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Home My WebLink About09-1069Julie E. Brannen IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- l?(d 9 CIVIL TERM Randy W. Brannen Defendant 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, 1 Courthouse Square, Carlisle, Pennsylvania. 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 LEGAI. HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Julie E. Brannen IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- LI CIVIL TERM Randy W. Brannen Defendant IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE Plaintiff is al? who currently resides at Cumberland County, Pennsylvania. 2. Defendant is a0(0)e°nwho currently resides at LDC.)AAAV-C- /2-t• Pmt C C S:\\6 Y\-+D13 14 1 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on (o a `c h G, D-D05 at 5. The marriage is irretrievably broken, and the parties separated on L-S-a nI a(I C\j ?Q_ ?0( 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. r Date Plaintif , Pro Se I ' ICI r E. PXar\lvei lverify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. a_ Dq Date: Pl intiff, Pro Se Assisted by: Michael A. Scherer, Esq. O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 r.,. c Ct`i 27 ?': Julie E. Brannen IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- l6 (A CIVIL TERM Randy W. Brannen Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Julie E. Brannen, Plaintiff, to proceed in forma au eris. I, Michael A. Scherer, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Mic ael . Sc erer, Esquire Attorney for Plaintiff O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 r r -T7 t Julie E. Brannen IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- (d(yq CIVIL TERM Randy W. Brannen Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Randy W. Brannen (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. 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 and . Brannen, Defendant rVI y JULIE E. BRANNEN, Plaintiff V. RANDY W. BRANNEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1069 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above-captioned action as discontinued. Date: May 7, 2009 Respectfully submitted, O'BRIEN, BARIC & SCHERER Mi aeI A. Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas.dir/divorceclinic/brannen/discontinue.pra CERTIFICATE OF SERVICE I hereby certify that on May 7, 2009, I, Jennifer S. Lindsay, secretary at O'Brien, Baric & Scherer, did serve a copy of the Praecipe To Discontinue, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Randy W. Brannen 72 West Louther Street, Apt. C Carlisle, Pennsylvania 17013 FILED-OFFICE OF THE PROTHICI TARP 2009 MA Y- 7 Ali l i= 3 Q . ?Jr?i. 1}. ,,,'I ? f ? LIM?.