The URL can be used to link to this page

Home My WebLink About04-2144 Michael J. Wilson 816 Derby Avenue Camp Hill PA 17011-8367 PAID No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE 314 E. MEADOW DRIVE MECHANICSBURG P A 17055 Plaintiff CIVIL ACTION--LA W : v. NO. ()L/ ~ ";l.ltJ4 ei~d.. T'i1'l.1v] KIM M. DAWSON BROLLE 102 FAIRFIELD STREET NEWVILLE PA 17241 Defendant 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 coumelors is available in tbe Office of the Prothonotary, Cumberland County Courthouse, 1 Conrthouse Square, Carlisle, PA 17013. (717) 24G-(j19S. IF YOU 00 NOT FILE A CLAIM FOR ALIMONY, DMSION 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: Court Administrator 4th FL, Cumberland County Courthouse Carlisle,PA 17013 (717) 24G-(j200 Michael J. Wilson 816 Derby Avenue Camp Hill PA 17011-8367 PAID No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE 314 E. MEADOW DRIVE MECHANICSBURG P A 17055 Plaintiff : CIVIL ACTION--LA W v. : NO. C>4 - ~1"C/ (?Ux:(y~ KIM M. DAWSON BROLLE 102 FAIRFIELD STREET NEWVILLE PA 17241 Defendant . . COMPLAINT IN DIVORCE COUNT I - DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE Plaintiff, by his attorney, Michael J. Wilson, respectfully represents: I. The Plaintiff is Bruce W. Brolle, who currently resides at the above-captioned address in the County of Cumberland, Commonwealth of Pennsylvania. 2. The Defendant is Kim M. Dawson Brolle, who owns a current residence at the above-captioned address in Newville, County of Cumberland, Commonwealth of Pennsylvania. 3. Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. -1- 4. The parties were married on October 4, 2003 in Cumberland County, Pennsylvania. 5. The parties have no children from the marriage. 6. There have been no prior action of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 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 to participate in counseling. WHEREFORE, Plaintiff requests the Honorable Court to enter a decree in divorce, divorcing Plaintiff and Defendant. Respectfully submitted, ddfPd- Michael J. Wilson Attorney for Plaintiff -2- VERIFICATION I, Bruce W. Brulle, hereby affirm, under the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the statements made in the foregoing Complaint in Divorce are true upon my personal knowledge or information and belief. (3/UUA~u) ~ Bruce W. Brolle (J ole;) ~ - ~ ...Q 0 "- . V') V) -- () ...... '1 0 ..... ~ -V 0- p: J Q :;:~ ~ i.-.:.. ,.-1 -, --r- 1';, ..., - (....,;' ,"1 -r::.~ c> ,1.:_0 8 , Michael J. Wilson 816 Derby Avenue Camp Hill P A 17011-8367 PA lD No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE 314 E. MEADOW DRIVE MECHANICSBURG PA 17055 Plaintiff CIVIL ACTION--LA W NO. 04-2144 v. KIM M. DAWSON BROLLE 1550 WILLIAMS GROVE ROAD LOT 70 MECHANICSBURG PA 17055 Defendant DIVORCE pRAECIPE FOR CORRECTION OF ADDRESS TO THE PROTHONOTARY: Kindly amend/correct the docket ofthe captioned action to change the address of Defendant to that set forth above. Respectfully submitted, A~~~ Michael J. Wilson Attorney for Plaintiff -1- Michael J. Wilson 816 Derby Avenue Camp Hill PA 17011-8367 PA ID No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W NO. 04-2144 v. KIM M. DAWSON BROLLE Defendant DIVORCE CERTIFICATE/PROOF OF SERVICE I, Michael J. Wilson, Attorney at law, hereby certify that a true and correct Copy/copies ofthe following document(s)/paper(s): l. 2, Praecipe for Correction of Address; and, Certification/Proof of Service dated October 26, 2004. was/were served on the date specified below to the following individual(s) by United States Mail, postage prepaid: Kim M. Dawson Brolle 1550 Williams Grove Road - Lot 70 Mechanicsburg P A 17055 Defendant Wife Dated: October 26, 2004 Respectfully submitted, ;h4J~ Michael J. Wilson Attorney for Plaintiff -1- o ....., c:-::> c::;:::> "'- C> c' ~ "') -oJ ~ "::1 ::t~ "T1 !11~ -,,In ,~y,9 "C<'::, ,J~'h j:D ,.('":i :_jfT1 .:::-i ,. :;"] -< -:'~l -,',. -.,;. i~? c:) 81'\L1tG W. 'BRoL-LC In the Court of Common Pleas of Cumberland County, Pennsylvania V$, !<If'Il ~AvJ~o) 13f:-oLLC No. o V -'Z (<lY Civil. 19 l<t ,IN-'1 f(s,.JSTY\T"'C: 11ft: GM OL/h..J, /.:, Di VO,ccc ~ rc::.:A KU.<h"'-1 -:'> ~) Prothonotary k,,;'S-- ~ 1f1. f To Attorney for Plaintiff f>0 '(~~ J. W. Ls 6,0 F1LEf}-fJ~T:C;F OF THE PFCT-:O~rIT/<FY No, Term. 19 _ LuGofEij..J PH 12: 2i:) Cj~:- vs. PRAECIPE Filed 19_ . Atty. SHERIFF'S RETURN - REGULAR CASE NO: 2004-02144 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BROLLE BRUCE W VS BROLLE KIM M DAWSON VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn accordin to law, says, the within COMPLAINT - DIVORCE was served upon BROLLE KIM M DAWSON t e DEFENDANT at 2055:00 HOURS, on the 15th day of Februar 2005 at 1550 WILLIAMS GROVE ROAD MECHANICSBURG, PA 17055 KIM M DAWSON BROLLE LOT 70 by handing to a true and attested copy of COMPLAINT - DIVORCE together ith and at the same time directing Her attention to the contents the eof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.66 .00 10.00 .00 34.66 So Answers: ~./. ~ "<;"'.'" .r ,. .,.~,. ,/:::~ ~.~~ R. Thomas Kline 02/16/2005 MICHAEL WILSON me this ;2 day of Sworn and Subscribed to before By: 7(r A/.-i,. A . D. ;r Q.o., ~ F~y'-0/(5 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under 3301(c) ofthe Divorce Code was filed on May 13, 2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry ofthe decree. 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: .7'-:;J/1-c2Cl?5 4/Uta U/ A~ BRUCE W. BROLLE Plaintiff n r-> 0 = ~:; = -n c.n -0 (\ .~ <- ~::n rY" (, , c::: "'.-: ",) ~r 6- ._.r -o~ thY :I'J (.,) -:J I~; c :;:l~?, ~ _:_'1'1 ~:. i.:'. ::1: '~o - bC<l P" c:: - -.-1 2': -~ ---i C) ~ -< Cl - IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I, 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! 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 statement made in this waiver are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities, Date: .:)-.2 t/ -;z (}{J5'" 0~ tab~ BRUCE W. BROLLE Plaintiff 0 "" 0 = ~; = -n """' <- 3'! c: nl:D Z r- -om W :lJ5? (~O ....'1 ~ s-n :::r.: '~:7'(-) C. ::.--m ~: .~ -I =<! 0 ?o 0 -< IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYL VANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE NOTICE: If you wish to deny any of the statements set forth in this affidavit. you must rIle a counter- affidavit within 20 days after a copy of this affidavit has been served on you or the statement wiD be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on.MAY 13,2004 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 are made subject to the penalties of Title 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. ---- Date: :J a 11 e..3 t-oO ~ ) .0~/~ tV ,6~ BRUCE W. BROLLE ,....., <=> = c,-. c...- c: z o ." ~ rn.:.1J ," ~f5 f:9 ~~.~~ cSf11 ::r;! 55 -< I -.J v :.11: ~ o Michael J. Wilson (717) 774-7018 816 Derby Avenue (717) 774-7019 (facsimile) Camp Hill PA 17011-8367 Attorney for Plaintiff PAID No.: 52680 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE CERT~CATEWROOFOFSERVICE I, Michael J. Wilson, Attorney at law, hereby certifY that a true and correct copy/copies of the following document(s)/paper(s): 1. Affidavit under Divorce Code Section. 3301(d) of Plaintiff, Bruce W. Brolle; 2. Notice of Intention to Request Entry of Section 3301(d) Divorce Decree; 3. Counter-Affidavit Under Section 3301(d) of the Divorce Code (in blank form attached to Notice); and, 4. Certification/ProofofService dated June 7, 2006. was/were served on the date specified below to the following individual(s) by United States Mail, postage prepaid: Kim M. Dawson Brolle 1550 Williams Grove Road - Lot 70 Mechanicsburg P A 17055 Defendant Wife Dated: June 7, 2006 Respectfully submitted, ;kIJv- Michael J. Wilson Attorney for Plaintiff -1- o ~~ r-..:s = ..-= <:::l" '- (= :;J;:: o "11 "-I Iii rn,! :n ;1J ;.:;~2;; 2;~2~i c5 r1i ,:"'"1 :0 -< I -..I 3? N o N ........ -... IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION-LAW v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: ~3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: February 15, 2005 (by Cumberland County Sheriff (Return filed)) 3. Date of execution of the Plaintiff's Affidavit required by ~ 3301(d) of the Divorce Code: June 3, 2006 Date of filing and service of Plaintiff's Affidavit upon Defendant: June 7, 2006 4. Related claims pending: No economic claims. Parties have executed a Pre-Nuptial Agreement. 5. Date and manner of service of the Notice of Intention to Request Entry of Section 3301(d) Divorce Decree with attached blank form of Counter-Affidavit (copies attached): June 7, 2006 ~~~ Attorney Ichael J. Wilson PA ID No. 52680 Attorney for Plaintiff Bruce W. Brone 717.774.7018 (") r- ~~~ C:._) C~.... ::;J j',j C) C:' (,I) 0'1 ./ . IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF SECTION 330Hd) DIVORCE DECREE You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after June 30, 2006, the other party can request to enter a fmal decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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: Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 ~ C) r--..-' C'::> CJ " (';':" n :::1 1'-"[-1 (.,) (=1 --n ~ !.,,) Ii i -- =2 - C'"~ / . IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION--LA W v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): _ (a) I do not oppose the entry of a divorce decree. _ (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): _ (i) The parties to this action have not live separate and apart for a period of at least two years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _ (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. _ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party's attorney of record or upon the other party if he/she has no attorney. IfI fail to do so before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable to thereafter file any economic claims. 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: KIM M. DAWSON BROLLE NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF. YOU SHOULD NOT FILE TIDS COUNTER-AFFIDAVIT. (") c~ ~, if~ ,::0-..... t-'- ';;1'4 ::::! /Ci?:! , ,< (,) c::, w f"..':l Michael J. Wilson 816 Derby Avenue Camp Hill P A 17011-8367 PA ID No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) Attorney for Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA BRUCE W. BROLLE Plaintiff CIVIL ACTION-LAW v. NO. 04-2144 KIM M. DAWSON BROLLE Defendant DIVORCE CERTIFICATE~ROOFOFSERVICE I, Michael J. Wilson, Attorney at law, hereby certify that a true and correct copy/copies of the following docwnent(s)/paper(s): 1. Praecipe to Transmit Record (with attached copies of Notice ofIntention to Request Entry of Section 3301(d) Divorce Decree and Counter-Affidavit Under Section 3301(d) of the Divorce Code; and, 2. Certification/Proof of Service dated June 30, 2006. was/were served on the date specified below to the following individual(s) by United States Mail, postage prepaid: Kim M. Dawson Brolle 1550 Williams Grove Road - Lot 70 Mechanicsburg P A 17055 Defendant Wife, pro se Dated: June 30, 2006 Respectfully submitted, ~ Michael J. Wilson Attorney for Plaintiff -1- I'-J C::> ., .~'j CO) ,-J :::-1 ,---, c..__ < 1', C,,) c..> -:") r-,) ~ ~~~ ~ ~~ ~~~ ~~ ~~~~~~~ IN THE COURT OF COMMON PLEAS STATE OF OF CUMBERLAND COUNTY PENNA. J. BRUCE W. BROLLE Plaintiff VERSUS KIM M. DA WSON-BROLLE No. 04-2144 CIVIL 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; Defendant AND NOW, DECREE IN DIVORCE 1~ J"r , Z4o(" , IT IS ORDERED AND DECREED THAT BRUCE W. BROLLE , PLAI NTI FF, AND KIM M. DA WSON-BROLLE , DEFENDANT, ~ ARE DIVORCED FROM THE BONDS OF MATRIMONY. None By THE OURT: ~~- *'- ~~, 9I / PROTHONOTARY ~ ~ ~ -m2. ~~ ~t..'L. ~(1 ~ ~ ~~'ry 'All..[ ..>