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HomeMy WebLinkAbout07-0870Bryan K. Carl, IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Q ~ -Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE NOTICE TO DEFEND 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 within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. 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 Courthouse, Carlisle, Pennsylvania. 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBILE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717) 761-1274 kellymd@carrucoliandassociates.com Attorneys for Plaintiff Bryan K. Carl, IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, :PENNSYLVANIA v. NO. p ? - Y'°70 -Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE COUNT I-DIVORCE 1. 2. 3. 4. 5. 6. 7. Plaintiff is Bryan K. Carl, an adult individual, who currently resides at 315 Reno Avenue, New Cumberland, PA, 17070, Cumberland County, Pennsylvania. Defendant is Louise Ann Carl, an adult individual, who currently resides at 24 North Kister Street, Etters, PA, 17319, York County, Pennsylvania. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on December 24, 1992, in Schuylkill County, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. Plaintiff and Defendant have two children born of this marriage. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 8. This marriage is irretrievably broken. 9. 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. 10. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays Your Honorable Court to: a. Enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant; and b. Order attorneys' fees and such other relief as the Court deems just and reasonable. Respectfully submitted, CARRUCOLI & ASSOCIATES, PC ~~ Kelly aney Dick, Esquire Supreme Court ID. No. 93167 875 Market Street, Suite 200 Lemoyne, PA 17043 (717) 761-1274 Attorneys 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. Section 4904, relating to unsworn falsifications to authorities. Date: 8 d Bryan Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717) 761-1274 kellymd@carrucoliandassociates.com Attorneys for Plaintiff Bryan K. Carl, IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, :PENNSYLVANIA v. NO. ~' 70 -Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE WAIVER OF COUNSELING Bryan K. Carl, 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 my spouse and me to 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 counseling prior to a divorce decree being handed down by the Court. 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. b A~ Date: Bryan K. C Iv ,^ t'"3 ~~ ~ o p` ~~ ~ w ~ j~= t~ J ~` 1 CTS t~_ .~~ ~-< N m _~ CJl .,0 N .~` © '~r~ ~~ ' .l S.^j ~r ~~ K Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717) 761-1274 kellymd@carrucoliandassociates.com Attorneys for Plaintiff Bryan K. Carl, IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, :PENNSYLVANIA v. NO. U~' - ~~() -Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. -/ D ~ Date: e endant a~lN.n,sr v. pf ~ ~ 7~% Mailing Add ess ~ ~ C~ o -~ T..1 ~~'. 'Ti .-.~ ~ dip! i = ~_. -` i"*"i CSI -TI ~ , = % ' ~ ~.a~__ _~ C~~. 'r> ~_' ~ t'tt PV MARITAL SETTLEMENT AGREEMENT Bryan K. Carl -age 43, February 13,1963 Ryan M. Kuhn -age 18, December24, 1988 Bryan S. Carl -age 12, July 29~ 1994 Brandon A. Carl -age lo, July 2,1996 Louise A. Carl -age 4~, March 24,1965 The property at 315 Reno Avenue, New Cumberland, Pa. l~o~o is occupied by Bryan K., Ryan, Bryan S. and Brandon and will remain occupants of said property. Property will be refinanced into the name of Bryan K. Carl only and Louise will receive $3,00o in cash at time of settlement as agreed on by both of us. The children will not be disputed in any manor. Bryan And Louise both agree on shared custody. Garages have items in that belong to George Crum, Louise's father, and will remain there as long as necessary. Both Bryan and Louise agree to this. There are no vehicles involved to be divided. There are no monies to be divided. There are no life insurance policies, premiums or anything that remains binding to be divided. Bryan Keith Carl Date: /5/0~ uise Ann rl -`~~--- Date: 2/5/0 ~ o ~ "r't ~ `~ C~' ,,,,,,, t,~ s-r~; f } ; C ..~.~ ,. .-'- _, ~ -~t'rt ~'f~4- ff«. ~. p .,.~ i... - ~ l~J ft' + ...~.,,} 1~..} ~. ,~,~ ~ ~"°\i ~ i }'' \ nw~ 1 Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717)761-1274 kellymd@carrucoliandassociates. com Attorneys for Plaintiff Bryan K. Carl, IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, :PENNSYLVANIA v. NO. U~- - ~~"~- Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on ~ /'~ d ~ , 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 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: c5 ZZI~ Bryan K. Carl rJ~~' ~ .- J k'.'.... J'.. frC-' ~ ~~ w.1~~, t~ ~~~ ~ ~` ~~ Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717)761-1274 kellymd@carrucol iandassociates. com Attorneys for Plaintiff Bryan K. Carl, : IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, :PENNSYLVANIA v. NO. b~"" ~~~ -Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) 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. Section 4904 relating to unsworn falsification to authorities. Date: SILL~d~' (.~~''~~ Bryan K. C ~ ~ ^' ° C] -st ~.~ [ ~ ~ ~ rys~ ,~ xar -C , ~ Ur ._ _ rte. `_:. ~ -~ , ~: ~ ~ --~ Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717)761-1274 kellymd@carrucoliandassociates.com Attorneys for Plaintiff Bryan K. Carl, IN THE COURT OF COMMON PLEAS Plaintiff. OF CUMBERLAND COUNTY, "" :PENNSYLVANIA v. NO. ~~~- ~~~ -Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on ~ ~S` ~~~. 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 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: ~ ZZ~D Louise Ann Carl ~ ° ..~ ~ ~. ~„ ~,J ~~ _.. ~ '~ ~- : '~ aJ ~3 .~-` ~ C~? ~ .° a , .~ Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoli and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717) 761-1274 kellymd@carrucoliandassociates. com Attorneys for Plaintiff Bryan K. Carl, Plaintiff. v. Louise Ann Carl, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . NO. U~- ~~~ -Civil Term CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) 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. Section 4904 relating to unsworn falsification to authorities. Date: ~ ZZ ~~ ~ _ Louise Ann Carl "` C) E ±';'I r ==i 7~' ~.. ~ ~ ~- ~ y Y ""4 ~ y ~ ~~~~``'~`f[~~~ _ i ~ + Kelly McNaney Dick, Esquire; ID No. 93167 Carrucoii and Associates, PC 875 Market Street, Suite 200 Lemoyne, PA 17043 (717)761-1274 kellymd@carrucoliandassociates.com Attorneys for Plaintiff Bryan K. Carl, : IN THE COURT OF COMMON PLEAS Plaintiff. : OF CUMBERLAND COUNTY, :PENNSYLVANIA v. : N0.07-870- Civil Term Louise Ann Carl, :CIVIL ACTION-LAW Defendant. : IN DIVORCE To the Prothonotary: PRAE,CIPE TO TRANSMIT RECORD Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Acceptance of Service dated February 19, 2007. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: By Plaintiff: May 22, 2007, By Defendant: May 22, 2007. 4. Related claims pending: NONE. S. Date Plaintiff s Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 30, 2007. Date Defendant's Waiver ofNotice in §3301(cj Divorce was filed with the Prothonotary: May 30, 2007. 6. Plaintiffs Social Security number 176-4$-$392; Defendant's Social Security number 161-62-0479. r Date: June 1, 2007 ~ ~ Kelly M. ~ k Attorney for Plaintiff o ..- ~~° ~ E-- ~~~.. ~ ~ .. •, a R ~ ~ j~~ ~ ~ ~ ~ a... ..,,-~ ~~ r .t'- ~~ ~ ' ~ • ~ "" = I N T'H E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BRYAN K . CARL `~ ~' ~~ Plaintiff VERSUS LOUISE ANN CARL Defendant ~] O , 07-870 CIVIL TERM DECREE IN DIVORCE AND NOW, , '~+y~, IT IS ORDERED AND DECREED THAT BRYAN K . CARL AN D LOUISE ANN CARL ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAT NTI FF, DEFENDANT, 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 The Marital Settlement Agreement is not merged. BY TH ATTEST: ` J. PROTHONOTARY emu' ~ ~,.~ .tea ~''~ .~°~~ ~~ ~ - ~ ~~_ ~ ~~