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Home My WebLink About08-7020iGv??*?iph is C, "Y k---- Ji TWOK 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 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AN 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 18360 PH: (717) 249-3166 Kenneth J. Brownlee, Jr Plaintiff, ) COURT OF COMMON PLEAS; CUMBERLAND V. ) COUNTY, PENNSYLVANIA TERM, ?..008 0?- Amanda A. Brownlee ) NO. Defendant. ) IN DIVORCE COMPLAINT UNDER SECTION 3301(c) -ao OF THE DIVORCE CODE Plaintiff respectfully represents: 1. Plaintiff is Kenneth J. Brownlee, Jr. who currently resides at 920 Chester Road, Enola, PA 17025, in the County of Cumberland, Commonwealth of Pennsylvania, since August 20, 2008. 2. Defendant is Amanda A. Brownlee who currently resides at 240 Princeton Avenue, Palmerton in County of Carbon, Commonwealth of Pennsylvania, since April 27, 2007. 3. Plaintiff and Defendant are sui juris and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on May 15, 2005, at Monroe County, Commonwealth of Pennsylvania. Attached to this Complaint as Exhibit "A" is a a? certified copy of the marriage certificate. Ili- 4-3 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. ' WHEREFORE, your Plaintiff respectfully requests the Court enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. ? -?v 12 - /-'a COMMONWEALTH OF PENNSYL' ,v 9 0 2 Notadal Seal Jennifer N. Grove, Notary Public Silver Spring Twp., Ctxnberland County My Conunisslon E)Otres Jan. 28, 2012 Member, Pennsylvania Association GEORGE J. WARDEN Prothonotary and Clerk of Courts Prothonotary / Clerk of Court Clerk of Orphan Court / Courts of Common Pleas 43rd JUDICIAL DISTRICT OF PENNSYLVANIA MONROE COUNTY COURTHOUSE - ROOM 312 STROUDSBURG, PENNSYLVANIA 18360-2190 570-517-3385 KATHLEEN M. MENEILLY Chief Deputy Clerk of Courts DAVID J. WILLIAMSON Solicitor CERTIFICATION OF EXCERPTS FROM MARRIAGE LICENSE RECORD STATE OF PENNSYLVANIA COUNTY OF MONROE I, GEORGE J. WARDEN , CLERK OF ORPHANS' COURT in and for said County, hereby do certify that the records in this office, as contained in Marriage License Docket, Vol. 116 Page49970, show that Marriage License No. 49970 was issued on May 9, 2005 to BRO WNL EE KENNETH J JR (Last, First, Middle) and WARD AMANDA ANN that the Return to (Last, First, Middle) - said -- ..License sho;fs thd, ;6aldpersons were married on May 5, 2005 at STROUDSBURG, PA by ROBERT R. SHANK BROWNLEE KENNETH J JR stated his date of birth was December 11, 1982 his birthplace DOVER NJ and the names of his parents KENNETH BROWNLEE SR CARLA BROWNLEE and WARD AMANDA ANN stated her date of birth was August 11, 1983 her birthplace BUCKS PA and the names of her parents JOHN FREDERICK WARD BERNADETTE MARIE MACFARLANE IN TESTIMONY WHEREOF, I have hereunto set my hand and the seal of said court this 30th day of May , A.D., 2008 G RGE W DEN CL RK OF OR ANUS' COURT l r-a cr-,> CD c, c O Kenneth J. Brownlee, Jr. ) Plaintiff, ) COURT OF COMMON V. PLEAS; CUMBERLAND . ) COUNTY, PENNSYLVANIA Amanda A. Brownlee ) O, TERM, 2008 NO. 730 Defendant. ) IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce under section 3301(c) of the Pennsylvania Divorce Code. Date: DEFENDANT ????- h. fr„-x, Ivy MAILING ADDRESS Pik NOTE: This document must be filed with the Prothonotary. CC" SO Kenneth J. Brownlee, Jr. Plaintiff, ) COURT OF COMMON PLEAS; CUMBERLAND V. ) COUNTY, PENNSYLVANIA TERM, 2008 Amanda A. Brownlee ) NO. U k- ?Dail Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under § 3301(c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I 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. Date: 3-11- 200 (Plaintiff)/(Bt? N c ? o . c7 n E 3 LL Kenneth J. Brownlee, Jr. Plaintiff, ) COURT OF COMMON PLEAS; CUMBERLAND V. ) COUNTY, PENNSYLVANIA TERM, 2008 Amanda A. Brownlee ) NO. N- 7090 Defendant. ) 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 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: 3 ? ?? -.Zap Plaintiff ? ? ?? ..v ? ? ' ? , . ? ? ?> - - _ --? c ?.? - ,? ?® - :. -??, _ t .. _ ?; .: ,' ?-? t_-- .,? ;?. ?..?t .? :-? Kenneth J. Brownlee, Jr. Plaintiff, ) COURT OF COMMON PLEAS; CUMBERLAND V. ) COUNTY, PENNSYLVANIA TERM, 2008 Amanda A. Brownlee ) NO. ®f- 70,M Defendant. ) 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 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: )ZMA A111 a"" OW Defendant ? ? C7 Mal ~^a •l• ?, tom... tea. -l'i '?'?? _: Kenneth J. Brownlee, jr. V. Amanda A. Brownlee To the Prothonotary: Plaintiff, ) COURT OF COMMON PLEAS; CUMBERLAND COUNTY, PENNSYLVANIA TERM, 2008 NO. 68 _ 7a). 0 Defendant. ) IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under § (3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: -y1- is 2009 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 dim 3 - I 1 " 3 by defendant "Aajz 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: `3- ) 8 -- 260q Date defendant's Waiver of Notice was filed with the prothonotary: -3-)8-2001 '3 - 16-,7001 M co 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Kenneth J. Brownlee, Jr V. Amanda A. Brownlee NO. 08-7020 DIVORCE DECREE AND NOW, r t eA t 4' , zero 9 , it is ordered and decreed that Kenneth J. Brownlee, Jr , plaintiff, and Amanda A. Brownlee , 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 the Court, Atte i J. 7Prothonotary 5