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Home My WebLink About99-05620 r li I - r •?::?„•7M: +7;•::dK+?71C•'?14c:•7Yk ?lo::c? ,s,,,.,?; .,?.,,,?,,.,M,..,?,..,?,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. _ .......... ............_.................... 5620 Civil c 99 N c ? ......................... ................. 1) .... OHN.. D ....BROWN...... .............................. Versus ................ ......._..... _ _..... . _ ........ _......... ANGELINA BROWN DECREE IN ,p DIVORCE AND NOW, .. .. ?......... , ?, it is ordered and OHN D. BROWN decreed that ......... .................................. plaintiff, and .............. ANGELINA. BROWN.......................... , 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 Ore i Hy u e Attest: ^ ?• •? Prothonotary f :i :ti :1 •. :? • G:? .•716. •X.• -4K- W' -M {N? rak• {R• {wl •'A;• •A:• • ? • :? • tit • L6• •:4* •W.• M.'30, •A:• X? S.3i ?i 44 43?e?? JOHN D. BROWN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. ANGELINA BROWN, Defendant. NO: 5620 CIVIL 1999 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: 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) , 33Rd) of the Divorce Code. (Strike out inapplicable section.) ?? \\ 2. Date and manner of service of the Complaint: 9/21/99 - Upon Defendant's counsel, copy of Acceptance of Service Attached hereto. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 4//24100 By Defendant: 4/17/00 (b) (1) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1)(i) of the Divorce Code: i' P: Richard Wagner sq. Attorney-ftf-15-laintiff -, . '- ; i - ;; JOHN D. BROWN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND (Polo CyOUNT/,Y, PENNSYLVANIA V. NO. 7/ 1 :3 CIVIL ACTION - LAW ANGELINA BROWN, . 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 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, PA 17013 (717) 249-3166 JOHN D. BROWN, V. ANGELINA BROWN, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99- SG.20 C.a.j T,,.r. CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, JOHN D. BROWN, by and through his attorneys, MANCKE, WAGNER, HERSHEY & TULLY, and files the following Complaint in Divorce: 1. The Plaintiff, JOHN D. BROWN, is an adult individual currently residing at 2161 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant, ANGELINA BROWN, is an adult individual currently residing at 2161 Canterbury, Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on August 14, 1993, in Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that he has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken; and B. that as of September, 2000, the parties will have lived separate and apart for a period of at least two (2) continuous years. WHERFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. 9. The averments contained in paragraphs 1 through 8 above are incorporated herein by reference and made a part hereof. 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Section 401 of the Divorce Code of 1980. WHEREFORE, Plaintiff, JOHN D. BROWN, requests this Honorable Court: A. Enter a Decree in Divorce; B. Equitably distribute all property, both real and personal, owned by the parties; and C. Grant such further relief as the Court may deem equitable and just. Respectfully submitted, MANCRS, pAGN?j HERSHEY i TDLLY By r M1Vllas ay.•?-, --z- 1 2733 North Front Street .1arrisburq, PA 17110 (717) 234-7051 Attorney for Plaintiff DATE: 30 99 I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE. b 922 s v.` as SMfp561 ryr °'ir., C.) U1 lJ O m } Y W = U Q W JOHN D. BROWN, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. ANGELINA BROWN, Defendant. NO. 5620 CIVIL 1999 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, JAY R. BRADERMAN, ESQUIRE, attorney for the Defendant, ANGELINA BROWN, do hereby accept service of the Complaint in Divorce thi6V_day of 1999, in the above-captioned action. r? ;? r ??_. , ' 'i. _ :-? 'i i_' Ci JOHN D. BROWN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 5620 CIVIL 1999 CIVIL ACTION - LAW ANGELINA BROWN, , IN DIVORCE Defendant. AFFIDAVIT of COMBBNT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 14, 1999. 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. 4. 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. 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 4904, relating to unsworn falsification to authorities. DATE: ql d y 0o 1 y _ 4D6&-B:irown r, <? ?= ;_; ? ?=:; - :_:; `-- ?:? :_? JOHN D. BROWN, V. ANGELINA BROWN, Plaintiff, Defendant IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA NO. 5620 CIVIL 1999 CIVIL ACTION - LAW IN DIVORCE 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. 54904 relating to unsworn falsification to authorities. 1 _ Job DI Brown DATE: ldqlp() - ???, - ., ?: ?? ;; ,_ ;. ;,. - . -.: :?:. JOHN D. BROWN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW V. NO. 5620 CIVIL 99 ANGELINA BROWN, IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on September 14, 1999. 2. The marriage between 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 in Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this affidavit are hue and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to urswom falsification to authorities. Date: ANGEL,INA BROWN SSN: 181 - 64 - 5735 ?, ?? ?_? f_ ? _? JOHN D. BROWN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. ANGELINA BROWN, Defendant : CIVIL ACTION -LAW : NO. 5620 CIVIL 99 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 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 understand that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. 1? A c?cC? Date: 7 QC x 4c, ANGEL A BROWN JOHN D. BROWN, V. Plaintiff, ANGELINA BROWN, Defendant. TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 5620 CIVIL 1999 CIVIL ACTION - LAW IN DIVORCE PRAECIPE Please withdraw Count I of Plaintiff's Complaint. Respectfully submitted, Mancke, Wagner, Hershey & Tully By ?t?-- P. Richard agner, Esquire I.D. 42343 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: `/ ;J 5 l10 ,, ' _ ,?. ,:` _ - '- ?? ;; ?, JOHN D. BROWN, Plaintiff V. ANGELINA BROWN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 5620 CIVIL 99 : 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 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 of 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 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, PA 17013 (717)249-3166 JOHN D. BROWN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 5620 CIVIL 99 ANGELINA BROWN, IN DIVORCE Defendant ANSWER OF DEFENDANT TO DIVORCE COMPLAINT AND COUNTERCLAIM PETITION AND NOW, comes the above named Defendant, Angelina Brown, by and through her attorney Jay R. Braderman, Esquire, and files the following Answer and Counterclaim Petition: 1. Denied. Plaintiff no longer occupies the marital home at this address and his current address is not known to Defendant. 2-8. Admitted. I COUNT 9. Defendant incorporates by reference her answers in Paragraphs 1 - 8. 10. Admitted. COUNTERCLAIM PETITION 11. Defendant incorporates by reference her answers in Paragraphs I - 10. 12. Defendant is unable to sustain herself during the course of litigation. 13. Defendant lacks sufficient property to provide for her reasonable needs and is unable to sufficiently sustain herself through appropriate employment. 14. Plaintiff has sufficient resources available to sustain himself, pay his counsel fees, costs, and expenses, and provide assistance to Defendant for her support, counsel fees, costs, and expenses. 15. Plaintiff is in a better position to provide for Defendant than Defendant can provide for herself. 16. Defendant desires that the Court enter an award of alimony pendene lite (APL), counsel fees, costs, and expenses after considering all relevant factors. WHEREFORE, Defendant respectfully requests that Your Honorable Court enter an award of alimony pendente lite until final hearing, and that the Court enter an Order directing Plaintiff to pay Defendant's reasonable counsel fees, costs, and expenses pursuant to § 3702 of the Divorce Code. Date: Esquire 126 Locust Street ¢ 0. Box 11489 Harrisburg, PA 17108-1489 (717) 232-6600 Attorney for Defendant VERIFICATIQN Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Answer of Defendant to Divorce Complaint And Counterclaim Petition are true and correct to the best of my knowledge, information, and belief. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: - c?!_? -x <v ?A? Angelina Nown ?d ?F?? r r> cv l?.V iJ o <J 0 2 Ir w? W Z w m U O m U. Q H%> O m ]mZ C 3 0 0 L.Lu i 5 of ?dI i } N 2 Q H m m m 6 Q I