The URL can be used to link to this page

Home My WebLink About03-3858STACEY E. BRYAN Plaintiff KENNETH B. BRYAN, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 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 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 WI-IERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 STACEY E. BRYAN Plaintiff KENNETH B. BRYAN, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Stacey E. Bryan, who currently resides at 8 Robin Drive, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Kenneth B. Bryan Jr,, who currently resides at 75 Walnut Dale Road, Shippensburg, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint, 4. The Plaintiff and Defendant were married on May 20, 1995 at South Hampton Township, Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provisions of the Divorce Code, 3301(c), and 3301 (d), in that the marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 8. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT I - COUNSEL FEES AND COSTS 9. Paragraphs 1 through 8 of this Complaint are incorporated herein by reference as though set forth in full. 10. Plaintiff has retained Stephanie E. Chertok and John C. Porter, Attorneys at Law, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and is unable to bear the burden of court costs and expenses. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate, and at final hearing to award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Respectfully submitted, j~C. Portent'~ Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 VERIFICATION I, Stacey E. Bryan, verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date STACEY E. BRYAN Plaintiff KENNETH B. BRYAN, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-3858 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, John C. Porter, Counsel for the Plaintiff, Stacey E. Bryan, hereby certify that a tree and correct copy of the Divorce Complaint in the above captioned case were served upon Attorney Finucane, Counsel for the Defendant, Kenneth B. Bryan, in the following manner: First Class Prepaid Postage to: Attorney Finucane Finucane Law Offices 14 N. Main Street, Suite 500 Chambersburg, PA 17201 on this 12th day of August, 2003. Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 STACEY E. BRYAN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 0:1-3858 KENNETH B. BRYAN, JR. Defendant CIVIJL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 330] (c) of the Divorce Code was filed on August 8, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service ofthe 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. Dated: -0/1# 16 5 I <7. c., <--" C::-' c_? c..n -<1 1"1 <:P C) -"1', :::? - - - Q I" STACEY E. BRYAN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 03-3858 KENNETHB. BRYAN,JR. Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENl: 1. A complaint in divorce under ~ 3301 (c) ofthe Divorce Code was filed on August 8, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 sllrvice of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are tm~ 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. Dated: / /;;. 7/ oS { Lha: "".4' tcs ~;. -,-, rc' <:P \ - , \-v ~.r-' (-\ -"1:1 - -- o t") - STACEY E. BRYAN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 0:1-3858 KENNETH B. BRYAN, JR. Defendant CIVIJL ACTION - LAW IN DIVORCE MARRIAGE COUNSELING AFFIDAVIT The Plaintiff, being duly sworn according to law, deposes and says: I. 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 Prothonotary's office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are tITle and correct. I understand that false statements herein are made subject to the penaltie:s of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: / /)-1/6S- srnbf~ ."...:. i . r-.:'- ~~~ ~~'"l -n r'\ CO I - ,'--) f"...) - STACEY E. BRYAN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. No. 0.3-3858 KENNETH B. BRYAN, JR. Defendant CIVIL ACTION - LAW IN D][VORCE MARRIAGE COUNSELING AFFIDAVIT The Defendant, being duly sworn according to law, deposes and says: 1. 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 wunselors in the Prothonotary's office, which list is available to me upon request. 3. Being so advised, I do not request that the Court requin: that my spouse and I participate in counseling prior to a divorce decree being handed down. 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. Dated:O//9h~ ~~B. r-c' ~. ~~ '(~\ c'~ \ C) .0\"\ -~,. ""-.'" .- ..-,-' ....;,.. -- -- - STACEYE. BRYAN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 03-31158 KENNETH B. BRYAN, JR. Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330HC) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divom; without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divon;e 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. section 4904 relating to unsworn falsification to authorities. DATE: / h7 ~S' . ~~P~~ '- ""'-'-..--> . "" c;::') = <J' -n r-' co , o c"J STACEY E. BRYAN Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 03-3858 KENNETH B. BRYAN, JR. Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I. 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! 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 Due 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: OIl/bioS' t I ~L~~ 'K~;lth ~. B ., Defendant ~.;:~ e:'J '-" """ pi CO C' ~'ll --1 :'C C) <..' IN THE COURT OF COMMON PLEAS STACEY E. BRYAN, PLAINTIFF, VS. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION KENNETH B. BRYAN, JR., _DEF-ERDANT. NO.3 8 5 8-0 3 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to th'3 court for entry of a divorce decree: ,. Ground for divorce: Irretrievable breakdown under 93301 (c) ~~f('€l1'('lY'eff't1'fe'131VO/Ee~~ (Strike out inapplicable section). 2. Date and manner of service of the complaint: August, 12, 2003;Attorney for Defendant accepted service on behalf of Defendant 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff 1 - 2 7 - 2 005 ; by defendant 1-16 - 2 0 0 5 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was fiied with the Prothonotary: _ 02- 01- 2005 Date defendant's Waiver of Notice in 93301 (c) Divorce was filed With the Prothonotary: 02 - 0 1- 2 0 0 5 I)' A;1L n~s;t ,i) Allorney for Plaintiff I Defendant r---:1: (;-::~ c") <:"~:;:t -j I (;...i'1 ::::! ,.. c;:.:! ""'"", C) .J!;',"- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. :f.;f,iHf.:t .. 1t;:f. "':t ;t; ... "'''';to ;Ii"':': . .. .. .. . . :Ii'" :ti:t:;Ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STACF:Y \1,. BRYAN No. 3858 2003 VERSUS KENNETH B. BRYAN,JR. DECREE IN DIVORCE 1~",,"I '(.. ,~20dr , IT IS ORDERED AND AND NOW, STACEY E. BRYAN DECREED THAT , PLAINTIFF, KENNF:TH B. BRYAN, JR. AND , 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; {lJ61..J~ PROTHONOTARY . .. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . + . . . . . . + . . + + . + . . . r;...-,'w ,- _ , i,:r"~ ' , -'/'~ ///1' (7~ $17 ? /1f;r '->>7/ rp'0"( ;2. ~r~' ..-~?) j7/) . . '- .SL/ II ->,? 1/ (