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HomeMy WebLinkAbout01-6614BRIAN L. BRUNNER, Plaintiff Ve JULIA M. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O~-~q CIVIL 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE ARANNULMENT 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 BRIAN L. BRUNNER, Plaintiff Ve JULIA M. BRUlglFER, Defendant · ' IN THE COURT OF COMMON PLEAS = CUMBERLAND COUNTY, PENNSYLVANIA : NO. O~ - ~. ~ Civil : IN DIVORCE COMPLAINT AND NOW comes Plaintiff, by his attorney, Kent H. Patterson, and files this Complaint in Divorce, based upon the following= 1. Plaintiff, Brian L. Brunner, is an adult residing at 121 Pine Hill Road, North Middleton Cumberland County, Pennsylvania (Carlisle, PA 17013). 2. Defendant, Julia M. Brunner, is an adult individual residing at 175 East High Street, Apartment No. 4, Borough of Carlisle, Cumberland County, Pennsylvania (Carlisle, PA 17013). 3. Plaintiff and Defendant have been bona fide residents in the Co, mLonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 7, 1991 in Carlisle, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties· individual Township, 6. Plaintiff and Defendant are both citizens of the United States of America. 7. Defendant is not a member of the A~.Led Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA (717) 238-4100 17101 VERIFICATION I, Brian L. Brunner, verify that the statements in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Brian L. Brunner I BRIAN L. BRUNNER Plaintiff JULIA M. BRUNNER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-6614 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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 A M. BRUNNER BRIAN L. BRUNNER ~ IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01-6614 CIVIL : JULIA M. BRUNNER, : Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Section 4909 relating to unsworn falsification to authorities. Date ./~JULIA M. BRUNNER BRIAN L. BRUNNER Plaintiff V. JULIA M. BRUNNER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6614 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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. Da~e BRIAN L. BRUNNER ° r. LSm BRIAN L. BRUNN-ER Plaintiff Ve JULIA M. BRUNNER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6614 CIVIL : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELIN~ 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. 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 A M. BRUNNER BRIAN L. BRUNNER Plaintiff JULIA M. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6614 CIVIL IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of e divorce decree· 1. ® Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date .and manner o.f service of the comDlaint: On November 27, 2001 Dy U.S. certified mail. A certificate of service has been filed with the Prothonotary. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on August 7, 20021 by defendant on March 22, 2002. Related claims pending: None. No economic clainm have been raised. Date Plaintiff,s waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: August ~, 2002. Date defendant,s waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: April 22, 2002. Kent H. Patterson Attorney for the Plaintiff 221 Pine Street Harrisburg, PA 17101 (717)238-4100 IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. BRIAN L. BRUNNERf Plaintiff VERSUS JULIA M. BRUNNER, Defendant NO. 01-6614 DECREE iN DIVORCE DECREED THAT AND AND NOW, %,~, ~ BRIAN L. BRUNNER , 2002 JULIA M. BRUNNER ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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; NONE. ThE Cour : ATTIC/I~' 0 - ' ~ '~ PROTHONOTARY BRIAN L. BRUNNER, Plaintiff JULIA M. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6614 Civil IN DIVORCE .... C~LISLE PA 17013 ~ .o~t~e $ f,0.57 I Return Receipt Fee I ~l~nt's Name (P/ea~ be comp/stay I]- i Str6et, Apt. No4 or PO Sox No. -- .... SENDER: · Complet~ items 1 and/or 2 for addit~rv_[ces. · Complete items 3, 4a, and 4b. ~.~ ~l~l~ll~ll~.--__ following services (for an · Pdnt your name and address on the~ turn this extra fee): card toyou. -'-~w · n~ · a Attach this form to the front of the melll~,~-I~f ~111~ not 1.D Addressee's Address · Write "Return Receipt Request~d"o~ ~~ number. · The Return Receipt will show to whom the affl'~l~'~Fa]R~ll~ I~ the date delivered. Consult postmaster for fee. 3. Article Addressed to: 4a. Article Number s ce- / o/3 ! 5. Received By: (Print Name) 6. Signature: (Addressee o~ ;4'~er~ m PS o~811, Decem~r 1994~ I--I Registered ~[ Certified ~ [] Express Mail [] Insured vL~ [] Return Receipt for Merchandise [] COD "~ and fee is paid) 102595-98-Bo0229 Domestic Return Receipt