherine A. Procopio, 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: February 1, 2007 ~' ~ Katherine A. Pro opio, Plaintiff r`~ n.,y ~_.. ~~ C~ ` --~' ~r~ ~7 r7 ~' ~ ~ r ?? t~ ~ ~ _ t C N ~:~ ~ -} .-~ ~ ~ ~ r _ .rt ~~ Katherine A. Procopio 141 East Main Street Mechanicsburg, PA (717)691-9112 k~rocopio@comcast. net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. PROCOPIO, Plaintiff v. MICHAEL J. BRUNNER, Defendant No. 2007 - 0639 Civil Term CNIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Michael J. Brunner, Defendant in the above referenced matter do hereby accept service of a true and correct, certified copy of the Complaint in Divorce filed in the above referenced matter, which was personally served upon me on ~F~'. !D Up Respectfully submitted, Date: ~ 2g~ 2007 Mic B Pro Se r-s ~ ~ ~ ~ -Fa - i 4 t ~ -~ ... ~ ~ . -.-, ~~ :~ ..... 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A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on February 1, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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 herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 5,h-1 f D7 Katherine A. Procopio, Plaintiff Katherine A. Procopio 141 East Main Street Mechanicsburg, PA (717)691-9112 k~rocopio@comcast.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. PROCOPIO, Plaintiff No. 2007 - 0637 Civil Term v. CIVIL ACTION -LAW MICHAEL J. BRUNNER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (c) AND ~ 3301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 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. § 4904 relating to unsworn falsification to authorities. Date: ~~ ~ 7 _ Katherine A. Procopio, Plaintiff k'`~ ° ~- `` ~ `'; ._..t ~4` ~ _. x. t_..~ A __ ~ Ti ~.: ~--~ { : j -- '.' ~. Katherine A. Procopio 141 East Main Street Mechanicsburg, PA (717)645-0178 k~~~rc~GOj~2C1!C(.%COT12C~2ti[.2'2~t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE A. PROCOPIO, Plaintiff No. 2007-0639 (Civil Term) v. CIVIL ACTION -LAW MICHAEL J. BRUNNER, Defendant 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 Decree in Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Cade. 2. Date and manner of service of the Complaint: A true and correct copy of the Divorce Complaint was served on Defendant, Michael J. Brunner, via Personal Service on February 10, 2007. An Acceptance of Service signed by the Defendant was filed on March 1, 2007. 3. As required by Section 3301(c) of the Divorce Code, Plaintiff and Defendant executed their respective Affidavits of Consent on May 21, 2007 by Plaintiff and May 17, 2007 by Defendant. The Defendant's Affidavit and the Plaintiffs Affidavit are being filed contemporaneously herewith. 4. Related claims pending: None. 5. As required by Section 3301(c) of the Divorce Code, Plaintiff and Defendant executed their respective Waivers of Notice of Intention to Request Entry of Divorce Decree on May 21, 2007 by Plaintiff and May 17, 2007 by Defendant. The Defendant's Waiver and Plaintiff s Waiver are being filed contemporaneously herewith. Date: May 21, 2007 By: Katherine A. Procopio 141 East Main Street Mechanicsburg, Pennsylvania 17055 (717) 645-0178 Pro Se I N T'H E COU R7' OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~A~hc~~t-e. A. ~or ~p~o p`a-~ f VERSUS Inli rl ~ ~ ~ Ylhc~ de ~~ndQ,~I F No. ZOD~-0(~3~i i il~tl.rw~ DECREE IN DIVORCE AND NOW, ~r IT IS ORDERED AND p DECREED THAT ~I~Y~Y1C. ~ ~~ fba-O PLAINTIFF, AND ~I~~ ~' ~~~~iV DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING GLAlMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT PROTHONOTARY YET BEEN ENTERED; ~~