HomeMy WebLinkAbout08-7493IN THE COURT OF COMMON PLEAS
Cumberland COUNTY PENNSYLVANIA
DOMESTICS RELATIONS DIVISION
FAMILY COURT
Andre E. Brown
PLAINTIFF
VS
Tahitia Brown ,
DEFENDANT
CIVIL ACTION NO.Of- 93
PRAECIPE TO PROCEED INFORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow ---Andre E. Brown , Plaintiff in the
above captioned matter, to proceed Informs Pauperis.
I, Andre E. Brown , PRO SE Plaintiff, do hereby
certify that Iam presently incarcerated in the State correctional
Institute at SCI Camp Hill and unable to pay the costs of
filing this action of divorce.
RES CTFULLY SUB ITTED,
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IN THE COURT OF COMMON PLEAS
Cumberland COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS DIVISION
FAMILY COURT
Andre E. Brown ,
PLAINTIFF
SS#: 213-62-5688
VS
Tahitia Brown
DEFENDANT
S S # : 218-89-5247
NAME OF FILING PARTY:
• CIVIL ACTION #-_Qy..?q93
PETITION FOR DIVORCE
Andre E. Brown
STATUS OF FILING PARTY: X PLAINTIFF DEFENDANT
TYPE OF FILING: SUPPORT CUSTODY X DIVORCE
FULL DESCRIPTION OF ENCLOSED MOTION:
Petition or uncontested divorce
IN THE COURT OF COMMON PLEAS
Cumberland COUNTY PENNSYLVANIA
DOMESTIC RELATIONS DIVISION
FAMILY COURT
Andre E Brown
PLAINTIFF
j'
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Tahitia Brown
DEFENDANT
CIVIL ACTION NO. 0,?-?49'3
PETITION FOR DIVORCE
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
AND NOW comes the Plaintiff and for his cause of action for
divorce against the defendant alleges and states the following:
1) This action for divorce is-between plaintiff, who
is a resident of the commonwealth of pennsylvania and has been
such for more than twelve months prior to the filing of this
action, and the defendant, who is a resident of the state of
Pennsylvania
2) This action in divorce is filed persuant to the
Divorce Code of the commonwealth of Pennsylvania, and intends
to be an uncontested action in divorce due to abandonment and-
irreconcilable differences.
3) Defendant in this case is Tah;_ia Brown ,
whose address is currently known to the defendant as _ 7095
S. Sentinel an York. Pennsylvania 17403
4) Plaintiff in the above captioned matter is Andre
EcBrown , who is currently incarcerated at the State
Correctional Institute at Camp Hill , whos address
is P.O. Box 200, Camp Hill, Pennsylvania 17001-0200
5) Plaintiff has been incarcerated since the -26
day of -F, Ey , 2007
6) Plaintiff avers that plaintiff and defendant have
not held a residence together as man and wife since the Thirdday
of Octomber , 20;06
7) Plaintiff avers that there are no marrital assetts
to be divided between the parties.
8) Plaintiff avers that there are no minor children
or otherwise between the parties and that custody and support
and visitation will not be at issue.
-WHEREFORE, plaintiff prays that the court will grant
this uncontested action in divorce.
RE CTFULLY SUBMITTED,
PLAINTIFF PRO SE
CLERK OF COURTS
Cumberland COUNTY COURTHOUSE
IN RE: CIVIL ACTION FOR DIVORCE
TO THE CLERK:
PLAINTIFF HEREBY ELECTS THAT ALL PROCEEDINGS IN THE ABOVE CAPTION
MATTER SHALL BE UNDER THE PROVISIONS OF THE DIVORCE CODE OF
THE COMMONWEALTH OF PENNSYLVANIA. IT IS FURTHER UNDERSTOOD THAT
APPROPRIATE PLEADINGS MUST BE FILED WITHIN TWENTY:;(20) DAYS
FROM THE DATE HERE TO EFFECTUATE THIS ELECTION.
DATE:__
RESPECTFUL
PLAINT PRO SE
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Cumberland COUNTY, PENNSYLVANIA
DOMESTIC RELATIONS DIVISION
FAMILY COURT
Andre E. Brawn
PLAINTIFF
VS.
Tahitia Brown
DEFENDANT
CERTIFICATE OF SERVICE
AND NOW, Andre E. Brown , Plaintiff in the above captioned matt
does hereby file this certificate of service, indication that the enclosed petiti
was filed and served on the Defendant, Tahitia Brown , at the address liste
below, and was served on the noted date and in said manner.
THIS ACTION IS HEREBY SERVED UPON the following:
NAME: Tahitia Brown
ADDRESS: 7095 S. Sentinel
En. York, Pa.
17403
Date of service: Ae&?Z?Z/20V
Method of Service: A/?
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esp fully Submitted
7IFF 0 ,SE
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ANDRE E. BROWN IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
TAHITIA BROWN,
Defendant NO. 08-7493 CIVIL TERM
ORDER OF COURT
AND NOW, this 6 h day of January, 2009, upon consideration of Plaintiffs
Praecipe To Proceed in Forma Pauperis, the Plaintiff is hereby authorized to proceed in
forma pauperis.
BY THE COURT,
l°
J. esley r, Jr., J.
Andre E. Brown, HM-7257
SCI - Camp Hill
P.O. Box 200
Camp Hill, PA 17001-0200
Plaintiff, pro Se
Court Administrator
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