HomeMy WebLinkAbout09-1678LTNDSEY BROWNAWELL, : IN THE COURT OF COMMU~1 PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :Civil Action-Law
:No. ~~, /L7~ ~N~I
NATHAN A. BROWNAWELL,
Defendant
IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following per, you must take prompt action. You are warned that if yorl fail to do so, the case
may proceed without you anal a decree of divorce or annulment maybe entped against you by the
court. A judgnent may aLgo be entered against you fnr any other clairnl or relief requested in
these papers by the Plaintiff. You may aiso lose money or property or other rights ixrcportant to
you, including custody or visitatiar of your children.
When the ground for the divorce is indignities or irretrievable brewdown of the marriage,
you. may request mazriage counseling. A list of marriage counselors is avlailable in the Office of
the Prothonotary at the Cumberland County Court House, High and Haaovier Streets, Carlisle.
IF YOU SO NOT FILE A CLAIM FOR ALIMONY, DTUIS~ON 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 A'~ ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO 4R TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17413
Phone: (717) 249-3166
(800} 9~-9108
AMERICANS WITH DISABILTT~ES ACT OF 990
Tire Court of Common Pleas of CWmberland County is roquiced by law comply with the
Americans with Disabilities Act of 1990. For iefonmation abort aoxasdrle ~ and amble
accommodatiaus available to disabled individuals havieg business belie the vo~rt, please cou~ct our
of~oe. Alt a~ must be made at least 72 hours prior to any hearing or lbusiaes$ before the oaurt.
You must attend the scheduled conference or hearing.
LINDSEY BROWNAWELL, : IN THE COURT OF COMMON PLEAS OF
Plaintiff. :CUMBERLAND COUNTY, PENNSYLVANIA
v :Civil Action- Law
:NO' 09- { ~ 7~ cave
NATHAN A. BROWNAWELL, .
Defendant
IN DIVORCE
COL ~ ~ ~~ f 1~1 ^a .fit.. l iw..1 • v ~ .r.
OF TDE DIVORCE CODE
AND NOW, comes the Plaintiff, Lindsey Brownawell, by ar~d through her
counsel, Michael J. Where, Esquire and avers as follows:
1. Plaintiff is Lindsay Brownawell, an adult individual, whop currently resides at
1501 Lowmaland Drive, Apartmeirt S5, El Paso, Texas ?9935
2. Defendant is Nathan A Brownawell, an adult individual,'who currently resides
at 233 Wildwood Lane, Nevwille, Cumberland County, Pennsylvaniia 17241.
3. Defendarn has been a bona fide resident in the Commonvlvealth for at least six
momhs immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December' 16, X004, in Carlisle,
Cumberland Courny, Pennsylvania and separated on September 15~ 2008.
5. There have been no prior actions of divorce or annulment between the parties
hereto in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available, and that Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
8. Plairniff requests the Court to erner a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to erner a
Decree in Divorce and such other Orders as may be just and appropriate.
Respectfully submitted,
~~~~., 09 ~ Gam, ~
Date: Esquire
'chael J. ,
37 East Pomfret Street
Carlisle, PA 17413
Supreme Ct. Id No. 890~Z8
Attorney for Plairnff
LINDSEY BROWNA~~-~ ~ IN T~ COURT OF .COMMON PLEAS OF
Plaintiff : CUMBERI-AND COUNTY, PENNSYLVANIA
~ :Civil Action- Law
NATHAN A. BROWNAWELL,
Defendant
IN DIVORCE
ATTORNEY RIFICATIt?N
I, Michael J. Where, Esq., verify that the statements made in this Petition are true
and correct. I understand that false statements herein are made subject to the penalties of
~ R pa ('. S. & 4904 relating to unsworn falsification to authorities.
Date:.~~~~~~_ ~~
Michael 7. e, Egq~
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