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Home My WebLink About07-2476DEANNA BROOKHART, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION -LAW LARRY BROOKHART, 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 maybe 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 mazriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Cazlisle, 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 DEANNA BROOKHART, Plaintiff, v. LARRY BROOKHART, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . ~ l :CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Deanna Brookhart, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint in Divorce: 1. The Plaintiff, Deanna Brookhart, is an adult individual currently residing at 21 Burgners Mill Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Larry Brookhart, is an adult individual currently residing at 21 Burgners Mill Road, Cazlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least 6 months prior to the filing of this Complaint. 4. Plaintiff and Defendant are Husband and Wife, having been married on September 13, 1969, in New Bloomfield, Perry 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 she has the right to request that the Court require both parties to participate in counseling. 8. Plaintiff avers as grounds on which this action is based is that the marriage is irretrievably broken pursuant to § 3301(c) of the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 s~ Attorneys for Plaintiff Date: '' l Mancke, Wagner, Spreha & McQuillan VERIFICATION 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.A. Section 4904, relating to unsworn falsification to authorities. .._~ "~~ ~~ ~ DATE: ~ ~~ G V.J fir. 1~` ~ w ° ~? 1 0 _~ J { - t. . y f"_ N C~ C;3 +J ~J ~+..! ~9+ 1r~ I^7 '.,.' ~-- ~~ 4_ ~ __•~ C3 .~ i`[i J~ ~' DEANNA BROOKHART, Plaintiff, v. LARRY BROOKHART, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2476 CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, LARRY BROOKHART, do hereby certify that I was served with a COMPLAINT IN DIVORCE in the above-captioned action on the l~ day of May, 2007, by certified mail, restricted delivery, return receipt requested. ~ :,'~~~ r ,~ '} `O? ;'°'; } i,...J '~„~ .'._ _~ ti +:r _.J f e"7 .yf ~~ C.c~ "'~ DEANNA BROOKHART, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO. 07-2476 CIVIL ACTION -LAW LARRY BROOKHART, IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Apri127, 2007. 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:_ ~ 6 'd Eµi r°~a ~ {,) ~°_ s ~ _.~ -~ .~-~` ~._ --r- ,~,.y ','~ ; ~_. i`~.3 ; ~ - C: ...~- ... , M =; ~: S r. ;~ -"{ -^^~ .~ ~~ DEANNA BROOKHAR"I', : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. LARRY BROOKHART, Defendant. NO. 07-2476 CIVIL TERM CIVIL ACTION -LAW 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 l8 Pa.C.S. §4904 relating to unsworn falsification to authorities. Larry rookhart DATE: ~ ~C1~ll ~_ ra l~7 4"_::J ~~ ..q.7 l.:.a ~"i' u~ `4s :'- ~ j~"~ C;`1 Z,,~s :T! --G DEANNA BROOKHAKT, v. Plaintiff, LARRY BROOKHART, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2476 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Apri127, 2007. 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. 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: ~'' G 11'I a Brookhart i." c` n _ ~.~ ~.aS~9 ~ Jr _..- ~ ~J -y ,-., ~~ "s ~ ~ '_ ~ _. __ ~T , :. ... ..-r ,~ _.Y ~. _ .... _ ~, ~S' ~ [ l'1 s: W .> ~ 'y ~r ~ °" . DEANNA BROOKHART, : IN THE COURT OE COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v. Plaintiff, NO. 07-2476 CNIL TERM LARRY BROOKHART, Defendant. CIVIL ACTION -LAW 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. §4904 relating to unsworn falsification to authorities. Deanna Brookhart DATE: 8 t`) ~ .~., i-~ ~., •--~ `Y'Y r ,~ ~ ~~ ~.; =Cti. __ ~ ~ w ~ ~ e a • ..; ~ .A~ DEANNA BROOKHART, Plaintiff, v. LARRY BROOKHART, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 2007-2476 -CIVIL TERM 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) , 33~(d) of the Divorce Code. (Strike out inapplicable sectton.) ~~ 2. Date and manner of service of the Complaint: May 1, 2007 by certified mail, restricted delivery, return receipt requested, a copy of an Acceptance of Service is attached. 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: 08/06!07 By Defendant: 08/06/07 (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. (Complete ether (a) or (b).) (a) 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 xi) of the Divorce Code: ~_- +Al (b) Date Plaintii~s Wavier of Notice was filed with the Prothonotary: 08/08/07 (c) Date Defendant's Waiver of ~ce was filed wiith th~,e.Pothonotary: 08/08/07 P. Ricly~rd Waggs!`, Esq. ~~ ~:~ _~~ __ , . __ -_, ~~ :~~ i.~ ~.~ _r.Y ~ ~-T , ;°-~ ~.~ _ .., .~ ___ t _ ,-r= _€ >. C.; 3 ,~,, :7:~ ..: I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~~- - . DEANNA BROOK:HART VERSUS N o. DECREE IN DIVORCE AND NOW, Av,~g~ Z'L , 1~, IT IS ORDERED AND DEANNA BROOKHART DECREED THAT PLAINTIFF, AND LARRY BROOK]HART ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; BY THE COURT: ATT T ~ ~ .1. PROTHONOTARY ~ ~ . ~~ ~ , , .~ ,,-~ ~ ~. y~~~ :. `~i ~ e c.0 ~,-~ Go, ~-.~