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Home My WebLink About04-0579 F;\User FolderlFinn Docs\Gendocs2004\3442_1div_complaint.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA C. BROSET, Plaintiff v. CIVIL ACTION - LAW L...- NO, 2004- ..5'11' ~t"u~L T~ WILLIAM R. BROSET, Defendant 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty (20) days ofthe date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Street Carlisle, Pennsylvania 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA C. BROSET, Plaintiff v, CNlL ACTION - LA W ~ NO, 2004- S79 Ct"OiL tEA-""\. WILLIAM R. BROSET, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this I b+)day of February, 2004 comes Plaintiff, Laura C, Broset, by and through her attorneys, Hanft & Knight, P,C" and files the following Complaint in Divorce, and in support thereof avers as follows: I. The Plaintiff is Laura C. Broset, who resides at A25 Forbes Avenue, Carlisle, Cumberland County, Pennsylvania 17013, 2, The Defendant is William R. Broset, who resides at 460 Sumner Road, Room 308B, Carlisle, Cumberland County, Pennsylvania 17013, 3. The Plaintiff and Defendant are sui juris, and both are been bona fide residents of the Commonwealth of Pennsylvania and Plaintiff has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce, 4, The parties were married on February 20, 2003, in Augusta, Georgia, 5, The marriage is irretrievably broken, The foregoing facts are averred and brought under Section 330l(c) or 330l(d) of the Divorce Code of 1980, as amended, 6, The Plaintiff has been advised ofthe availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same, 7. Plaintiff is an active duty member of the United States Army, 8, Defendant is an active duty member ofthe United States Army, WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, HANFT & KNIGHT, P,C, C;:b-A MIchael J, Hanft, Esquire Attorney ID No, 57976 Sean M. Shultz, Esquire Attorney ID No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff VERIFICA nON The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the Complaint in Divorce, The language ofthe document is that of counsel and not my own, I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content ofthe document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties, ~C~ F: IUser FolderlFirm DocslFonns\Family LawlDivorcelverificaliondivorce. wpd ~~~ '- ~ 8 ~ ~ pc! t, J- ,......., r) C2 8 :C-ii s:~ ..r- ._~ '...'"--. ....", "1:": ". r--; fll C0 '...-. .- ~:1 (....) -~ -' -,::> 9 -- D _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA C, BROSET, Plaintiff v. CIVIL ACTION - LAW NO, 2004- 579 WILLIAM R. BROSET, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, William R. Broset , the Defendant in the above captioned matter, hereby accept service of the Complaint in Divorce filed on February 10, 2004, in the above captioned matter, ~~ --- William R. Broset Dated:O~ ~ Oty F IUser Folder\Finn DocsIGendocsIGendocs2004\344Z_1accservice_wpd g .:::: -ate fY,\ ; Z:Jc ZC UJ,!;- :..c'3'_" ~c J~(--) ?~ I:; :Pc. z 2 ,.., -= 5? :l!: :P~ -< I 0' -0 :>: r:-? ~ ..... :I:-n rllr -orn -09 ~~~ :r.::-," Oc '5;":("1":'" r) :::. ~ '-< - ..s;) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA C. BROSET, Plaintiff CIVIL ACTION - LAW v. NO. 2004- 579 WILLIAM R. BROSET, Defendant IN DIVORCE AFFIDAVIT OF CONSENT -- STATE OF I ex QS COUNTY OF \\ill \i QJ<\SO\\ ) SS. ) 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 10, 2004. 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 ofa final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. 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 prior to a Divorce Decree being handed down by the Court. 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. ;/~--{2fi- ,< 11 Date: .t)J(l(U-j;)T ,2005 Laura C. Broset Sworn to and subscribed before me this c2 day ofS~ Ll CU'1 ' 2005. -1:) 1-:-1 .._.~ 'i'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA LAURA C. BROSET, Plaintiff CIVIL ACTION - LAW v. NO. 2004- 579 WILLIAM R. BROSET, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &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 in 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 ofthe 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. 94904 relating to unsworn falsification to authorities. Date: dz:}\ 05 27<- Laura C. Broset .-<-j I,,,,) r'0 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA LAURA C. BROSET, Plaintiff CIVIL ACTION - LAW v. NO. 2004- 579 WILLIAM R. BROSET, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER !l330HC) 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! 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. 94904 relating to unsworn falsification to authorities. Date: ~), ,1 05 qE;~;.- C William R. Broset - L-- ~~:y~\ _,oj"~ 'U) ~ ...-> $ d' ;'1" C ",,,,, N N "'" - ....-'" ~::\~.-- ~;~(l Y'S ~2 Q. :?-n rnf:':: _om. 7''1' ',,)G' :J ~'"'- '1--.--('\ S~c.") ...-(0 9 'Z: !l - .- 0" , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURA C. BROSET, Plaintiff CIVIL ACTION - LAW v. NO. 2004- 579 WILLIAM R. BROSET, Defendant IN DIVORCE AFFIDAVIT OF CONSENT STATE OF ) : SS. ,) COUNTY OF 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 10, 2004. . , ' 2. The marriage of ~Iaintif~ ~~, D:!~I;l~t i,s :ir,i-etrievably broken and ninety days have elapsed from the date of filmg and stm:1ce-Mlle C.OIp.,pfamt. ,"'" , ....... .i 3. I consent to the entry of a",frftffj;~edree of Divorce after service of notice of intention to request entry of the Decree, ' 4. 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 prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I understand thai false statements herein are made subject to the penalties of 18 Pa. C. S., Section 4904 relating to unsworn falsification to authorities. Date: A "y / I , 2005 c:iih_~ -::- William R. Broset Sworn to and subscribed before me this ~pa~of ~ () ':-? ' 2005~ ~~"." AIe'''~ '.\~, ~- . . , " 4::!"', - .. .~" Notary Pubhc c.€. \bu . 5 ".'!5iJ{'ifJ~ , .'It ~c..\JS~ '. ".~~, ~, :r I\t\),' M..a 7-':;,'0 ",.," ~ ~7' , ",. ' ~ "', !~-::'~~{:, ~. ':-t.. '-~ .- , . ?":;; .,0 /.,'~t,,. "'~~~.,.,,,,,'!I. ,~"'fii ~', ....... d!{.. -1ft" .JiIa" ...,,'I(!i~' -il'/.;j,;;J-:- If).i!-'" ......., " Q ~ <"" ;;~,.~, ~)),~, \- ~ ~ ~ ...... ctJ r,j rV ~,~~., T " ~.~~ ~ ::.<. Q\ S;:!;\ '"';;:D :'{1C? (?~~!. ,"c -r\ '6~ ~~"'~" ~1 '~ ':2 ...., .:;z:. -- .- C1' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA LAURA C. BROSET, Plaintiff v. CIVIL ACTION - LAW NO, 2004-579 WILLIAM R. BROSET, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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) of the Divorce Code, 2. Date and manner of service of the Complaint: served on Defendant by hand delivery on May 5, 2004. 3, Date of execution of the Plaintiffs Affidavit of Consent required by Section 3301 (c) of the Divorce Code; February 7,2005; by the Defendant; August 11, 2005, 4. Related claims pending: None. 5, Date Plaintiff s Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: February 7, 2005. Date Defendant's Waiver of Notice m S3301(c) Divorce was filed with the Prothonotary: August 22, 2005. Date: August /1 ,2005 S;A~~-- Sean M. Shultz, EsqUire Attorney LD, No, 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 F:\User Folder\Firm DocslGel1docs2005\3442_J praecipe.wpd Attorneys for Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . LAURA c. BROSE!'. Plaintiff VERSUS . WILLIAM R. BROSET, . Defendant . AND NOW, . PENNA. . . No. 2004-579 . . DECREE IN DIVORCE ~~ , 2005 . . . y ef' ~:or A.~ . . . , IT IS ORDERED AND . . DECREED THAT LAURA C. BROSET . . , PLAINTIFF, AND WILLIAM R. BROSET , 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; . . . . rJ6~ . . . . . . . . . . J. . . . . . . PROTHONOTARY . . . . _,<lip y~~ YJ-(7[f ~Y$ ~~;r~ 5/7<'''-'' . ' . a.- I.~ ..' .. ,a!' -