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HomeMy WebLinkAbout10-1452 • •a Brandy L. Harrison N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- Jq6?- CIVIL TERM 0 Justin J. Harrison -o rv w Defendant IN DIVORCE 65- NOTICE TO DEFEND AND CLAIM RIGHTS w 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 LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 y ? Brandy L. Harrison IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- 11,5-1 CIVIL TERM Justin J. Harrison Defendant IN DIVORCE COMPLAINT UNDER &3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is N04,4? 00N(('S00 , who currently resides at lju.?e-<S1Cam' -ZKIbQ fLJe Cumberland County, Pennsylvania. 2. Defendant is 7i ? ?1 ?AC.LCC 150n , who currently resides at I () I C?\6,,rtm©nA ) Co.c ? isle PR 1701-5 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. t 4. Plaintiff and Defendant were married on C`Nd?c 31 ? , Q= l at i 5. The marriage is irretrievably broken, and the parties separated on a 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. d-aa - IO N Date Plaintiff, o Se I, Houc'c tSoc- , verify 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. Date: Or- F. Plamtif ro Se Assisted by: Jerry Brown, Esq. 4601 S. Clearview Dr. Camp Hill, PA 17011 (717) 737-9174 0 Brandy L. Harrison Plaintiff V. Justin J. Harrison Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10- )4/5-aL- CIVIL TERM n IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: .L7F aj 4 ?- .gyp r=? ?_? t fi C:i 3 N Kindly allow, Brandy L. Harrison Plaintiff, to proceed in forma 12auperis. I, Jerry Brown, 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 providin re legal services to the party. Jerry ]Blr o n, Esquire Atto for Plaintiff 4601 Clearview Dr. Cam 1 PA 17011 (717 37-9174 ,1() 6; 3 IF S" Brandy L. Harrison, Plaintiff v. Justin J. Harrison, Defendant To The Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1452 CIVIL TERM -~ ~ CIVIL ACTION- LAW z~ ~ rv IN DIVORCE .~.. ~'~~ ~:x - ., c ss i. `~ ~ PRAECIPE TO REINSTATE COMPLAINT ~~ c , ~ ctr Please reinstate the Divorce Complaint at the above-captioned docket. ~~i%c-l Andrew Hall Certified Legal Intern ~~. , ~~ Mega~2iesmeyer, Esq. Supervising Attorney Date: ,~'Bn ~"~, .? X7,0 T-' Brandy L. Harrison, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10-1452 CIVIL TERM Justin J. Harrison, CIVIL ACTION - LAW -0 ? ' Defendant IN DIVORCE ` ' AFFIDAVIT OF SERVICE I, Andrew Hall, hereby certify that I personally served a true and correct copy of the Divorce Complaint, on Justin J. Harrison, at: The Cumberland County Prison, at 9:05 a.m. on Friday, September 03, 2010. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. i Date: Andrew 901 f... Brandy L. Harrison, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10-1452 CIVIL TERM Justin J. Harrison, : CIVIL ACTION - LAW (7) Defendant : IN DIVORCE C= C= ` -1 M-, i c ?' r- -a rn AFFIDAVIT OF CONSENT < ` - 4CZ) > C.3 e? 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed oaa jg 2 , 2010, and reinstated on September 2, 2010. 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. §4904, relating to unsworn falsification to authorities. Date ka 5- o Brandy L. H son, Plaintiff Brandy L. Harrison, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 10-1452 CIVIL TERM Justin J. Harrison, : CIVIL ACTION - LAW -3 Defendant : IN DIVORCE ?M C/) M -a z -n WAIVER OF NOTICE OF INTENTION TO REQUEST =?' - = ENTRY OF A DIVORCE DECREE UNDER J= w D C ) r1l 43301(c) OF THE DIVORCE CODE "< w,- K 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 are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date 1 c? -57-10 Brandy L arrison, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Brandy Harrison, Plaintiff File No. 10-14 IN DIVORCE Justin J. Harrison, Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, Brandy Harrison prior to the entry of a Final Decree in Divorce, hereby elects to resume the prior surname of Mckay, and gives this written notice avowing his/her intention pursuant to the provisions of 54 Pa.C.S. § 704. Date: /"'/Signature Signature name being re ed COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On theme 'day of -ry-) a, 2011, before me, the Prothonotary or the Notary Public, personally appeared the above affiant, known to me to be the person whose name is subscribed to the within document, and acknowledged that he/she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal. LINDA M. STATE OF 'ARY PUBLIC o: A i t ur HANS'YLVAMA MY COMMISSION EXPIRES MM N41 FILED-OFFICE OF THE PROTHONOTAR'? 2011 MAY 26 PM 12, 22 CU PEENRNSYLVAN A r °r ? as9>7G Brandy Harrison, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Justin J. Harrison, Defendant NO. 10 - 1452 CIVIL TERM CERTIFICATE OF SERVICE I, Patrick Boyer, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Plaintiff's (d) Affidavit on Justin J. Harrison, residing at Cumberland County Prison 1101 Claremont Rd. Carlisle, PA 17015, by depositing a copy of the same in the United States mail on September 12, 2011. Patrick Boye Certified Legal Intern c-? c C= C:: -? n 1 = V r n rr -0 - ? -urn ? cry r -- ? O )> r. PV --{ CN " ? rt p C> --a r --9 Brandy Harrison, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVAN IA V. : NO. 10-1452 CIVIL TERM Justin J Harrison : CIVIL ACTION - LAW w; . Defendant : IN DIVORCE ° - f"1 Ur" iTi :' PRAECIPE TO TRANSMIT RECORD r°- °n To the Prothonotary: 1 _ Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Personal service on Defendant at 1101 Claremont Road, Carlisle, PA 17013 on September 3, 2010 3. Complete either paragraph (a) or (b): (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: September 12, 2011; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed and served September 27, 2011. 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to Request Entry of Divorce: October 26, 2011 by first-class mail. Decree, a copy of which is attached: Date -+--?-1--`- Certified Legal Intern Robert E. Rain , squire Lucy Johnston-Walsh, Esquire Martin J. D'Urso, Esquire Thomas M. Place, Esquire Megan Riesmeyer, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Brandy Harrison V. Justin Harrison NO. 10-1452 DIVORCE DECREE AND NOW, ,11?or/G•? ?i?' -j a /? , it is ordered and decreed that Brandy Harrison plaintiff, and Justin Harrison bonds of matrimony. defendant, are divorced from the 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.") None By the Court, Attest: J. 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