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Home My WebLink About07-6758 KELLY W. BROWN, Plaintiff vs. CURT M. BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 017 - (ormb Civil IerM IN DIVORCE CIVIL ACTION - LAW 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 the 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 Court Administrator, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17103 (717) 249-3166 ( . 4b Nichole M. Staley O'Gorman, Esquire PA Atty. ID No. 79866 PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102 Telephone: (717)234-4178 Email: nstaley(&-pkh.com KELLY W. BROWN, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CURT M. BROWN, IN DIVORCE Defendant CIVIL ACTION - LAW COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, COMES Plaintiff, Kelly M. Brown, by her attorneys, Purcell, Krug & Haller, and avers as follows: 1. Plaintiff is Kelly W. Brown, an adult individual who currently resides at 32 Broad Street, Apt. No. 2, Newville, Cumberland County, Pennsylvania. 2. Defendant is Curt M. Brown, an adult individual who currently resides at 7821 Talisman Drive, Port Richey, West Pasco County, Florida. 3. Plaintiff has been bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 30, 1980, in Inverness, Florida. • 5. There have been no prior actions in divorce or annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. The marriage is irretrievably broken. 8. 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 counseling. 9. Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce. PURCELL, KRUG & HALLER By: Date: 11 r] . dr,7 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff 4 % VERIFICATION I, Kelly W. Brown Plaintiff in the within action, hereby verify that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATE': C? ? 0 -TI 00 r (OTC O^ v . ? rkQ KELLY W. BROWN, Plaintiff vs. CURT M. BROWN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-6758 Civil Term : IN DIVORCE ACCEPTANCE OF SERVICE I, Curt M. Brown, hereby accept service of the Complaint in Divorce. DATE: ?? 3 a C-C Curt M. Brown ?'? ? i? _._-- . cs ? , ? r?? ?? i -?? :?` --, .?? ? , t ?4 q+? KELLY W. BROWN, Plaintiff VS. CURT M. BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6758 IN DIVORCE CIVIL ACTION - LAW NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated on December 13, 2005 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 1 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. Dated: e y W. Brown 0 1 -? 3'3 r; nim 17 -OM z 7-4 v Nichole M. Staley O'Gorman, Esquire PA Atty. ID No. 79866 PURCELL, KRUG & HALLER 1719 N. Front Street Harrisburg, PA 17102 Telephone: (717)234-4178 Email: nstaleyft)kh.com KELLY W. BROWN, Plaintiff vs. CURT M. BROWN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 07-6758 Civil Term IN DIVORCE PRAECIPE TO TRANSMIT 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 3301 d of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint was served in person on November 30, 2007 at the office of Plaintiffs counsel. Defendant executed an Acceptance of Service on November 30, 2007, which was filed of record on December 4, 2007. 3. (Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: By Plaintiff: and By Defendant: s (b) (1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code: December 19, 2007. (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: Plaintiffs Affidavit was filed of record on December 26, 2007 and served on the Defendant on January 2, 2007 by U.S. postage prepaid mail. 4. Related claims pending: N/A 5. (Complete either (a) or (b)) (a) Date and manner of service of the Notice of Intention to file a Praecipe to Transmit Record, a copy of which is attached: January 24, 2008 by U.S. postage prepaid mail. (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary; N/A Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: N/A PURC,kLL, KRt)G & HQLJ ER Date: ? "P A By: 1719 N. Front treet Ha isburg, PA X17102 (717) 234-4178 ID No. 79866 n, Esquire HowARD B. KRuG LEON P. HALLER JOHN W. PURCELL JR. Jn1 M. Wr%TXA WHOLE M. STALEY O'GoRMAN LISA A RYNARD LAToYA C. Wn IFm LAW OFFICES 0GG?'C%P.G?, ?/y/1? 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-0409 January 24, 2008 Curt M. Brown 7821 Talisman Drive Port Richey, FL 34668 Re: Brown v. Brown Dear Mr. Brown: HERSHEY (717) 533-3836 JOSEPH NISSLEY (1910-1982) JOHN W.PURCELL VALERIE A. GUNN OF COUNSEL Enclosed please find a Notice of Intention to Request Entry of Divorce Decree. It is my client's intention to seek entry of a Decree in Divorce on or after February 14, 2008. NMSO/clm Enclosure cc: Kelly Brown, w/enc. KELLY W. BROWN, Plaintiff vs. CURT M. BROWN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-6758 IN DIVORCE CIVIL ACTION -LAW NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: CURT M. BROWN You have been sued in an action for Divorce. You,have failed to answer the Complaint or file a Counter-Affidavit to the §3301(d) Affidavit. Therefore, on or after February 14, 2008, the other party can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a final Decree in Divorce. A Counter-Affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect your economic claims. 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 Street Carlisle, PA 17103 (717) 249-3166 '`lam` IN THE COURT OF COMMON PLEAS KELLY W. BROWN No. 2007-6758 VERSUS CURT M. BROWN DECREE IN DIVORCE OF CUMBERLAND COUNTY STATE OF PENNA. AND NOW, Mm'j? LA, IT IS ORDERED AND DECREED THAT KELLY W. BROWN , PLAINTIFF, AND CURT M. BROWN 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; Nv OL'o Ao