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Home My WebLink About01-0688 FX _r._ , -- ~~~ :". . . . . . :+: ;Ii ;Ii ;Ii ;Ii;li :+: :+: ;Ii ;Ii;li ;Ii;li;li;li ;Ii ;Ii ;Ii;li :+::+: ;Ii:+:;Ii . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY . PENNA. . . STATE OF . . SUSAN M. BROWN, Plaintiff No. 2001-688 . . . VERSUS . . BRETT K. BROWN, Defendant . . DECREE IN DIVORCE . . .,.;t (,: ,) /) A."'" . 'JOI>/ , IT IS ORDERED AND . . fIr.~31 SUSAN M. BROWN AND NOW, DECREED THAT , PLAINTIFF, . BRETT K. BROWN . . AND , 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; NONE. . . . . . . . . . . . PROTH ARY :+::+::+::+::+::+: :+::+: :+::+::+::+: '--'-'. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . !?d ~"O""H " _ U , ~-'~".". ,. -, ' '''.""",,, ,-, ..5':,3'1- C!( .5'51 '01 "'-~ ~, -- ~ - - - - M~m~ zf; 4.Q;J/ ~~;;}-~, .. ~ '" '., '. <'~'~~__"" ',_,', ""-""~'""r~~,'r$:,~!III,. -- <~'-~~~ "'_~"Vr -~"'1"~-~"^~ j '."--'..:j "e"' "'0>'", : - """,';,t-, ,,~-.- (-, -" - ~~" . SUSAN M. BROWN, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01- &~ l' CIVIL TERM BRETT K. BROWN, Defendant : CIVIL ACTION - LAW : IN DNORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 , ' - -~_ . m'" '.. u', . SUSAN M. BROWN, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO.01- ,,~? CIVIL TERM BRETT K. BROWN, Defendant : CIVIL ACTION - LAW : IN DNORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Susan M. Brown, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Susan M. Brown, is an adult individual who currently resides at 657 Grahams Woods Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Brett K. Brown, is an adult individual who currently resides at 135 Oakhill Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 2, 1992 in Cumberland County, Pennsylvania. 5. There have been no prior aGtions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. -., '" I 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken, WHEREFORE, the Plaintiff, Susan M. Brown, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. S 3301(c) or 330l(d) of the Divorce Code. Respectfully submitted, Date: ':)-R, ~O l mas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ,;--,-"---- -~- ~ - COO""~ - " .,."~' -.<' - _,-I --"','-"~ _" -X;.- "'^. -'-<'-,~:'_ -, ,;,'C ".' - ~:";"J;' I:;;;. '~ -'---.c'd: 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. S 4904, relating to unsworn falsification to authorities. ~~ --1;f' 6~---- SUSAN M, BROWN, Plaintiff ~~, ~ [, ~'^",,_.', ,;,.' ,-,~- ,-,,~ ':::' . i ' ., SUSAN M. BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-688 CIVIL TERM BRETT K. BROWN, Defendant : CIVIL ACTION - LAW : IN DNORCE AFFIDAVIT OF SERVICE AND NOW, this 6th day of February 2001, comes Thomas S, Diehl, Esquire, Attorney for the Plaintiff, Susan M. Brown, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Brett K. Brown, at 135 Oakhill Road, Carlisle, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on February 5, 2001. Respectfully submitted, .'.....~_..- (J'"! " / i ) I,', / ! /..,./"'~' , Thomas S. Diehl ' Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX I \ "-L.I->_ '''- ',' "~~, 1 I ........-... D"'" (Endorsement ReqUired) l:I C ResbtctedDelJve1yFee c::J (Endorsement Required) Total Postage & Fees Postage. $ .55 1.90 nJ <0 I'Tl <0 I'Tl r- U'J U'J Certified Fee l:I nJ ~ rNami:m'EWdK' :'e~e completetl by maIler)' ,/ II'" SfiHf~'ii~limttN~OAn '_.~...~_._,....,..-.._'_..._-..- II'" ~ CiIy.~E;-'PA17of3-"----""--""- 1.50 , r 3.20 $ 7.15 PS Form 3800, JUly 1999 See Reverse fo\ Instructions · ~~:~~i~=~~~il~~i,'~,"'D',' ' . Print your name ;ttmJJX;I)~I~ sothatwecan,return,~ :,' R.-ftV . Attach this card to thUi&lltlhVrliilitlcl. or on the front il space permits. ' 1. Article Addressed to: " , Is delivery addreSs diffelont (rom _ 1? If YES, enter delivery address below: BRETT K. BROWN 135 OllKHILL ROAD CARLISLE, PA 17013 3. Service Type XI. Certified Mail 0 Express Mail o Registered 0 Retum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2, Article Number (Copy from so/Vice label) 7099 3220 0009 5573 8382 PS Fonn 3811. Juiy 1999 Domestic Retum Receipt 102S9S-00.M.09S2 . - - I I 1 .~ I .1.... . ~ \j~ ilii FiU:lJ-(;fHCE OF Ti..F :- ;-:~,:~::THC~\:OTARY 0\ FES -8 IHi II: 16 CUMBthi~<~D COUNTY PE~lNSYlW\J\jiA " ......",""" ~ - . , ,,~, '" . .; SUSAN M. BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-688 CIVIL TERM BRETT K. BROWN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint In divorce under S3301(c) of the Divorce Code was filed on February 2,2001. 2. The marriage of the 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. S 4909 relating to unsworn falsification to authorities. Date: 5 119/;;'001 . ~ ~b~fft ~.~ Susan M. Brown, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. I consent to the entry of a Final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 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. S 4909 relating to unsworn falsification to authorities. Date: .5"'- 19 -0/ ~~'^- 7r-r ~ Susan M. Brown, Plaintiff I I I j ~;' /-'/ uf;'J ""Iq' ,.3 r;,:i I (,_ r,' 'I""'.. r-r' r'U L:..:1-..: CUtAGc.f'{i.../~\JO COUNTY PENNSYLVANI,i\ f ~ ,..,,- '. """ ". .. SUSAN M. BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-688 CIVIL TERM BRETT K. BROWN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint III divorce under S3301(c) of the Divorce Code was filed on February 2,2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe Complaint. 3. I consent to the entry of a Final Decree intention to request entry of the Decree. Date: WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I. I consent to the entry of a Final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I veri false statem falsificatio Date: -,"" ~ , ::'Cir',{: 1I',.1l.- " "-'R"Y '"'''1''' . ' l!'~i_:I{"', "'/ "''f "'9 ''''/') -n LJ I i'.,~; J L' l"'rl f~: ~)... C"ll,',r.~... ';"; [";\;;-'j ('c('jiJ.~<rfY tnJ'_LI jG 'i ;;'~ -"-',,..i, 1"1 PENNSyLVANiA I I I J '~ --~ .;~ ~ ,>;! W ~ i I ill , ; ~ ~~"''''-=, ~~ '... - ~, SUSAN M, BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 01-688 CIVIL TERM BRETT K, BROWN, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following inforination, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under S 3301(c) 33€lI(d) of the Divorce Code, (Strike out inapplicable section), 2, Date and manner of service of the Complaint. Service was made on February 5, 2001 by certified mail, restricted delivery signed for by the Defendant. 3, (Complete either paragraph (a), or (b),) (a) Date of execution of the Affidavit of Consent required by S 3301(c) of the Diyorce Code: by the Plaintiff: May 19,2001; by the Defendant; May 22, 2001. (b) (1) Date of execution of the Plaintiffs Affidavit required by S 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant; 4, Related claims pending: None, 5, (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by S 3301(c) of the Divorce Code: by the Plaintiff: May 19,2001; by the Defendant: MllY 22, 2201, Date: May 24,2001 I I ! I 'i :lIJ ~ ; I I Ii I I I J , !:Ti\flY r!it~~PiV?q Pt,j/2:sn L.. ,,,~., ..... "" . j i ..." C'u' 11'\i:,';'fF;: :,j',T', C'(';U,uyy """""."'-f, ,__ '-./ 1"4 PENNSYLVN~Ii\ \ , ~