HomeMy WebLinkAbout01-06614
.
.
.
.. .
.
..
.....
..
:Ii ;+:;F./fi:f.
Of. :+::Ii :Ii:+: Of. :1:::1:;1;:1:
.
..
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
.
.
.
.
.
.
.
STATE OF
.
.
.
.
.
.
.
BRIAN L. BRUNNER;
Plaintiff
.
.
.
VERSUS
.
.
JULIA M. BRUNNER,
.
.
Defendant
.
PEN NA.
No. 01-6614
CIVIL
DECREE IN
DIVORCE
.
.
.
.
.
.
AND NOW,
~t't-t ~
.
, 2002 , IT is ORDERED AND
DECREED THAT
BRIAN L. BRUNNER
, PLAiNTIFF,
.
.
.
.
AND
JULIA M. BRUNNER
, 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.
.
.
.
.
.
.
.
.
.
.
if. :Ii:t: :f.
. .
.
By TH E IJJ~
ATT
.
'!~
/
PROTHONOTARY
:Ii"; :Ii "':tiff.
...
:Ii""'" :Ii :Ii;+; :f.
.
:Ii :Ii:f.Of.:Ii
J.
~~",
...
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
. "
.~
~. -~. ~ ,. ~'~-<-~ ,-~.~~"'~~-~
I/g
S.1'
9- &, '0,)
tf ~ .t?,;J
..,.
-
,,-' _, ,C,_ e_ ."'" ~ _ ,g,J
~ ~<~,.~, =.~ '___~'..,~""O"'_""""_ "'_=i..i~~~"""
, .
" ,'<W.- ,.
\&:" . ,,';',~
.
w~~~::?~
11~~~~
, r_~~~1[~~~fIl~~~'-:'F~%'f;.';j::Wi,<w"g~lf~~~~~
~
~~~'~ ~
.1(1
. ,
,
. ""~"h~"$i"
.h
,<c,
BRIAN L. BRUNNER
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
NO. 01-6614
CIVIL
.
.
JULIA M. 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 divorce decree.
1. Ground for divorce: Irretrievable breakdown under Section
3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: On November 27,
2001 by U.S. certified mail. A certificate of service has
been filed with the Prothonotary.
3. Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Code:
by plaintiff on
August 7, 2002; by defendant on March 22, 2002.
4. Related claims pending: None. No economic claims have been
raised.
5. Date plaintiff's waiver of notice in Section 3301(c) divorce
was filed with the Prothonotary: August~, 2002.
Date defendant's waiver of notice in Section 3301(c) divorce
was filed with the Prothonotary: April 22, 2002.
J- ~/ /~~
, ,
Kent H. Patterson
Attorney for the Plaintiff
Dated: ~r?-~ 2Cl::/;>-
221 pine Street
Harrisburg, PA 17101
(717)238-4100
~~ .".
"'~*,>i' :,":"0',;-,,-. "';;_"i!~'-~1!!l~'~~~*.~~!f.f;i~2,'_M'wi"diutl~*;_1--"W~f"""'" :
""
_ ,_"_,~,"""J~ ,.. .,,_,....< '.' .,""". ~,_..?"',_ ~
-\
1-
->-~ '
~ 0 0
N -'1
"'" --I
~W c i;~;n
m rn
::0
d5~ N ";2m
1".' -9.6
~'-~
3;0 -0 ~C=H
:x (:)0
5>8 r- 2m
Q'
Z :;;;
::t (,) :3!
W;
"'.---"-~
.' '-'-'- .~, ~
"
~
~"~~
~,",".,. ,'"
.~~:,
H
"
c'
BRIAN L. BRUNNER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6614
CIVIL
JULIA M. BRUNNER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
1. A complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on November 26, 2001.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the complaint.
3. I consent to the entry of a final decree in divorce after
service of notice of intention to request entry of the decree.
4. I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling. Being so advised,
I do not request that my spouse and I participate in counseling
prior to a Decree in Divorce 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. 54904 relating to unsworn
falsification to authorities.
~h/o~
.
Date
e~L;J~
BRIAN L. BRUNNER
~'i
~~~"~lfJr:h;;;:~i};K~'~'l?l;j;{:1!,i~illii<;~8:~&J'~*~"':<\ "'~\::&"')~\ jH-A'n"",,"i<.~:fi.,~..fu1m;;&._i~~~~~"~."""-liifll~lI'~ ,-~, "~.m
1tiIlhI..
,
i 0 0
N .."
",. .....
j~ c::: :::r:
C') ,.....,:n
_:(:1 .' r--
N --171
~~ 1'-:' 6~
;.:::c; ." ...;....f....;r!
.J..--n
~o :x 0--
--0 r:- :z:~_
J>c 8
:s 5:;
-< r-:> '<
'II
~ .' .., ~, ."
~ "
~ -
.' ,,~ ,,~
,-,
.
.'
BRIAN L. BRUNNER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6614 CIVIL
JULIA M. BRUNNER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 4909 relating to
unsworn falsification to authorities.
1!7!() ~
Date
tJ~~t~
,
BRIAN L. BRUNNER
"
""~vc"
f:
)~~?{"::;li"l.~~,~~iM;;mt~J4fu~"';;"N:rlii;-"':Vi,';;i#&'L':'_*,,;'1o~,,*,,-m'Jl!dl;,}&:/wJg'I" '.......-~~~"'i"; ~-lli:!1i1iJt#ill;~J'.l!f.&1,::,iLjgjl~jr'Jji~f:.
.
"
. "~~~ '>',,-
l~;
.~ 0 0
N -n
Do :t
'~!B ~ ~. -
-
G") tl1dJ
,
.'~~ N -.~rn
N ~cry
G' <;jO
!.<: " ~r: =R
~Q 3: Q'C)
::s:g r- ern
~ ['\;i ~
-<
ES
ef
-""
;,...;,.,d
.
'<, ~I -'&'- - ,<
.,;m'....;;.;.-~ "-"'-I>;f~",'
" ,~
BRIAN L. BRUNNER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6614
CIVIL
JULIA M. BRUNNER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COT~SELING
1. A complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on November 26, 2001.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the complaint.
3. I consent to the entry of a final decree in divorce after
service of notice of intention to request entry of the decree.
4. I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling. Being so advised,
I do not request that my spouse and I participate in counseling
prior to a Decree in Divorce 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. 54904 relating to unsworn
falsification to authorities.
3 - ~ 0\ - () d _
Date
.
I
e . ",' ~,~_" " ,'~"'-"
"-", -~.i~L/,
'.-
".'
BRIAN L. BRUNNER
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6614 CIVIL
JULIA M. BRUNNER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 4909 relating to
unsworn falsification to authorities.
Jj - ('*~ '-' (Jr~(
Date
-n!
"i~t~.iM~~~Jl't~~~>Fi~~~jJa~,_(Sf!I\*",,~,,~,'i~'i/';_t~"~~j#i~#~~~.~iw"c>:..~-'''''-<--l.JIiII'.iS._rJ
.- ~ .
j
.I-~,^,
"-~-
"." JG,"- '. "'h"',"', " c,'",",'. . " .. -,- .. .J',,,,_ r~";
. , "
o
~
-wei:-'
rf1jT--;
~~.
r::::c.
it~
:z
.-t
--"
D
N
",.
'0
';0
N
N
o
---n
-0
..;.;~
~::J
Alp
"nm
',0
(~'-i. !
.~~
-I
. :>-'
:z
N
C"
(j\
p;.s
61/
'-'
'0' ~,
.,
'L"~
,>,-;. nl.>!il~'~~""
.
." .)
.~.,.
1'J-"-'-7'
BRIAN L. BRUNNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01- 1.l.1'1
CIVIL
JULIA M. BRUNNER,
Defendant
IN DIVORCE
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 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, Cumberland County Courthouse, One
Courthouse Square, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE AR 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.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
- . J_ - - "" -,"-- --'liiI'a
-".i'jJ;,-~jj,*uli-JT.'.-;'
" J
,....
BRIAN L. BRUNNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01 -}.p(, I'{
Ci vil
JULIA M. BRUNNER,
Defendant
IN DIVORCE
COMPLAINT
AND NOW comes Plaintiff, by his attorney, Kent H. Patterson,
and files this Complaint in Divorce, based upon the following:
1. Plaintiff, Brian L. Brunner, is an adult individual
residing at 121 Pine Hill Road, North Middleton Township,
Cumberland County, pennsylvania (Carlisle, PA 17013) .
2. Defendant, Julia M. Brunner, is an adult individual
residing at 175 East High Street, Apartment No.4, Borough of
Carlisle, Cumberland County, Pennsylvania (Carlisle, PA 17013).
3. Plaintiff and Defendant have been bona fide residents in
the Connnonwealth of Pennsylvania for at least six (6) months
previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on September 7, 1991
in Carlisle, Pennsylvania.
5. There have been no prior actions for divorce or annulment
between the parties.
..",
'::-.
I':
!1
-"v'
'-,.i~,:;,
,
.
"
6. Plaintiff and Defendant are both citizens of the United
States of America.
7. Defendant is not a member of the Armed Services of the
United States or any of its allies.
8. Plaintiff avers as the grounds on which this action is
based are that the 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 participate in counseling.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a
Decree in Divorce dissolving the marriage between Plaintiff and
Defendant and such further relief as the Court may determine
equitable and just.
~J/~-
. .
Kent H. Patterson
Attorney for Plaintiff
221 Pine Street
Harrisburg, PA 17101
(717) 238-4100
!,:;;i
~""
.J
"
. .
.
..
. ,
VERIFICATION
I, Brian L. Brunner, verify that the statements in the
foregoing Complaint are true and correct to the best of my
knowledge, information and belief. I understand that false
statements herein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
(J~~ (J~
Brian L. Brunner
J;J Jf) /6 J
Date' ,
. ,
.L~"'J~:;'.
~~~~i.~~~~~f,jlai~k11\j;w;;.o-fJ "U';'8";"Ii.i;;~;-",,.i,_;,"":.,,;ij,.g;';~'i~_,",~tM"ii~i~~_~t""._~.~;...."c.,.....
~iifj'yi"'~"
,="~
'~~<'l~t
"
.
fY ~
~ 0 0 C)
C 'T1
5;'". Z
~ ~ }t -OW 0 +-n
mCL ~"':: I:',,;:'
Z,_L!
""[- l'> -
. ... 05;1';:: 0-'
-</ =-.:::l~>
"- ~Cj
..... ~ ... -0
-l1> ;E ~-- :F.:: i~rA
<"> '" -- ZL
~ (;> )>Q S'9
...... ,,_- ~
z
~ =< ':..., 5:J
'.0 -<
"".,.,"'.
..". ~~"_.1?__~,_,,,._=,_ >,_o>_~",,",< ,< .'-, o,~
-
~- ,.
- .- ~,
""~
"''''1'
BRIAN L. BRUNNER,
Plaintiff
v.
JULIA M. BRUNNER,
Defendant
"
.~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-6614
CIVIL
IN DIVORCE
CERTIFICATE OF SERVICE
I, Kent H. Patterson, attorney for Plaintiff, hereby
certify that I served Defendant with the Complaint in Divorce on
November 27, 2001 by mailing a copy of same by U.S. Certified
Mail, postage paid, addressed to Defendant as follows:
Julia M. Brunner
175 East High Street
Apt. #4
Carlisle, PA 17013
Attached hereto is the sender's receipt and the return
receipt card which is signed by Julia M. Brunner and indicates a
date of delivery of November 30, 2001.
~r~
kent H. Patterson
Attorney for Plaintiff
221 Pine Street
Harrisburg, PA 17101
(717) 238-4100
, .' ~~~"~~'"
>
-
"" "0
"~~
~~~
. '.
.
BRIAN L. BRUNNER,
Plaintiff
~
~~"'",~I"~"'-.-'<;
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
01-6614
.
.
JULIA M. BRUNNER,
Defendant
IN DIVORCE
,.."
U1
""
-ll
CARLISLE PA 17013
""
""
-ll
fT1 '
Postage $
$0.57
$2.10
$1.50
$3.20
Certified Fee
,,;'" Return Receipt Fee
~. ~,(Endorsement Required)
t::J, Restricted Delivery Fee
d . (Enddrsement Required)
Total Po~tage & Fees
$ $7.37
Cj
Cj
~ R~n.t's Nam" (please Print Clearly) (to be complet by
nmn/,!,!.J.fLf!1'n'll&U.r,1NJ;';J'Lmmnmnmmnnnnmmnm
0-' Street;.Apt. No.; or PO Box No.,
~ L'1:S.'j2,mt/lfi1HmSLn"..{)PL&!.':1nmnnnnnnmm.
L-' Ci, State, Z/P+4
"" (.,1: PA '1-0 I
Civil
~ j
"0 . Complete items 1 and/or 2 for addit'
'w . Complete itelTIs 3, 4a, and 4b.
~ . Print your name and address on th
_ card to you.
el) . Attach this form to the front of the mail
~ permit.
. Write "Return Receipt Requested" on _
<<II . The RetiJrn Receipt will show to whom the a' I
:5 delivered.
, ...,.., ,
i ~ alsdwt5t1itb)r-ecei~e:the
following services (for an
extra fee):
1. 0 Addressee's Address
2. Sf Restricted Delivery
Consult postmaster for fee.
4a. Article Number
c
o
'tl,
,!
"
Ii
E
G'
'"
3. Article Addressed to: 'U
::Tt.c./..Ifl rn. ORWVNEIl...
175 E. Hu.,H ST/2.EET
APT. #4
CAflU S L-€ fA 1'1013
I
IlilCertified
o Insured
o COD
8. Addres e's Address (Only if requested
and fee is paid)
10.........-022. DoMesticF'lelurn Receipt
ai
u
~
"
'"
a
'ij
u
"
~
~
;;
a:
..~
.1ii
~
-
.2
~
g,
..
C
l\l
'"
...
~i~!imiil:'J~_~&$~jJl~~r~J::~~'ii!:i~-~A~.'1t!,i';-Y:S<';J{f%~'"
~"~-< ~--"-~~--'
- , "~" - ,~
;",,:,-",-,,'
':;:::',"'mi~:~"';"i_;,,-,;,~~__L_:'
,,,.
'--'-"~~~1OiJ"-.I~""'""jj--'-'j;;f_'-
't"J.
("::
~~.
~O
ig
~
:.<.
,-'~
~~
". ,.,-.
.
1-
.' .
.
o
."
_,~-t
0"~
::';?,\:s
~);~~:)
-:~1'~~
0::1"
,_..I
...~;
~
N
.."
::J:
r::-
o'
.,,"",
-
";;.,."
...~~
~.
.-