HomeMy WebLinkAbout09-0348BRADLEY L. CORNMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2009 - 3 Ilk CIVIL TERM
HEATHER R. CORNMAN,
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 in 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, Carlisle, Pennsylvania 17013.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing.
BRADLEY L. CORNMAN,
Plaintiff,
V.
HEATHER R. CORNMAN,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009 - 3 y? CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301(C) AND D) OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Bradley L. Cornman, by and through his attorneys, Irwin
& McKnight, P.C., and files this Complaint in Divorce against the Defendant, Heather R. Cornman,
representing as follows:
1. The Plaintiff is Bradley L. Cornman, an adult individual residing at 231
Springfield Road, Shippensburg, Pennsylvania 17257.
2. The Defendant is Heather R. Cornman, an adult individual currently residing at
231 Springfield Road, Shippensburg, Pennsylvania 17257.
3. The Plaintiff and Defendant have been residents of the Commonwealth of
Pennsylvania at least six months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on May 24, 1994 in Shippensburg,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
By:
Respectfully submitted,
IRWIN & McKNIGHT, P.C.
Marcus AJ McKn' ht, I, Esquire
Supreme Court I. o. 25476
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Dated: January 23, 2009
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
BRADLE L. CORNMAN
09
Date: 1123
BRADLEY L. CORNMAN,
Plaintiff,
V.
HEATHER R. CORNMAN,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009- CIVIL TERM
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. 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.
2. I understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
BRADLEY L. CORNMAN
Date: / S Q 9
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BRADLEY L. CORNMAN,
Plaintiff,
V.
HEATHER R. CORNMAN,
Defendant.
CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I, P. RICHARD WAGNER, ESQ., counsel for the defendant in the above-captioned
divorce action, hereby verify that I accepted service on behalf of my client, of the Complaint in
Divorce filed under Sections 3301(c) and 3301(d) of the Divorce Code on or about January 30,
2009.
. RIC WAGNER, ESQ.
Date:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
: SS:
On this, the v19 of January 2009, before me, the undersigned officer, personally
appeared P. RICHARD WAGNER, ESQ., known to me to be the person whose name is
subscribed to the above instrument and acknowledge that he executed same for the purposes
therein contained.
Notary Public
COMMONVVEA ? H OF PENNSYLVANIA
tvota-rial Seal
Debra K Spinner, Notary Public
City Of Harrisburg, Dauphin County
My Commission E?ires Sept 3, 2011
Member, Penrisyiu? ; s; ,arsncie?:ian of Notaries
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
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BRADLEY L. CORNMAN,
Plaintiff,
V.
HEATHER R. CORNMAN,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
20091. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 23,
.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
Date:
L Y/Y L. CORNMAN
Plaintiff
2 E0 9 1 71 i'. Y 2 a P, i 2•
BRADLEY L. CORNMAN,
Plaintiff,
V.
HEATHER R. CORNMAN,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: J "/,z? ?09
L L. CORN MAN
Plaintiff
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BRADLEY L. CORNMAN,
Plaintiff,
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
HEATHER R. CORNMAN,
Defendant.
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 23,
2009.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn
falsification to authorities.
evll & O.
Date: MI O ?
HE R. CORNMAN
Defendant
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BRADLEY L. CORNMAN,
Plaintiff,
V.
HEATHER R. CORNMAN,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
4HATTHERRIL CORNMAN
Defendant
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2C 9.IgJr 17 p,"i f
S. J.t '! y S?t
BRADLEY L. CORNMAN,
Plaintiff,
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
HEATHER R. CORNMAN,
Defendant.
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. 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.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I participate in
counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
HEATHER ?R.CORNMAN
Defendant
2009 JJ N 17 P11
-1 J
h . t t ?.
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this day of January 2009 by and between BRADLEY
L. CORNMAN, (hereinafter referred to as "HUSBAND") and HEATHER R. CORNMAN,
(hereinafter referred to as "WIFE")
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on May 24, 1994, in
Franklin County, Pennsylvania. The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
a. is represented by counsel of his or her own choosing;
b. is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
c. enters into this Agreement voluntarily after receiving the advice of counsel;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully read each provision of this Agreement; and
f, fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect,
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
3
7.
REAL ESTATE: The parties own real estate located at 231 Springfield Road,
Shippensburg, Cumberland County, Pennsylvania. Upon the completion of the mortgage
refinance HUSBAND agrees to convey by deed his right, title and interest in the property to
WIFE. WIFE agrees to refinance the mortgage into her own name on or before February 15,
2009.
8.
SPOUSAL SUPPORT: HUSBAND will not provide spousal support, alimony pendente
lite, or alimony to WIFE before or following the divorce. WIFE will not provide spousal
support, alimony pendente lite, or alimony to HUSBAND before or following the divorce.
9.
CHILD SUPPORT: HUSBAND agrees to pay to WIFE child support as set by the
Cumberland County Domestic Relations Office after the parties have separated.
10.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. His bank accounts;
c. Any life insurance policy;
d. His motor vehicle (Chrysler Town and Country van): and
e. All his employee benefits.
WIFE shall receive the following items:
a. The personal property in her possession;
b. Her bank accounts;
c. Any life insurance policy;
d. Any employee benefits;
e. Her motor vehicle (Jeep Liberty);
f. The sum of $20,000.00 in cash and the sum of $20,000.00 from
Beistle Company retirement to be transferred to an IRA of Wife by a
Qualified Domestic Relations Order.
4
WIFE hereby waives all right and title which she may have in any personal property of
the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property
of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any
claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
11.
AUTOMOBILES:
a. WIFE agrees to waive any and all interest which she may have in
HUSBAND'S motor vehicle (Chrysler Town and Country van).
b. HUSBAND agrees to waive any and all interest which he may have in
WIFE'S motor vehicle (Jeep Liberty). WIFE agrees to pay the outstanding loan on the
Jeep Liberty and hold HUSBAND harmless from any obligation for said loan.
12.
MARITAL DEBTS & BANKRUPTCY: Each party will be responsible for their own
debt incurred after the date of separation as well as their individual credit cards. It is hereby
understood and agreed by and between the parties that their obligations pursuant to this
Agreement shall not be affected by any bankruptcy proceeding and shall not be deemed to
5
constitute or be a dischargeable debt of a bankruptcy. Both parties warrant that he/she has not
heretofore instituted any proceeding pursuant to the bankruptcy laws nor are there any such
proceedings pending with respect to him/her, which have been initiated by others.
13.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND
waives all right, title, and claim to any of WIFE'S employee benefits.
14.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in HUSBAND'S business savings account or any other bank
accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he has in the
bank accounts of the WIFE.
15.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
16.
INCOME TAX EXEMPTIONS: The parties agree that HUSBAND will take Katelyn
N. Cornman as his income tax exemptions on his Federal income tax returns filed each year. The
parties also agree that WIFE will take Lindsey M. Cornman as her income tax exemption on her
Federal income tax returns filed each year.
6
If primary custody of the children changes, the income tax exemption for said children
will be assigned to the parent of said children with primary physical custody.
17.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
18.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other parry any and all further
instruments that may be required to give full force and effect to the provisions of this Agreement.
19.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is
not the result of any duress or undue influence. The provisions of this Agreement are fully
understood by both parties and each party acknowledges that the Agreement is fair and equitable,
that it is being entered into voluntarily, and that it is not the result of any duress or undue
influence.
20.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
7
21.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
22.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
23.
PAYMENT OF COSTS: Each party agrees to pay one-half (1/2) the costs of attorney
fees in obtaining equitable distribution of the marital property and a final Decree in Divorce.
24.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
8
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
(SEAL)
L. CORNMAN
SEAL)
H AT HER R. CORNMAN
9
i-TTCICTC-
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this day of avy
2009, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, BRADLEY L. CORNMAN, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
NOW Sew
MWft L. NON, NrAry Public
L * j4MM ?- Carlisle Toro, CunibeMnd County
Sept 18, 2011
MOMWI n of Notaries
COMMONWEALTH OF PENNSYLVANIA
AQ "+-JJLZ, : SS:
COUNTY OF --- -- ?rAFD
PERSONALLY APPEARED BEFORE ME, this a?-3 A-A day of
2009, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, HEATHER R. CORNMAN, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA v? ?l' G11nt??
Debra Spirrw, Notary blic
? Keg, DaupMnpuCmm y
MY CWnIMISSIM E*kw Sept 3, 2011
Member, Pennsylvania Association of Notaries
10
roc THE r ':'GARY
2009 „'l 117 PI'1 31 , 0 5
BRADLEY L. CORNMAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2009 - 348 CIVIL TERM
HEATHER R. CORNMAN,
Defendant. IN DIVORCE
To the Prothonotary:
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 Section 3301(c) and or (d) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Heather R. Cornman, on or about January 30, 2009, through her attorney, P. Richard Wagner, Esq.
and addressed to him at Mancke, Wagner, Spreha & McQuillen, 2233 North Front Street, Harrisburg,
Pennsylvania, 17110. An Acceptance of Service was filed on February 2, 2009.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by plaintiff: May 27, 2009; by defendant: June 9, 2009.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a)
of which is attached:
(b)
June 17, 2009.
June 17, 2009.
Date: June 17, 2009
Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy
Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
Date defendant's Waiver of Notice in Section 3301(pAivorce was filed with the Prothonotary:
A. McKnight, III, Esquire
v for Plaintiff
OF 'ME 2 0 9 9 JUIri 17 PI'll %3: 0;