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Home My WebLink About99-06960I? 0 a v Q ;' r'• N 7 E ljo? Cl t L;: J r. - J l: V 8 V F t m n. z 3 W u _ W o M W g. =) m a 5 < Z a g m W Q Z ' K.. ? U W, ?i ' r r <Yqy; THOMAS L. BRANSOM, Plaintiff V. BERNADETTE R. BRANSOM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ?9 l0 9G? Ci?? CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT 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 judgement 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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, Pennsylvania 17013 (717) 249-3166 THOMAS L.BRANSOM, Plaintiff V. BERNADETTE R. BRANSOM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 to `%?0 C [t?ci ci CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: l?? ?GtL?L Ar?v THOMAS L. BRAN OM THOMAS L. BRANSOM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. `r ('- G 4G0 L'ca-LP ?z.. BERNADETTE R. BRANSOM, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE Plaintiff is THOMAS L. BRANSOM, an adult individual residing at 402 Norman Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is BERNADETTE R. BRANSOM, an adult individual residing at 234 East Main Street, Apt. C, Shiremanstown, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on June 22, 1997 in Cumberland County, Pennsylvania. 5. The parties are parents of three (3) minor children, namely: Brenee E. Bransom (DOB 6/24/94); Carly C. Bransom (DOB 8/27/96); and Nathan L. Bransom (DOB 3/13/98). Additionally, Plaintiff has stood in loco parentis to Defendant's son, Chase D. Miller (DOB 9/4/91). 6. The parties separated on September 15, 1999. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of PlaintifFs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with § 3301 of the Pennsylvania Divorce Code. Dated: Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 1) THOMAS L. BRANSOM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. BERNADETTE R. BRANSOM, CIVIL ACTION - LAW Defendant IN DIVORCE VERIFICATION I, THOMAS L. BRANSOM, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: 4? THOMAS L. BRA OM J . tr:i . J . p5<. . _ iZ Y ::" v cr U . J f . ..1 .1 Z w J ZZ (L 3 g ? m a Q n Z a g a m m 1 r•"::, THOMAS L. BRANSOM, IN THE COURT OF COMMON PLEAS Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-6960 BERNADETTE R. BRANSOM, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE 1, Barbara Sumple-Sullivan, Esquire, do hereby certifv that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. Z 143 612 081, Return Receipt Requested, on the above-named Defendant, Bernadette R. Bransom, on November 26, 1999, at Defendant's last known address: 234 East Main Street, Apt. C, Shiremanstown, PA 17011. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Dated: November __? . 1999 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff J i c c ° C e -- -Z--14 3 612 081 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. new not ucm fnr Intmm.Nnnnl ",;I /C.... ,. of Sent to Ms. Bernadette R. Bran rent & Number 34 East Main ST. A t VW Olfce, Slate, B ZIP Code i 1 remanstown PA 1701 Postage $ 5.i Certified Fee / v r Special Delivery Fee Restricted Delivery Frm hommE Data ) Oefi Showin W1w ' v ,$ +1( I:s( vj i Rebmaxepl C) Date,dldd I TOTAL Ponta eon I $ D .7J Posnarkor Dd`eL y 0lb \\ rN. p o 170• tom C o SENDER: { 8 •Compfeb came 1 ardor z for addieanal ceMCoa. • Cam t• plel e item. a,xa, and ab I also Wish to receive the t . .Print Arname are address on the reverse of this form so that Cord to You. wo can return INa following services (for an extra fee): •Amech 'his form to rho from of the meildeca, or on the back If space does not Addre •W 0 _.t s' D 111 ss Refumgecelpf Repuested'on the mmgPi•oe below the article number. .0 Restricted .The Rolm Receipt Off Into whom rile Woo well deliveed and th Z••7 Restricted Delivery deli d vered. c ° q 3. Artlcle Adtlressetl lo: e ate Consult postmaster for fee. 'Postmaster for fee". g 4a, Article Number g . H Ms. Bernadette R. Bransom Z 143 612 081 E ° 234 East Main Street 4b. Service Type R' Apt. C O Registered III Certified IC Shi=a^a:r? PA 17011 ? Express Mail NSTO Insured ? Return Receipt s OD 7. Date of Dell H o 5. Receivetl By: (Pdn1 NemeJ a°. 8. Address Is as( /r If fed Y a and to e fsp and 6. Sign re: (Atldr a rA ) ° US?9 a n Ps Form 3811, December 1994 EXHIBIT "A"