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BRION P. MOMULLEN,
Plaintiff
IN THE COURT OF COMMON PLEAS O~'
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 98-1760 CIVIL TgRM
CIVIL AC1'ION - LAW
DIVORCE
PATTY K. MCMUI,I,EN,
Defendant
PRAECIPE O~' TRANSMIT RECORD
To the Prothonotary:
Tranllmit the record, together with the following information, to the court
for entry of a divorce decree;
1.
Ground for divorce I
Irretrievable breakdown under Section 3301 (c) of the Divorce Code,
Date and manner of service of ths complaint I
a. Date, April 6, 1998
b. Manner: Acceptance of ServIce signed by Defendant, Patty K. MCMullen.
Date of execution of the affidavi t of COllsent required by Section 3301 (c)
of the Divorce Code:
a. PlaintIff: July 7, 1998
b. Defendant: July 9, 1998,
QB
Date of execution of the Plaintiff's affidavit required by Section 3301 (d)
of the Divorce Code and date of ser.victl of the Pla:lntiff' s 3301 (d) affidavit
upon the Defendant:
a. Date of execution: N/A
b, Date of filing: N/A
c. Date of ser.vicel N/A
Related claims pending: No issues are pending. All issues have been resolved
pursuant to the Marriage Settlement Agreement between the parties dated June
26, 1997 which Agreement is to be incorporated into but not merged with the
Divorce Decree.
2.
3.
4.
5,
Date and manner' of service of the Notioe o,f Intention to file Praecipe to
Transmit Record, a copy of which is attached, if the deoree is to be entered
under Section 3301(d) (I) (i) of the Divorce Code:
a. Date of Ser.vice: N/A
b. Manner of Service: N/A.
QB
in Section 3301 (c) Divorce was filed with the
Oats WaJ.vsr of Notice
Prothonotary:
a. Plaintiff's Waiver:
b. Defsndant's Waiver:
July 15,
July 15,
1998
1998
("
\
CL ,
Road
17011
S t IO # 32112
Phonol (717) 737-0100
Fax: (717) 975-0697
Attorney for Plaintiff
DIANE G. RADCLIFF
3448 TRINDlE ROAD
CAMP Hill, PA 17011
(7171737.0100
~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BRION P. McMULLEN,
Plaintiff
v.
NO. CJ r" I 7 i.. CJ C~;,:..f .T(........
PATTY K. McMULLEN,
Defendant
CIVIL ACTION - LAW
DIVORCE:
COMPLAINT
AND NOW, this aL~~ day of _~!...e....., 19!1r , comes the
PlaintIff, BRION P. McMULLEN, by his attorney, DIANE G. RADCLIFF,
ESQUIRE, and files this Complaint in Divorce of which the following
is a statement:
COUNT I: DIVORCE
1. The PlaintIff is BRION P. McMULLEN, an adult individual
residing at 3301 Walnut Street, Camp Hill, PA 17011.
2. The Defendant is PATTY K. McMULLEN, an adult individual
residing at 1913 Arlington Street, Unit 2, Camp Hill, PA
1'7011.
3. PlaintIff and/or Defendant have been bona fide residents of
the Commonwealth for at least six (6) months previous to the
filing of this Complaint.
4. Pla.i.ntiff and Defendant were married on August 23, 1990 at
Baltimore, Maryland.
5. There have been no prior actions of divorce or 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
. ~.
IN THE COUR'f OF COMMON PLEAS OF
CUMBrmlJAND COUNTY, PENNSYL,vANIA
BRION P. McMUL,L,EN,
Plaintiff
v.
NO. 98.1760 CIVIL TERM
PATTY K. McMUIJLEN,
Defendant
CIVIL ACTION - L,AW
DIVORCE:
AI1flIDAVITOlICONSENT
1. A Complaint in Divorcc undcr Scction JJOI(c) of the Divorc(1 Codc was filcd on 3/J 1/98.
2. Thc marriagc of Plaintiff and Dcfcndant is irrctricvahly hrokcn and nincty (90) days havc
clapscd from thc datc of filing and scrvicc of thc Complaint.
3. I conscnt to th(1 cntry of a fillal [)corcc in Divorcc aftcr scrvicc of notiec of intcntion to
rcqucst cntry ofthc decrcc.
I vcrify that thc statcmcnts madc in this Afl1davitarc truc and corrcct. I undcrstand that false
statcmcnts hcrcin arc madc suhjcct to thc pcnaltics of 18 Pa. C.S. Scction 4904 rclating to unsworn
falsification to authoritics,
Dated:--1bJ.il_
~~J~~-
DIANE n RAIX'1.I1'1'
.144M TRINlll.li ROAIl
CAM!' HiLl..!''' 17011
(717) 7J7.0\lJO
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