HomeMy WebLinkAbout08-6977I I
KEVIN M. BRUNNER,
Plaintiff
V.
TIFFANY L. BRUNNER,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO: ??'?j 77 L
CIVIL ACTION - LAW
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 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, One
Courthouse Square, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYERS'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
32 South Bedford St.
Carlisle, PA 17013
(717) 249-3166 OR (800) 990-9108
1 h
KEVIN M. BRUNNER,
Plaintiff
V.
TIFFANY L. BRUNNER,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUN'T'Y,
PENNSYLVANIA
NO:
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
1. Plaintiff is Kevin M. Brunner, who currently resides at 439 N. East Street,
Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Tiffany L. Brunner, who currently resides at 439 N. East
Street, Carlisle, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on June 25, 2005.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. Divorce is sought pursuant to the provisions of the Divorce Code,
§ 3301(c), and §3301(d) in that: The marriage is irretrievably broken.
7. 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 such
counseling.
8. Plaintiff does not request counseling, pursuant to §§3301(c) and 3301(d)
of the Divorce Code.
9. The Plaintiff in this action is not a member of the Armed forces.
WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce.
Date: I ?-').l - o ?
Respectfully submitted,
Andre H. Shaw, Esquire
200 S. Spring Garden Street
Suite 11
Carlisle, PA 17013
(717) 243-7135
(717)243-7872 facsimile
Attorney for Plaintiff
VERIFICATION
I, Kevin A Brunner, verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made subject to the penalties of
18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities.
Date: A
Kevin A Brunner
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"IN
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KEVIN M. BRUNNER,
Plaintiff
V.
TIFFANY L. BRUNNER,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO: 08-6977
CIVIL ACTION - LAW
IN DIVORCE
PROOF OF SERVICE
I, Andrew H. Shaw, Counsel for the Plaintiff, Kevin M. Brunner, hereby certify
that a true and correct copy of the Divorce Complaint in the above captioned case was
served upon Defendant via First Class Mail on December 6, 2008. A copy of the
Acceptance of Service is attached.
Date: Q a
Andrew H. Shaw, quire
PA Sup. Ct. ID Num. 87371
200 S. Spring Garden St., Suite 11
Carlisle, PA 17013
717-243-7135
Counsel for Plaintiff
KEVIN M. BRUNNER,
Plaintiff
V.
'T'IFFANY L. BRUNNER,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO: 08-6977
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
1, Tiffany L. Brunner, hereby accept service of the Divorce Complaint.
Date.
aow.
CERTIFICATE OF SERVICE
I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the
following document, Proof of Service, was served this date on the below named, by
placing same in the United States mail, first-class, postage prepaid thereon, addressed as
follows:
Tiffany L. Brunner
439 N. East Street
Carlisle, PA 17013
Date: /,2- 2 V
ew H. Shaw, Esquire
Sup. Ct. I.D. No. 87371
200 S. Spring Garden Street
Carlisle, PA 17013
(717) 243-7135 (phone)
(717) 243-7872 (facsimile)
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS-69
BRUNNER
KEVIN M
,
.
Plaintiff OF CUMBERLAND COUNTY, PENN All*
VS NO. 08-6977 CIVIL N
ca S9
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TIFFANY L. BRUNNER, CIVIL ACTION - LAW =?
Defendant IN DIVORCE 54=
NOTICE ""
If you wish to deny any of the statements set forth in this Affidavit, you must file a
Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the
statements will be admitted.
AFFIDAVIT UNDER
SECTION 3301(d) OF THE DOMESTIC RELATIONS CODE
The parties to this action separated on November 17, 2008, and have continued
to live separate and apart for a period of at least two years.
1. The marriage is irretrievably broken.
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.
I verify that the statements made in the affidavit are true and correct. I
understand false statements herein are made subject to the penalties of 18
Pa.C.S.§4909 relating to unsworn falsification to authorities.
Date Plaintiff
KEVIN M. BRUNNER,
Plaintiff
VS
TIFFANY L. BRUNNER,
Defendant
IN THE COURT OF COMMON PLEAS OF
OF CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-6977 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date, a true and correct copy of the
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foregoing Affidavit under §3301(d) of the Domestic Relations Code was seru?y f
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class mail to the following: Z? ?
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Tiffany L. Brunner ''QC) =°
502 Highland Court z ;° jj
Carlisle, PA 17013 , co °M
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By:
Date: f?Z _ Gr
Plaintiff
KEVIN M. BRUNNER,
Plaintiff
VS
TIFFANY L. BRUNNER,
Defendant
IN THE COURT OF COMMON PLEAS OF
OF CUMBERLAND COUNTY, PENNSYLVANIA
NO. 08-6977 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date, a true and correct copy of the
foregoing Notice of Intention to Request Entry of Divorce Decree and CounterAffidavit
was served by first class mail to the following: C=
Tiffany L. Brunner zo
502 Highland Court F.;-
Carlisle, PA 17013 ?-<
CD a•
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By.
Date:
Kai6tff-
• Complete items 1, 2, and 3. Also complete A.
item 4 If Restricted Delivery Is desired. X t
¦ Print your name and address on the reverse Addressee
so that we can return the card to you. B. Received by (Printed ) C. t of Delivery
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
D. Is delivery address different from kem 11 Yes
1. a3icJa Ad
r`wed to: If YES, enter delivery address below: 13 No
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5? od (off
n v `3 3. Service Type
1 1 I jd Certified Mail ? Express Mail
? Registered ? Return Receipt for Merchandise
? Insu ad Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes
2. Article Number
7011 0470 DDDD 4306 9484
(Transfer Anon service label)
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540
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KEVIN M. BRUNNER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
TIFFANY L. BRUNNER,
Defendant
CIVIL ACTION - LAW
NO. 08-6977 CIVIL TERM
IN DIVORCE
WAIVER OF INTENTION TO REQUEST C
ENTRY OF A DIVORCE DECREE UNDER -0X --t
§3301(C) OF THE DIVORCE CODE rnm
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1. I consent to the entry of a final Decree of Divorce without notice. -<3>
CA -.om
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2. I understand that I may lose rights concerning alimony, division of prolie>&, z
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lawyer's fees or expenses if I do not claim them before a divorce is granted. ov ;:0
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 THE FOREGOING 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 KEV M. BRUNNER
KEVIN M. BRUNNER, IN THE COURT OF COMMON PLEAS OF
Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA
VS : NO. 08-6977 CIVIL
TIFFANY L. BRUNNER, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO TRANSMIT RECORD c
To the Prothonotary: z? - ma c -0
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Transmit the record, together with the following information, to the court r
for o ;
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divorce decree: zp , ??
1. Ground for divorce: i;c-- co
Irretrievable breakdown under § (3301(c)) and -i N
§ (3301(d)(1)) of the Divorce Code.
(Strike out inapplicable section.)
2. Date and manner of service of the complaint: April 29, 2011, by certified mail
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by § 3301(c) of
the Divorce code:
by plaintiff ; by defendant
(b) (1) Date of execution of the affidavit required by § 3301(d) of the
Divorce Code: April 28, 2011
(2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon
the respondent opposing party: April 29, 2011
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:
(b) Date plaintiff's Waiver of Notice was filed with the Prothonotary:
May 25, 2011
Date defendant's Waiver of Notice was filed with the
Prothonotary:
Pro aintiff
KEVIN M. BRUNNER, IN THE COURT OF COMMON PLEAS OF ,-y
Plaintiff OF CUMBERLAND COUNTY, PENNSYLV&P
VS NO. 08-6977 CIVIL
;Aim
TIFFANY L. BRUNNER, CIVIL ACTION - LAW :z a' °C,
Defendant IN DIVORCE c?
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PRAECIPE TO TRANSMIT RECORD
` r3C
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 under418V'(sWand
§ (3301(d)(1)) of the Divorce Code.
(Strike out inapplicable section.)
2. Date and manner of service of the complaint: April 29, 2011, by certified mail
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by § 3301(c) of
the Divorce code:
by plaintiff ; by defendant
(b) (1) Date of execution of the affidavit required by § 3301(d) of the
Divorce Code: April 28, 2011
(2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon
the respondent opposing party: April 29, 2011
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: Monday, June 6, 2011,
by first class mail
(b) Date plaintiffs Waiver of Notice was filed with the Prothonotary:
Date defendant's Waiver of Notice was filed with the
Prothonotary:
Pro Se Plaintiff
lk?
KEVIN M. BRUNNER, IN THE COURT OF COMMON PLEAS OF
Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA
VS : NO. 08-6977 CIVIL
TIFFANY L. BRUNNER, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT
You are hereby given notice that ten days following the mailing of this notice, a
Praecipe to Transmit Record, together with a proposed Final Decree in Divorce, will be
filed in this matter. Exact copies of the Praecipe and the proposed Final Decree are
enclosed herewith.
If you dispute any of the information on the Praecipe or the proposed Final
Decree, you must act within this ten-day period. Any objections must be filed in writing.
If objections are not filed before the expiration of the ten-day period, this case will be
submitted to the Court for entry of the Final Decree.
Date: --
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN M. BRUNNER
V.
TIFFANY L. BRUNNER
: NO. 08-6977
DIVORCE DECREE
AND NOW, ?c..? z / Zo it is ordered and decreed that
KEVIN M. BRUNNER , plaintiff, and
TIFFANY L. BRUNNER
bonds of matrimony.
defendant, are divorced from the
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 the Court,
Cetl do e? Ivdl ?e al -/v