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HomeMy WebLinkAbout03-3477IN THE COURT OF COMMON PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy MaHe Brenner, Plai~ 66 Na~ow Road New Bloomfield, Penns~vania 17068 175-40-9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court for divome. If you wish to defend against the claims set forth on the other side of this page, 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 o~ relief requested in this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or children. When the ground for divorce is indignities or irretrievable breakdow~ 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, in Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Carlisle,~A. Telephone(~-~) ~;L~('~J ~lL.b(j IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Brunner, Plaintiff 66 Narrow Road New Bloomfield, Pennsylvania 17068 175-40-9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court for: [] Divorce [] Support [] Division of Property [] Temporary Alimony [] Costs [] Annulment of Marriage [] Custody and visitation [] Alimony [] Attorney You have been sued in Court. If you wish to defend against the claims set forth on the other side of this page, 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 relie~ requested in this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of mardage counselors is available in the Office of the Prothonotary at the CUMBERLAND County Courthouse, in , PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Telephone( ). IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Brunner, Plaintiff 66 Na~ow Road New Bloomfield, Penns~vania17068 175-40-9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Nancy Marie Brunner who resides at; 66 Narrow Road; New Bloomfield, Pennsylvania 17068. 2. Defendant is Del Scott Brunner who resides at: 825 Windsor Place; Mechanicsburg, Pennsylvania 17055. 3. a Plaintiff and/or a Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on August 26, 1967 at Mechanicsburg, Cumberland County, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments. 6. There has been no prior action of divorce or for annulment between the parties. Complaint for Divorce; Page 1 7.The marriage is irretrievably broken. 8. After 90 days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in marriage counseling. 10. There are no minor children bom to or adopted by the parties to this marriage. WHEREFORE, if both parties file affidavits consenting to a divome after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and Defendant. COUNTII REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(B) OF THE DIVORCE CODE. Paragraphs 1-10 are incorporated herein and made a part hereof by reference as though fully set forth. The parties have entered into a written Marital Settlement Agreement providing for the division of their assets and debts, a copy of which is attached hereto and incorporated by this reference the same as if fully set forth at length. WHEREFORE, Plaintiff respectfully requests that this Court approve and Complaint for Divorce; Page 2 incorporate the agreement reached between the parties into the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. Na~(~-Made Brunner I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unsworn falsification to authorities. Date: /~ ~,J~mcy Marie Brunner, Pro Per IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Brunner, Plaintiff 66 Narrow Road New Bloomfield, Pennsylvania 17068 175-40-9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM COUNSELING NOTICE RULE 1920.45(a)*(1 ) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301 (aX6) Indignities Section 3301 (c) Irretrievable breakdown Mutual Consent Section 3301 (d) Irretrievable breakdown Two/Three year separation A list of qualified professions is available for inspection in the Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone(. ) IN THE COURT OF COMMON PLEAS OF THE OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Bmnner, Raintiff 66 Na~owRoad New Bloomfield, Pennsylvania 17068 175-40-9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 JUDICIAL DISTRICT CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM AFFIDAVIT OF NON-MILITARY SERVICE Nancy Made Brunner, being duly swom according to Law, deposes and says that Plaintiff knows by Plaintiff's own personal knowledge and therefore avers that the defendant, Del Scott Brunner, is 54 years of age and that Defendant is not in the military service of the United States or its allies, or otherwise within the provision of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments and that the defendant is employed by None. Sworn to and subscribed before me this the '~,~.day of ~F&,~. ~'. =,~d,~ .~ N~adal ~tarv Publi(J Ma?n Ripson, Notary PLIt)tlC Lower A,;en Twp., Cumberland County My Commission Expires July 27, 2004 IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Brunner, Plaintiff 66 Narrow Road New Bloomfield, Pennsylvania 17068 175-40-9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 § CIVIL ACTION - LAW § TERM § CASE NO. 0~-~H77 § IN DIVORCE ACCEPTANCE OF SERVICE I, Del Scott Brunner, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divorce filed in the above-captioned matter. IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Brunner, Plaintiff 66 Narrow Road New Bloomfield, Pennsylvania 17068 175-40~9724 Del Scott Brunner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM AFFIDAVIT AS TO SIGNATURE Nancy Marie Brunner, being duly sworn according to law, deposes and says that Nancy Marie Brunner is the Plaintiff in the above-captioned divorce action; that Nancy Marie Brunner is familiar with the signature of the Defendant; and that the signature on the Acceptance of Service attached hereto as Exhibit "A" is the signature of the Defendant, Del Scott Brunner. Nanc~arie Brunner, Plaintiff Sworn to and subscribed before me this the .~'~ day of ry Public Notadal Sea~ Mad!n R1pson, NotaP7 Public Lower A~len Twp.. Cumberland County My Commission Expires July 27, 2004 Member, Per--ia .~ssoc~at,:)n of No{aries IN THE COURT Of COMMON PLEAS Of THE q~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Made Brunner, Plaintiff 66 Narrow Road New Bloomfield, Pennsylvania 17068 175-40-9724 Del Scott Brenner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW CASE NO. TERM DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the o~, day of ~'-'-c,..l~ , ~OO.~ 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that mardage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301(c) of the Divorce Code, and I understand said Complaint. I waive any pleading pedods and notices there may be. 5. I hereby enter my consent to the entTy of a final decree of divorce. 6. I undemtand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 7. I verify that the statements made in this affidavit are lrue 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. / D~/Scott Brenner, Defendant IN THE COURT OF COMMON PLEAS OF THE ~TH JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Nancy Marie Bmnner, Plaintiff 66 Narrow Road New Bloomfle~, Pennsylvania 17068 175-40-9724 Del Scoff Brenner, Defendant 825 Windsor Place Mechanicsburg, Pennsyvlania17055 182-40-9371 CIVIL ACTION - LAW 05-5'-t"1q CASE NO. TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301 (c) of the Divorce Code was filed on the .__~ay of ~-c~.-I~ ,.. o~.OO~ 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divome Under Section 3301 (c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the ent~ of a final decree of divorce. 6. I understand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 7. I verify that the statements made in this affidavit are t]'ue 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. Dated: Nancy M~i~r~nner, Plaintiff