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Home My WebLink About07-1975 CHRISTOPHER J. SANTANNA, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. (2t u-tL l S2-. BROOKE S. SANTANNA, CIVIL ACTION - LAW IN DIVORCE Defendant 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 any 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 Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 32 South Bedford Street Carlisle, PA 17103 Telephone: 1-800-990-9108 717-249-3166 Date: 41cl 1,26d By: Kelli . Bro well, Esquire Attorney I.D. # 90597 The Law Office of Kelli J. Brownewell 319 South Front Street Harrisburg, PA 17104 Telephone: 717-433-2860 Email: kbrownewell@comcast.net (Attorney for Plaintiff) CHRISTOPHER J. SANTANNA, Plaintiff V. BROOKE S. SANTANNA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 19 76' (ZW; ? CIVIL ACTION - LAW IN DIVORCE COUNTI COMPLAINT UNDER SECTION 3301(c) and 3301(d) OF THE PA DIVORCE CODE AND NOW, comes the Plaintiff, CHRISTOPHER J. SANTANNA, by and through his attorney, Kelli J. Brownewell, Esquire, who files this Complaint in Divorce, alleging the following: 1. Plaintiff is CHRISTOPHER J. SANTANNA, who currently resides at 211 9TH Street, New Cumberland, Cumberland County, PA, 17070. He has resided at this address for at least eight months. 2. Defendant is BROOKE S. SANTANNA, who currently resides at 331 Liberty Street #2, Bethlehem, PA, 18018 . She has resided at this address for at least 10 months. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 20, 2003 at St. Patrick's Cathedral in Harrisburg, PA. 5. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 6. The marriage between Plaintiff and Defendant is irretrievably broken and they have been separated since May 23, 2006. 7. Plaintiff further avers that Defendant is not in the Military Service or in any branch of the Armed Forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 8. The Plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests this Court to enter a Decree of Divorce. Respectfully submitted, KELLI J. BROWNEWELL, ESQ. q6 ' Date: / By: Kelli . Bro a ell, Esquire I.D. #9059 Cordier & Brownewell, Law Offices 319 South Front Street Harrisburg, PA 17104 Telephone: (717) 433-2860 (Attorney for Plaintiff) VERIFICATION I verify that the statements in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4094 relating to unsworn falsification to authorities. DD DA ier . Plaintiff p 4Q 70 W 73 ?J d _ _ % -- '!r D CHRISTOPHER J. SANTANNA, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-1975 Civil Term BROOKE S. SANTANNA, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on 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. §4904 relating to unsworn falsification to authorities. C All DAT ' 3 p C r._ e 1? CHRISTOPHER J. SANTANNA, Plaintiff V. BROOKE S. SANTANNA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1975 Civil Term : CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE PA DIVORCE CODE • R 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 statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. l ?D DATE PLA 0" 0 G. C= a d? . i r?o Z{ 1-> ti: --! 0 CHRISTOPHER J. SANTANNA, IN THE COURT OF COMMON PLEAS, Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-1975 Civil Term BROOKE S. SANTANNA, CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on hDri 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. 1 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. §4904 relating to unsworn falsification to authorities. ti a 1 CQ. - I P? DA DEFENDANT z?r F i Is i C. r o 0 CHRISTOPHER J. SANTANNA, Plaintiff V. BROOKE S. SANTANNA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-1975 Civil Term : CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE PA 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 statement are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DAT DEFENDANT G e rzl? 0 CHRISTOPHER J. SANTANNA, Plaintiff V. BROOKE S. SANTANNA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1975 Civil Term : CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the above captioned complaint in divorce on? (i 12007. I certify that I am authorized to accept service as the defendant. ? 4m&S -??,?i?? - DAT Brooke S. Santanna 410 Hammock View Savannah, GA 31410 r- ? Ic-j cri CHRISTOPHER J. SANTANNA, Plaintiff V. BROOKE S. SANTANNA, Defendant : IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1975 Civil Term : CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I . Ground for divorce: mutual consent under section 3301(c) of the PA Divorce Code. 2. Date and manner of service of the Complaint: Defendant received the Complaint on April 26, 2007, as evidenced by the Acceptance of Service. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divo a ode: by Plaintiff a00 ; by Defendant 4. Related claims pending: There is no marital property to be addressed. 5. Da Ti tiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 11 ? 00 V ; Date Defen is Waiver of Notice in §3301(c) Divorce was filed 'th a Prothonotary: O Respectfully submitted, Date: 3 0740 KELLI J. BROWNEWELL, ESQ. By:? Kelli J. ro 11, Esquire I.D. #90597 319 South Front Street Harrisburg, PA 17104 Telephone: (717) 433-28W (Attorney for Plaintiff) a rc ; . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF f PENNA. e ? Q t S-r-bP }? (? ?' SA NTH n(l?F,? ? ? N O. 0-7 - 9-15 c &'\ Le?M. VERSUS g? oc?lcf S , s .?. ?1 `??\ IJ,N DECREE IN DIVORCE AND NOW, v' IT IS ORDERED AND DECREED THAT TC(Z\STC??JCL ??TPcNJV , PLAINTIFF, AND l7\ZCD\C,? s, sANT^NN A 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; M' wc PROTHONOTARY fir,z Ac