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HomeMy WebLinkAbout08-3048r ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BRANDI K. THRUSH, :NO. M- 30qa_ CIVIL TERM Defendant : IN DIVORCE NOTICE 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BRANDI K. THRUSH, :NO. _o f- 3ayP CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Roger D. Thrush, who currently resides at 15 Beecher Drive, Carlisle, Penn Township, Cumberland County, Pennsylvania, 17015. 2. Defendant is Brandi K. Thrush, who currently resides at 23 Mountain View Terrace, Newville, Upper Frankford Township, Cumberland County, Pennsylvania, 17241. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 8, 1997 in Newville. Pennsylvania. 5. Plaintiff and Defendant separated on or about July 2001. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. Neither party is now serving in the United Armed Forces; however, both parties had prior Military Service in Active "Reserve" Status. 10. Plaintiff requests the Court to 5'll3?0? Decree in Divorce. L Paul Bradford Orr, Esquire Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 71786 M? VERIFICATION I verify that the statements made in the foregoing Petition 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: S OThrush, Petitio r I?°dd ' O co-- '" n o O V ?,.11,T'f ? mar` 1 ? j n C- ? ti tW ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BRANDI K. THRUSH, :NO. 08-3048 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of myself, the Defendant, Brandi K. Thrush, in the above-captioned action. r-a Date: By:4r - ndi k. Thru? Defendant c; rn c? ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDI K. THRUSH, Defendant : CIVIL ACTION - LAW NO. 08-3048 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(d) of the Divorce Code was filed on May 14, 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 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. j--7, Date: / C) --?? r D. hrush, Petitione F THE i r`- 1' 2009 JUL J I A, 10: ?r N Ty i? ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW BRANDI K. THRUSH, :NO. 08-3048 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of 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 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?3d©0 9 ??? r D. rush, PI i 2009 JU 31 All'i 10: ?;. 2 ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDI K. THRUSH, Defendant CIVIL ACTION - LAW :NO. 08-3048 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(d) of the Divorce Code was filed on May 14, 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 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. a Date: Brandi K. Thrush, Defe ant ''' ?. Un ' 9 i4JL 3 1 P2.ii Icy ip') ROGER D. THRUSH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDI K. THRUSH, Defendant CIVIL ACTION - LAW NO. 08-3048 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of 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 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:_ -? joq Br . Thrush, efendant FL 2009 JUL 31 ALI I'(D: C ROGER D. THRUSH, Plaintiff V. BRANDI K. THRUSH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 08-3048 IN DIVORCE 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 Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: July 14, 2008, by U.S. Mail, postage prepaid, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) & (d) of the Divorce Code: by the Plaintiff on July 30, 2009; by Defendant on July 30, 2009. 4. Related claims pending: NONE 5. Date Plaintiff's Waiver of Notice in §3301(d) Divorce was filed with the Prothonotary: July 31, 2009. 6. Date Defendant's Waiver of Notice in §3301(d) the Prothonotary: July 31, 2009. Date: ot By: Paul Bradford Orr, E 50 East High Street Carlisle, PA 17013 (717) 258-8558 was filed with uire FL} nr THE ' ""'M 2009 i : _ 51 ri'111 7 ?. ??`Jlt ?r ?t', ROGER D. THRUSH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. BRANDI K. THRUSH NO. 3048 of 2008 DIVORCE DECREE 0 it is ordered and decreed that AND NOW, 41 ROGER D. THRUSH, plaintiff, and BRANDI K. THRUSH , 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 By Attest: J. Prothonotary C ??ltiacti ? ?? L'