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Home My WebLink About09-5843? -h ANITA S. BREWSTER, Plaintiff V. JAMES I. NELSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009- S$y3 CIVIL ACTION - LAW : 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 will proceed without you and a decree in divorce or annulment may 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 or your children. When the ground for the 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 at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 S. Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 w ANITA S. BREWSTER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009- W1/3 CIVIL ACTION - LAW JAMES I. NELSON, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW comes Anita S. Brewster, plaintiff herein, by and through her attorney, Jacqueline M. Verney, Esquire, and represents the following: 1. Plaintiff is Anita S. Brewster, an adult individual, currently residing at 424 S. Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013 since June, 2004. 2. Defendant is James I. Nelson, an adult individual, currently residing at 1530 Spring Gate Drive, #9112, McLean, Virginia since April, 2009. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on June 12, 1998, in Schwetzingen, Germany. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. This marriage is irretrievably broken. Ab* WHEREFORE, Plaintiff prays Your Honorable Court enter a decree in divorce. Respectfully submitted, ac line M. Verney, Esquire Supreme Ct. ID. 23167 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing divorce complaint 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. 204/ Date Anita S. Brewster, Plaintiff RLEQ-t>`l:FiCE 0F THE P R0 T'. €CN'OfARY 2009 AUG 25 Phi 12= 28 $338.50 Po ATT-t C*-,* c.14 A at o2ag7,3(,v ANITA S. BREWSTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-5843 CIVIL ACTION - LAW JAMES I. NELSON, Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce in the above captioned matter pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). I certify that I am authorized to accept service on behalf of the defendant. v -,? Date: a512-c161 efendaant or Authorized Agent PA c- i? , VA Z;Z I ID Z Mailing Address FiLEG-i_?=F E OF THE (-,,NOTARY 2009 AUG 26 AM 10: 53 ANITA BREWSTER, Plaintiff vs. JAMES NELSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2009-5843 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 25, 2009. Defendant accepted service of the complaint on August 25, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the 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. section 4904, relating to unsworn falsification to authorities. Date: ZS ~f~Nft• Zol v ~L2a~k~ Anita Brewster, Plaintiff ~Cr ~ l~'~`(1~~ S~I~ ~ c+ ;~.~d~I~~ Ot~b'~~~BWl3~ ~` 1 ~~ ~~ 9Z 13~ OIQz .',~~.~.O~a~H~,c~~~ :~w~ .~~ ~a.~.~0-O~~I-~ ANITA BREWSTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. N0.2009-5843 CIVIL ACTION -LAW JAMES NELSON, Defendant 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 1.~ f.,,~ ~,.~ '7 ~{ and that a co of the decree will be sent to me immediatel after it is w ~ th py y , ~~ a~ ~ ey ~ -t prothonotary. ~ ~ - ~ ~"' ~~ °n ~~' ' ~~ a~ a ~~ ~~~ ~ ~?~ ~ {~= ~9 ~--~ _.., y~ ~: t yea I verify that the statements made in this affidavit are true and correct. I understaii~i that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Date: Z5 ~!~~~ Zv t~ ~~. ~1~~ Anita Brewster, Plaintiff ANITA BREWSTER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JAMES NELSON, NO. 2009-5843 CIVIL ACTION DIVORCE DECREE AND NOW, %',e7jam- ='016 _,it is ordered and decreed that ANITA BREWSTER, plaintiff, and JAMES NELSON, defendant, are divorced from the bonds of matrimony Any existing spousal support order shall hereafter be deemed an order for alimony pendente.lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order, has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") The parties' Marital Property and Settlement Agreement dated November 1, 2010 is incorporated herein and the court has jurisdiction over no other claims. By the Court, Attest: J. Y rothonotary Nolte Iva, ANITA S. BREWSTER, IN THE COURT OF COMMON PL Plaintiff CUMBERLAND COUNTY, PENNSYLYAN6k 7 V. CIVIL ACTION - LAW NO. 2009-5843 == JAMES I. NELSON, Defendant IN DIVORCE - DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 25, 2009. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification Jo authorities. Date: [ l /,51t 1201 G DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's SAIDIS SULLIVAN LAW 26 West High Street Carlisle, PA fees or expenses if I do not claim them before a divorce is granted. 3. 1 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification 6uthorities. Date: l i ?(?l ?2n1 c7 , mes Nelson