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Home My WebLink About03-5405JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL 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 irretriewible breakdown of the marriage, you may request marriage counseling. A list ofmmriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Sqaare, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A I)IVORCE 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 32 South Bedford St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Jerome Grady Brownawell, who currently resides at, 216 Shed Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is, Melissa L. Brownawell, whose whereabouts are unknown, but whose last known address is, 216 Shed Road, Newville, ,Cumberland County, Pennsylvania. 3. Plaintiffis unaware of any of the names or addresses of near relatives or other persons who would be likely to know the present residence and whereabouts of the Defendant, however Plaintiff does know that the Defendant worked for either JFC Temps or Manpower Temporary Services in Cumberland County. 4. The Plaintiffhas been a bonafide resident in Cumberland County in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiffand Defendant were married on February 2, 1996 at the Marriage Court of Cook County, Illinois. 6. The Plaintiff and Defendant immediately moved to Cumberland County, Pennsylvania, and both resided in Cumberland County for a period of over one year, before the Defendant left the marital residence and discontinued contact with the Plaintiff There have been no prior actions of divorce or for annulment between the parties. 8. Divorce is sought pursuant to the provision of the Divorce Code 3301(d), in that the marriage is irretrievably broken. 9. Plaintiff has 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. 10. I1. Plaintiff does not wish to undergo counseling. The Plaintiffin this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfhlly submitted, J(~hn C. Porter Counsel f'or Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249~ 1177 yERIFICATION I, Jerome Grady Brownawell, 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 Plaintiff, Jerome Grady Brownawell JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION - LAW IN DIVORCE TO THEPROTHONOTARY: PRAECIPE Please re-instate the attached Complaint against Melissa L. Brownawell in the above captioned action and return the same, along with the extra copy, to the undersigned for service. Jot C. Porter Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, John C. Porter, Counsel for Plaintiff, hereby certify that a true and correct copy of Notice to Defend and Claim Rights and the Divorce Complaint in the above-captioned matter, was served this ~,~ day of, ~) e c e,30er 2003, by First Class Mail and by restricted delivery Certified mail, return receipt requested, upon the Defendant listed below: Ms. Melissa Brownawell 3195 Beth Blvd. Apt. # 106 Decatur, IL 62526 John C. Porter, Esq. Co-Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, John C. Porter, Counsel for Plaintiff, hereby certify that a true and correct copy of Affidavit Under Section 3301 (d) of the Divorce Code in the above-captioned matter, was served this Igo-¢~ dayof, ~)ec~ ~--xo~ 2003, by First Class upon the Defendant listed below: Ms. Melissa Brownawell 1120 E. Walnut Street Decatur, IL 62526 J~o~ C.'Porter, Esqf~~ Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle,, PA 17013 717-249-1177 JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION ~ LAW IN DIVORCE CERTIFICATE OF SERVICE I, John C. Porter, Counsel for Plaintiff, hereby certify that a true and correct copy of Notice of Intention To Request Entry of §3301 (d) Divorce Decree and a Counter- Affidavit Under §3301 (d) of the Divorce Code in the above-captioned matter, was served this 12 day of, December 2003, by First Class Mail upon the Defendant listed below: Ms. Melissa Brownawell 3195 Beth Blvd. Apt. # 106 Decatur, IL 62526 John C. Porter, Esq. Co-Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 JEROME GRADY BROWNAWELL Plaintiff Vo MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION - LA~V IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in October of 1998, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ifI do no 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. § 4904 relating to unswom falsification to authorities. Date: '~----( JEROME GRADY BROWNAWELL Plaintiff LISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 03-5405 CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Plaintiff, Melissa Brownawell, in the above captioned case. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorney~ fd,~Plaintif ~/... By: ~/"/~.~('~ .indsay, E~quire C~'ol, I?~ ~g3 ,t High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JEROME GRADY BROWNAWELL Plaintiff V. MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE Check either (a) or (b): (~ I do not oppose the entry ofa divome decree. b) I oppose the entry of a divorce decree because (Check (i), (ii), or both): i) The parties to this action have not lived separate and apart for a period of at least two years ii) The marriage is not irretrievably broken. eck either (a) or (b): I do not wish to make any claims for economic relief. 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 wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. IfI fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, miming to unswom falsification to authorities. (J J 'Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. SAIDIS SI'lUff, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JEROME GRADY BROWNAWELL Plaintiff MELISSA L. BROWNAWELL Defendant : IN THE COURT OF COMMON PLEAS .' OF CUMBERLAND COUNTY, : PENNSYLVANIA . : : No. 03-5405 CIVIL ACTION-LAW : IN DIVORCE CERTIFICATE OF SERVICF AND now, this _ /-/~ day of _F~/_b_4... j , 2004, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys, hereb certify that I served the within COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OI THE DIVORCE CODE this day by depositing same in the United States Mail, First Postage Prepaid, in Carlisle, Pennsylvania, addressed to: John C. Porter, Esquire Counsel for Plaintiff 61 W. Louther Street Carlisle, PA 17013 717-249-1177 SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Defendant By: Carol J. Lindsay, Esquire ID # 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 JEROME GRADY BROWNAWELL Plaintiff Vo MELISSA L. BROWNAWELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5405 CIVIL ACTION - LAW IN I)IVORCE DIVISION OF MARITAL PROPERTY AGREEMENT RESOLUTION OF ALIMONY PENDENTE LITE. ALIMONY. MAINTENANCE AND SUPPORT ISSUES The parties to this divorce, Jerome Grady Brownawell and Melissa L. Brownawell hereby settle any and all marital property, alimony pendente lite, alimony, maintenance, and support issues as follows: 1. Both parties are represented by Counsel. 2. Defendant Melissa L. Brownawell submits to, and accepts, the jurisdiction of the Cumberland County Court of Common Pleas, Pennsylvania regarding this divorce and any and all marital property, alimony pendente lite, alimony, maintenance, and support issues pertaining thereto. 3. Plaintiff, Jerome Grady Brownawell agrees to pay the sum of $200.00 in full satisfaction of any and all marital property claims made by the defendant. 4. Neither party will seek alimony pendente lite, alimony, maintenance, or support, now or ever from the other party. 5. The signature bel°w °f each party represents their satisfaction with this agreement and binds them to this agreement. 6. The signature below of each party signifies that from this date forward no dispute shall arise or be recognized as to any marital property, alimony pendente lite, alimony, maintenance, and support issues as this agreement settles all such issues. 7. This agreement shall not be subject to modification by the Court. 8. This agreement shall be incorporated into, but not merged with the Divorce Decree. 9. This agreement shall survive the Divorce Decree. WHEREFORE, the parties, intending to be legally bound, execute this agreement of their own individual free will. Defenc~ant, ~ielissa L. Brown~w~ll f~//Plaintiff, Jerome Gra~Bywel~- Date: ~R ~ ~ 2004. JEROME GRADY BROWNAWELL PLAINTIFF MELISSA L. BROWNAWELL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5405 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (d) of the Divorce Code was filed on October 13, 2003 and was reinstated on December 1, 2003. 2. After service of the complaint the parties have agreed to pursue a divorce under § 3301 (c) of the Divorce Code. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. I consent to the entry of a final decree of divorce. I verify that the statements made in this affidavit are tree 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. Jerome Jrady Brownawell, Plaintiff JEROME GRADY BROWNAWELL PLAINTIFF MELISSA L. BROWNAWELL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5405 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (c) AND (d) 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 ifI 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 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 unswom falsification to authorities. Dated 'j e Grady Brownawell, Plaintiff ' JEROME GRADY BROWNAWELL PLAINTIFF MELISSA L. BROWNAWELL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5405 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT_ 1. A complaint in divorce under § 3301 (d) of the Divorce Code was filed on October 13, 2003 and was reinstated on December l, 2003. 2. After service of the complaint the parties have agreed to pursue a divorce under § 3301 (c) of the Divorce Code. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. I consent to the entry of a final decree of divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to t]he penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dated: ~ t~t0t9~ JEROME GRADY BROWNAWELL PLAINTIFF MELISSA L. BROWNAWELL DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-5405 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) AND (d) 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 ifI 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 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 unswom falsification to authorities. Dated: Melissa L. Brownawell, Defendant Jerome Crady Brownawell Plaintiff VS. Melissa L. Brownawell Defendant IN THE COURT OF COMMON PLEAS CUIvlBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 03-540_5 CIVIL TERM To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: December 3 i 2004 Restricted ~elivery Certified Ma~l and First Class Mail. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff ]'~'arch 10, 2004 ; by defendant ]'Iarch 18, 2004 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: b~one. 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 §3301 (c) Divorce was filed with the Prothonotary: '~arch 10~ 2C~04 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: March 1g, ?,004 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~~, PENNA. Jerome Grady Brownawell Plaintiff VERSUS Melissa L. Rro~mawe11 Defendant NO. DECREE IN DIVORCE , ~:~{ , IT IS ORDERED AND DECREED THAT Jerome Grad¥ Brownawell , PLAINTIFF, AND Melissa L. Brownawell _, 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; BY THE COURT: /~ / ~~PROTHONOTARY