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Home My WebLink About04-0775WILLIAM L. BRINTON, Plaintiff JENNIFER BRINTON, Defendant : CIVIL ACTION - LAW : DIVORCE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NOTICE TO DEFEND ~ 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 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, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CI/MBERLA/QD COUNTY LA~-YER REFERRAL SERVICE ONE COURTHOUSE SQUARE CARLISLE PA 17013 (717) 240-6195 Le hah demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGAD0 IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFON0 A LA 0FICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJ0 PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAW"ZER REFERRAL SERVICE ,ONE COL,'"P~nTTRR ~Q~AR~ 3A~ ~. ,,~f~.~,,.,~x ~/. ~AMLIo~m PA 17013 .~717) 240-6195 ' WILLIAM L. BRINTON, Plaintiff JENNIFER BRINTON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW DIVORCE COMPLAINT FOR DIVORCE UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, William L. Brinton, by his attorney, Mark A. Mateya, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth: 1. Plaintiff is WILLIAM L. BRINTON, who currently resides at 407 First Street, County, Pennsylvania 17013. an adult Carlisle, individual Cumberland 2. Defendant is JENNIFER BRINTON, an adult individual currently resides at 7073 Carlisle Pike, Lot #85, Carlisle, Cumberland County, Pennsylvania 17013. who 3. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 19, 1994, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 6. Neither the Plaintiff nor the Defendant are presently serving as members of the United States Armed Services. 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 of Divorce. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree in Divorce in the above matter. Respectfully submitted, Dated: Mark A. Mateya ~ Attorney I.D. No. 78931 407 North Front Street Harrisburg, PA 17108-1848 (717) 238-7151 Attorney for Plaintiff VERIFICATION I, WILLIAM L. BRINTON, verify that the facts set forth in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. WILLIAM L. BRINTON WILLIAM L. BRINTON, Plaintiff JENNIFER BRINTON, Defendant : IN THE COURT OF COMMON PLEAS ~ CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-775 : : CIVIL ACTION - LAW ' DIVORCE --AFFIDAVIT OF SERVICE AND NOW, this 1._~5th day of M_~ch~ 2004, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: 2004. A Complaint for Divorce was filed to the above term and number on February 23, 2. On February 25, 2004, a certified copy of the Complaint was sent to the Defendant via certified mail, restricted delivery, return receipt requested pursuant to Pa. R.C.P. 1920.4. 3. On February 25, 2004, a certified copy of the Complaint was set to the Defendant via first class mail, postage prepaid. A copy of the Certificate of Mailing is attached hereto as Exhibit 'A' and is incorporated herein by reference. 4. On or about March 1, 2004, undersigned counsel for Plaintiff received the return receipt card signed by the Defendant on February 27, 2004. Said receipt is attached hereto as Exhibit "B" and is incorporated herein by reference. Respectfully submitted, ;~k A.~Iv}a ~-'-teya' l~sq Uire Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE--POSTMASTER Received From: One piece of ordinaw mail addressed to: PS Form 3817, Mar. 1989 EXHIBIT "A" postage Total Postage & Fees · 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 rnailpiece, or on the front if space permits. 1. Article Addressed to: PS Fon m Agent D. Isdeliveryaddreesdiffemnt flora item 17 [] Yes If YES, enter delive~j address beJow: [] NO 3. Se~ice Type ~J~Cert~fled Mail [] Express Mail 02595-01 -M-2509 EXHIBIT "B" _CERTIFICATE OF SERVICE I, Mark A. Mateya, Esquire, hereby certify that I have served a copy of the foregoing Affidavit of Service on the following person(s) by depositing a tree and correct copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Dauphin County, Pennsylvania addressed to: Jennifer Brinton 7073 Carlisle Pike Lot #85 Carlisle PA 17013 Dated: 407 North Front Street Harrisburg PA 17108-1848 717 238-7151 WILLIAM L. BRINTON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 04-775 JENNIFER BRINTON, : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 23, 2004. 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 in 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. DATED: William L. Brinton Plaintiff WILLIAM L. BRINTON, Plaintiff JENNIFER BRINTON, Defendant : IN THE COURT OF COM~ON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04-775 : : CIVIL ACTION - LAW : DIVORCE 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. William L. B~inton Plaintiff WILLIAM L. BRINTON, Plaintiff JENNIFER BRINTON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 04-775 : : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT t. A Complaint in Divorce under Section 3301(c} of the Divorce Code was filed on February 23, 2004. 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 in 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. DATED: J~'~ ~'r' Bri~ton D~fendant WILLIAM L. BRINTON, Plaintiff JENNIFER BRINTON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND ,COUNTY, PENNSYLVANIA : NO. 04-775 : CIVIL ACTION - LAW : DIVORCE 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 Je~ ~e ~ Brinton ..... D~fendant William L. Brinton, Plaintiff IN THE COURT OF CC~ON PLEAS OF C~BERLAND COUNTY, PENNSYLVANIA NO. 04-775 CIVIL x~ 2004 vs. Jennifer Brinton, Defendant 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. Grounds for divorce: irretrievable breakdown% under Section 3301 (c) ~i ~d~i~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the co~plaint: By Certified Mail on 2/23/04 and by U.S. first class mail on 2/23/04 3. Cu~,~lete either Paragraph A. or B. A. Date of execution of the affidavit of c~]sent required by Section 3301 (c) of the Divorce Code: by the plaintiff by the defendant 6/9/04 B. (1) Date of execution of the plaintiff's affidavit requJ~ed by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code May 28, 2004 by way of U.S. First Class Mail Attoi~ey ' tiff/L_ IN THE COURT OF COMMON PLEAS William L. Brinton, Plaintiff OF CUMBERLAND COUNTY STATE OF p~~ VERSUS Jennifer Brinton, Defendant PENNA. NO. 04-775 AND NOW, DECREED THAT DECREE IN DIVORCE William L. Brinton ~,~;~1~ IT IS ORDERED AND , PLAINTIFF, AND Jennifer Brinton ,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; J. ATTEST: PROTHONOTARY IN TItE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : Vs : File No. Defendant : ** IN DIVORCE NOTICE TO RESUME PRIOR SU~'dNAME Notice is hereby given that the Plaintiff/defendant in the above matter, [select one l~y marking '~"] __ prior to the entry of a Final Decree in Divorce, or c./after the entry of a Final Decree in Divorce dated hereby elects to restmae the prior surname of ~ (L-f~. , and gives tiffs written notice avowing his / her intention pursuagt to the pr~¢siorcj~54 P.S. 704. V COmV~ONW~AJ~Tg~ OF?EN~SY~V~,r~ ) COUNTY o~ theo~-- d~y oFJ v2~ ,20~, before me, the ~rothono~y or the notary publ/c, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. seal.Iy Wimess Where°f, I have hereunt° set ~x~d hereunt° set~..~h~ and 7cial NOTAF~A!. S Carlisle, CUmber/an