The URL can be used to link to this page

Home My WebLink About08-1916Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant : NO. 08- 19 CIVIL TERM 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 Prothonotary, Cumberland County Courthouse, Carlisle, 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, 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, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant : NO. 08- 151(a CIVIL TERM DIVORCE COMPLAINT The plaintiff, Amanda L. Brimmer, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. 6443301(c) AND 3301(d) OF THE DIVORCE CODE 1. 2. 3. 4. 5. 6. 7. 8. Plaintiff is Amanda L. Brimmer, who currently resides at 231 East Louther Street Carlisle, Cumberland County, PA 17013, since on or about September 2007. Defendant is Aaron A. Brimmer, who currently resides at 2011 Street, Lynchburg, Campbell County, VA 24504, since on or about January 2008. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on May 31, 2003 at Wellsboro, Tioga County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since February 2007. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Rebecca Faulkner Certified Legal Intern J'e4?1 4w, MEGA14 RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date Plaintiff A anda L r_? ^' Y'J . _ ?_) r'_.::J ? ? ? -'E-? • ` ? -? f_j ?- ?? s .-s -1- 'T 1 r ?; ? ? J ., - t !?-? - - - .:._ ?_ ?- i`'?'. C,`"1 Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant NO. 08- ?q ?6 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Amanda L. Brimmer, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date -WoAr6 62(2, n)C(' Rebecca Fa kner Certified Legal Intern MEG RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?-? TI Fil Gg `"ry Amanda L. Brimmer, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Aaron A. Brimmer, Defendant : NO. 08 - 1916 CIVIL TERM CERTIFICATE OF SERVICE I, Rebecca Faulkner, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Aaron A. Brimmer, residing at 2011 Street, Lynchburg, Va 24504, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Aaron A. Brimmer, on the the 31St day of March 2008 as evidenced by the attached green card. ?Ede L__ A-0_allmlp Rebecca Fa kner Certified Legal Intern Megat iesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 r "" Q 1. 4 ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article wed to: A X ? Agent - - ? Addressee B. 14? =Ived by ( Printed Name) C. Date Aelivery J D. Is (very different from Item 1 13 Y If YES, enter delivery address ? No L c/r?chbuvC V4- ly? 3. Type J i CO tifled Mail O Man ? Registered LVI lettumBReceipt for Merchandise ? Insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2 7005 0390 0003 2632 4402 PS`For`m 3811, Fibn y 1004 Dorneaft Return Re W i?tsesoa M t6no r7 C csa r ,r± Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant : NO. 08-1916 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter hereby elects to retake and hereafter use her previous name of Amanda L. Price, having filed a divorce complaint on the 26th day of March, 2008, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.,C.S. § 704. manda L. Brimmer Wishes To Be Known As: Amanda L. Price COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the 28th day of May, 2008, before me, a Notary Public, personally appeared Amanda L. Brimmer, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal. OTAR IC Notarial Seal Laurie L. Wolf, Notary Public Carlisle Boro, Cumberland County My Commission Expires Feb. 14, 2010 ?. `?., r^? ., ?."", t_.? " a 3 _- -- ?? ?.vlp _ ?? ? ?' Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant :NO. 08-1916 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) and 3301(d) of the Divorce Code was filed on March 26, 2008. 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. 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 unworn falsification to authorities. Date Amanda L. Price (Brimmer , Plaintiff rv ?^* t:1 "???z G.. c;,?,. s ? ?' ct? `-` ?`- s? ? ? Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant :NO. 08-1916 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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. Date 7 02-fl 12 `? A ands L. Price (Brimmer), Plaintiff °C= ro c r ? =n _ F Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant :NO. 08-1916 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) and 3301(d) of the Divorce Code was filed on March 26, 2008. 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. 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. Date Aaron A. Brimmer, Defendant ° ? C? ?-, c? t ?_? .- ? ? ? ,, ?? ? _:_ ti-? - _.? Amanda L. Brimmer, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Aaron A. Brimmer, Defendant :NO. 08-1916 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 unworn falsification to authorities. Date 7- ?- C)i Aaron A. Brimmer, Defendant r"a Amanda L. PriceBrimmer, Plaintiff V. Aaron Brimmer, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE AND CUSTODY No. 08-1916 CIVIL TERM 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(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Aaron Brimmer on March 31, 2008. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff- July 2, 2008; by Defendant- July 14, 2008. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: July 9, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary: July 25, 2008. Date MICHAEL LIG FOO Certified Legal Intern s MEGAN RIESMEYER ANNE MACDONALD-FOX Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff -? - ?„" ? ?' f ?? ? .? a .- ,,,,,,, .?-? ?F r k f` ? ""L7 - ? ??-r -' r - _ r ? 4 ,t ?» TT't 3 ?-_ ? ? . ? ,G" .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Amanda Brimmer, Plaintiff VERSUS Aaron Brimmer, Defendant No. 2008 1916 DECREE IN DIVORCE AND NOW, V Q V ST ?`l IT IS ORDERED AND DECREED THAT AND Amanda Brimmer Aaron Brimmer ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,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; NONE BY THE COURT: ?h I ATTEST: J. PROTHONOTARY y, r. P- -,4?k