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HomeMy WebLinkAbout08-2894Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cobruntO-CPBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, V. Plaintiff DEBORAH J. CARL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW . NO. 08- a8q?} Ciu?( ler? : 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 in the Office of the Prothonotary at 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 17013 (717) 249-3166 Constance P. Brunt, Esquire Supreme Court ID 929933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrun PBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. . NO. 0k. z S'Qti DEBORAH J. CARL, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, CHRISTOPHER L. CARL, by and through his attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, DEBORAH J. CARL, upon the grounds hereinafter set forth. 1. Plaintiff is CHRISTOPHER L. CARL, an adult individual, who currently resides at 42 Willow Way Drive, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is DEBORAH J. CARL, an adult individual, who currently resides at 4 42 Willow Way Drive, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 28, 1990, in Dillsburg, York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. 2 WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. Respectfully submitted, DATE: Z444 CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 ppbrunt _CPBruntLaw com Attorney for Plaintiff 3 VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce 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: 5-.l-00' CHRISTOPHER L. CARL, Plaintiff Aa o°o O W oo Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbru ntCD_C PBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. . NO. 08 - 2894 CIVIL TERM DEBORAH J. CARL, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, DEBORAH J. CARL, accept service of a copy of the Complaint in Divorce filed in the above-captioned matter. Sworn and subscribed before me EBORA J. CARL, Defendant 42 Willow Way Drive Enola, PA 17025 this day of 12008. Z4414??7_ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Constance R Brunt, Notary Public Susquehanna Up., Dauphin County MY Commission Expires Oct. 20, 2009 C') +v •-;=r,... '-.? 33'1"' "o rn W r7? _i .0 "A- Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbruntO-CPBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW V. NO. 08-2894 CIVIL TERM DEBORAH J. CARL, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 6, 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. 1 consent to the entry of a final Decree In Divorce after service of notice of intention to request entry of the decree. 1 I II 11 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: 1 41-0 DEBORAH . CARL, Defendant Cl +? .. CA.) -G f .' W. Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cobruntP-CPBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, Plaintiff V. DEBORAH J. CARL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2894 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) AND §3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree In Divorce without notice. 2. 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. 3. 1 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 Waiver of Notice 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: =, ? C (J",J DEBORAH J CARL, Defendant -2- -? tea W r . %. Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrunto_CPBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 08-2894 CIVIL TERM DEBORAH J. CARL, . Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 6, 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. 1 consent to the entry of a final Decree In Divorce after service of notice of intention to request entry of the decree. J . f- . I 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: 1-2 /-,0? HRISTOPHER L. CARL, Plaintiff na C r .4b . , Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cabruntglCPBruntLaw. com Attorney for Plaintiff CHRISTOPHER L. CARL, Plaintiff V. DEBORAH J. CARL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2894 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) AND §3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree In Divorce without notice. 2. 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. 3. 1 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. . , A? I verify that the statements made in this Waiver of Notice 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: 09 ?C.?------- C ISTOPHER L. CARL, Plaintiff -2- ° ? c.a i . R Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbruntO-CPBruntLaw.com Attorney for Plaintiff CHRISTOPHER L. CARL, Plaintiff V. DEBORAH J. CARL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2894 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 Section 3301(c) or 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: Personal service on May 12, 2008. See Acceptance of Service filed May 13, 2008. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff on January 21, 2009; by Defendant on January 21, 2009. (b)(1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs Affidavit upon the Defendant: N/A. 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: N/A. (b) Date Plaintiffs Waiver Of Notice was filed with the Prothonotary: January 22, 2009. Date Defendant's Waiver Of Notice was filed with the Prothonotary: January 22, 2009. Respectfully submitted, DATE: >G CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbrunt(&-CPBruntLaw.com Attorney for Plaintiff 1?, L 11 as •• mil' ~ • w 1?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHRISTOPHER L. CARL V. as?y DEBORAH J. CARL NO. 08-294-CIVIL TERM 2008 DIVORCE DECREE AND NOW, ?a??o.?y Z7 x,00 , it is ordered and decreed that CHRISTOPHER L. CARL, Plaintiff, and DEBORAH J. CARL, Defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The Court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. The Marital Settlement Agreement dated May 12 2008, is hereby incorporated by reference, but not merged herein. By the Court: ?* -?, 4iss\ V Attest: VV J. Prothonotary 409. ' `'