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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, .. 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