HomeMy WebLinkAbout10-2951
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower
Plaintiff Pro Se, = r-1
vs. NO. lQ ' ?y S? C .
Stacie Robin Brower
Defendant Pro Se.
NOTICE TO DEFEND AND CLAIM RIGHTS
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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 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 Cumberland County Courthouse, S. Hanover St., Carlisle, PA
17013.
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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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYERS REFERRAL SERVICE
Telephone:
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to
Notice to Defend and Claim Rights
Page 1 of 2
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower :
4182 Antelope Ct. Apt# 111
Mechanicsburg, PA 17050
Plaintiff Pro Se,
vs.
Stacie Robin Brower
511 Penn Ayr Rd. :
Camp Hill, PA 17011 ;
Defendant Pro Se.
NO. I o?.y S( c l
COMPLAINT IN DIVORCE UNDER §3301(c)
OF THE DOMESTIC RELATIONS CODE
Count I-Divorce
Plaintiff, Michael Ray Brower, pro se, respectfully represents:
1. Plaintiff, Michael Ray Brower, currently resides at 4182 Antelope Ct. Apt# 111,
Mechanicsburg, PA 17050.
2. Defendant, Stacie Robin Brower, currently resides at 511 Penn Ayr Rd., Camp Hill, PA
17011.
3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have has/have been
resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months
immediately preceding the filing of this Complaint.
4. The parties were married on 09/14/1991, in Ft. Meade, MD.
5. The parties were separated on 07/04/2009.
6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its
allies within the provisions of the Service Members' Civil Relief Act of 2003.
7. The following children were born to the parties:
Name Age Sex
Alexis Rae Brower 16
Madison Dodie Brower
Complaint in Divorce
Date of Birth Residence
female 09/12/1993 Mother
11 female 10/09/1998 Mother
Page 1 of 2
8. There have been no prior actions of divorce or for annulment between the parties.
9. The parties have entered into a written agreement as to equitable distribution of marital
property, alimony, alimony pendent lite, spousal support, child support, custody, visitation,
fees and costs.
10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff
acknowledges the right to request that the court require the parties to participate in such
counseling in certain instances.
11. Plaintiff waives the right to request that the court require the parties to participate in
counseling.
12. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is
irretrievably broken and Plaintiff believes Defendant will consent to the divorce. If a divorce
based on consent cannot be granted, Plaintiff further alleges in the alternative that the
marriage is irretrievably broken and the parties will have been separated for two years or
more at the time of final disposition of this case.
WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to
Section 3301(c) of the Divorce Code.
A'Al t
Michael Ray Brower, Plaintiff Pro Se
VERIFICATION
Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct.
Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904, relating to unsworn falsification to authorities.
Michael Ray Brower, aintiff Pro Se
Date: 3 /7a v ;1,0 /0
Complaint in Divorce Page 2 of 2
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower
Plaintiff Pro Se,
Stacie Robin Brower
Defendant Pro Se.
ACCEPTANCE OF SERVICE
I, Stacie Robin Brower, defendant in this divorce action, hereby certify that I personally received
a copy of the Complaint in Divorce with a Notice to Defendant and Claim Rights on or about
Stacie Robin Brower, Defendant
Date: r~ ~ , y _ .~ O / O
^ Complete items 1, 2, and 3. Also complete
item 4 if Restricted DelNery is desired.
^ Print your name and address on the reverse
so that we can return the card to you.
^ Attach this card to the back of the mailpiece,
or on the front ff space permits.
1. Article Addressed to:
.StACi¢ ~/'pWQr
,S'/l pe ~ h ,4y~ Ram ~/
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A. Signature ~ o ,,-~,
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ressee ' ' ' ~' ~"
B. Received by (Prir-ted Name) C. Date Delivery Y~ '~
Star ~ e R £~~a w r ~ t..-
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D. Is delivery address different from kern 17 Yes ~
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If YES, enter delivery address below: ^ No
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3. Service Type
^ Certified Mall ^ Express Mall
^ Registered ^ Return Receipt for Merchandise
^ Insured Mall ^ C.O.D.
4. Restricted Delivery? (Exbs Fee) ^ Yes
2 a 7~1~ ~29~ 0001 7801 7166
(Transfer from serv/ce label)
PS Form 3811, February 2004 Domestic Return Receipt 1-tit-feseo
Exhibit A: Acceptance of Service
Page 1 of 1
~~ .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower
Plaintiff Pro Se,
vs. NO. / 0 z 9S/ ~ ,'~.~ ~
Stacie Robin Brower n o ,,,
Defendant Pro Se. ~~ ° =~ -
-~ a ~, ,-,
1 _ S_~ ~
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MARITAL PROPERTY SETTLEMENT AGREEMENT ~ --- _
,., $--
THIS AGREEMENT, made this ~ µ `~ day of ~~~~'~' , 2(~~~W
between PLAINTIFF, Michael Ray Brower, residing at 4182 Antelope Ct. Apt# 111, ~ ~_~ ~I°D =~'
Mechanicsburg, PA 17050, and Defendant, Stacie Robin Brower, residing at 511 Penn Ayr Rd.,
Camp Hill, PA 17011.
WITNESSETH
WHEREAS, the parties were married on 09/14/1991;
WHEREAS, the parties filed for 3301(c) Divorce on 3 /`lay ~ U /U ;
WHEREAS, the parties hereto desire to settle their property rights;
WHEREAS, both parties agree to relinquish any and all claims which either may have
against any property now owned or belonging to the other or which may hereinafter be acquired
by either of them by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the
obligations, covenants, and agreements contained herein; and,
WHEREAS, both parties each have had an opportunity to seek the benefit of competent and
independent legal advice by separate counsel.
NOW, THEREFORE, the parties, intending to be legally bound, do covenant, and agree as
follows:
1. INCORPORATION OF RECITALS
The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full.
Each paragraph hereof shall be deemed to be a separate and independent covenant and
agreement.
Marital Property Settlement Agreement
Page 1 of 6
f•
2. APPLICABLE LAW
This agreement shall be construed under the laws of the Commonwealth of Pennsylvania.
3. PROPERTY TO BE RETAINED BY WIFE.
Husband and Wife agree that, unless otherwise indicated in this Agreement, the Wife
shall keep all of her personal clothing and effects; and that the following property shall
also be retained by Wife:
4. PROPERTY TO BE RETAINED BY HUSBAND.
Husband and Wife agree that; unless otherwise indicated in this Agreement, the Husband
shall keep all of his personal clothing and effects; and that the following property shall
also be retained by Husband:
RETIREMENT PLANS:
-Military retirement
5. DEBTS TO BE PAID BY WIFE.
Husband and Wife agree that the Wife shall pay the following debts and will not at any
time hold the Husband responsible for them:
-credit card Capitol One $6,395
-credit card Capitol One $6,388
-credit card Chase $4,065
6. DEBTS TO BE PAID BY HUSBAND.
Husband and Wife agree that the Husband shall pay the following debts and will not at
any time hold the Wife responsible for them:
-consolidation loan Bank Of America $21,417
7. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND
ALL MARITAL RIGHTS.
Each of the parties hereto release the other from subsequent claims for alimony, alimony ,
pendente lite, or spousal support, except as set forth as follows:
Marital Property Settlement Agreement
Page 2 of 6
1~
The Plaintiff shall pay spousal maintenance to the other parry in the amount of $300 per
month, beginning on 5/1/2010 to terminate after 800 months or on the death or
remarriage of the payee, whichever occurs first.
8. JOINT DEBTS.
Husband and Wife warrant and certify to each other that there are no individual or joint
marital obligations outstanding, other than those listed in paragraphs 5 and 6.
9. CHILD CUSTODY.
The Plaintiff and Defendant are the parents of 2 unemancipated child(ren):
Name DOB Awe Gender
Alexis Rae Brower 09/12/1993 16 female
Madison Dodie Brower 10/09/1998 11 female
In the past five years, the parties' children have resided at the following locations:
Child Location
Alexis Rae Brower Living with Mother
511 Penn Ayr Rd.
Camp Hill, PA 17011
Madison Dodie Brower Living with Mother
511 Penn Ayr Rd.
Camp Hill, PA 17011
Custody of the above-listed children will be as follows:
Name Legal Custody Physical Custody
Alexis Rae Brower joint Mother
Madison Dodie Brower joint Mother
a. Weekly Parenting Time
The non-primary physical custodian shall have at a minimum the following rights of
parenting time/visitation with the minor child(ren):
Weekend Parenting Time
Other: As requested or planned for.
For purposes of this parenting plan, weekend parenting time will start at and end at .
Weekday Parenting Time
Other: As requested or planned for.
Marital Property Settlement Agreement
Page 3 of 6
~~
For purposes of this parenting plan, weekday pazenting time will start at and end at .
b. Vacation Pazenting Time
All vacation periods defined below do not include the pazenting time schedule for major
holidays, which may occur during the vacation period.
Winter vacation shall be defined as the period beginning on the day and at the time
school is recessed in December and ending on the day and at the time school resumes in
January of the following yeaz. No special winter vacation pazenting time. schedule will
apply and pazenting time will remain as stated in 9a and 9c except as follows: none
Summer vacation shall be defined as the period beginning on the day and at the time
school is recessed at the end of the school yeaz and ending on the day and at the time
school resumes at the beginning of the following school year. No special summer
vacation pazenting time schedule will apply and all pazenting time will remain as stated in
9a and 9c, except as follows: none
Spring vacation shall be defined as period beginning on the day and at the time school is .
recessed in the month of April and ending on the day and at the time school resumes as
designated by the child's school calendaz. No special spring vacation pazenting time
schedule will apply and all pazenting time will remain as stated in 9a and 9c, except as
follows: none
c. Major Holiday Schedule
MOTHER FATHER
New Year's Day Even Odd
Martin Luther King Day Even Odd
Presidents' Day Even Odd
Memorial Day Even Odd
July 4th Even Odd
Labor Day Even Odd
Veterans' Day Even Odd
Thanksgiving Day and Friday Even Odd
Christmas Eve Even Odd
Christmas Day Even Odd
Mother's Day Even Odd
Father's Day Even Odd
Mother's Birthday Even Odd
Father's Birthday Even Odd
Alexis's Birthday Even Odd
Madison's Birthday Even Odd
Marital Property Settlement Agreement
Page 4 of 6
Each designated holiday above will start and end as follows:
()Holidays that fall on Friday will include the following Saturday and Sunday
()Holidays that fall on Monday will include the preceding Saturday and Sunday
(~ Other: For purposes of this parenting plan, a holiday shall begin and end as
follows:
begin: lam
end: 7pm
10. CHILD SUPPORT, INSURANCE, AND TAX EXEMPTION.
a. Child Support
Plaintiff shall pay support in the amount of $1,500 per month for the support and
care of the parties' minor child(ren). This amount deviates from the Pennsylvania
Child Support Guideline calculation of $1,150.20 per month because that amount
is unjust or inappropriate for the following reason(s): This is the amount I have
agreed to pay in order to help maintain the childrens well being.
b. Insurance
Health care coverage for the minor child(ren) shall be provided by Plaintiff as
long as such coverage is available at a reasonable cost on anemployment-related
or other group basis. Any. health costs not covered by insurance shall be shared
equally.
c. Tax Exemption
For federal, state, and local income tax purposes the. father shall claim the
child(ren) annually beginning the tax year that the divorce is finalized.
11. DIVORCE.
Husband and Wife agree that the marriage is irretrievably broken and will proceed with
said Divorce under 23 Pa. C.A. Section 3301(c).
12. NAME CHANGE.
Does not apply.
13. TAX ADVICE.
The transfers set forth herein may result in income, inheritance, estate, and other tax
consequences to the parties. The parties specifically acknowledge that no attorney
involved in the negotiating or drafting of this Agreement has provided any tax advice
regarding the dispositions contained herein. The parties have been advised to seek
separate tax counsel concerning the Divorce distributions.
Marital Property Settlement Agreement Page 5 of 6
e>
14. INCORPORATION OF PROPERTY SETTLEMENT INTO DECREE.
Husband and Wife agree to the incorporation of the Property Settlement Agreement into
the Decree.
IN WITNESS HEREOF, the parties have hereunto set their hands and seals the day and yeaz first
written above.
Michael Ray Brower, PLAINTIFF
On this ~"°~ day of ~fv~ us ~`' 20 10 'before me, a Notazy Public, the
undersigned officer, personally appeazed Michael Ray Brower, Plaintiff, known to me to be the
person whose name is subscribed to the written instrument, and acknowledged that he or she
executed the same for the purposes therein contained.
IN WITNESS
set my hand and official seal.
COMMONyyEAI,TH OF PENNSYLVANIA
Naalial Seal
Stacy M. Omer, ~Y PubYc
lower Allen Twp., Curnbedand County
~ ~rwrtbiNor- Expires Dec. 28, 2012
Member. Pennsylvania Assocladon of Notaries
~.a~~.n ~~ ~.~ ~~,~~ .
Stacie Robin Brower, DEFENDANT
On this ~ n °~ day of ~Qu S v s ~` 20 / U ,before me, a Notary Public, the
undersigned officer, personally appeared Stacie Robin Brower, Defendant, known to me to be
the person whose name is subscribed to the written instrument, and acknowledged that he or she
executed the same for the purposes therein contained.
IN WITNESS WHE hereunto set my hand and official seal.
NOTARY P LI
Marital Property Settlement Agreement
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Stacy M. Omer Notary Publb
lower Allen Twp., Cumberland County
MY n Expires Dec. 28.2012
Member. Pennaylvarda Assoclatbn of Notaries
Page 6 of 6
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower
Plaintiff Pro Se,
vs. NO. !G - a 9s l c . v.' ~
Stacie Robin Brower
Defendant Pro Se.
PLAINTIFF'S ACKNOWLEDGMENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
_,~/L'fa.~./ zo ~D I agree that the marriage of the Plaintiff and Defendant is irretrievably
broken and mnety (90) days have elapsed from the date of filing the Complaint. All information
contained within the attached documentation is true and correct to the best of my knowledge,
information, and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached
Marital Property. Settlement Agreement and to be bound fully and completely by the terms and
conditions as set forth within said Marital Property Settlement Agreement documentation.
o~'x.~~~.~1 r`f'
Michael Ray Brower, Plaintiff Pro Se
On this 2 n °~ day of ~~S vs 7r` 20 JD , before. me, a Notary Public, the
undersigned officer, personally appeazed Michael Ray Brower, Plaintiff, known to me to be the
person whose name is subscribed to the written instrument, and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHERE I hereunto set my hand and official seal.
ARY
COMMONyy~TH OF PEN
~owrra~Y M ~ ~~ ~YLVANIA
AIMr- Twp„ ~Derlend
Member, e~ ~A~ $ Dec. 28~ p~
soctatbn of Notenes
Plaintiff s Acknowledgment Page 1 of 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower
Plaintiff Pro Se,
vs. NO. l U - ~ 9.5' / c ~'~.~ ~
Stacie Robin Brower
Defendant Pro Se.
DEFENDANT'S ACKNOWLEDGMENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
~/~ d o / 0 I agree that the marriage of the Plaintiff and Defendant is irretrievably
broken and nmety (90) days have elapsed from the date of filing the Complaint. All information
contained within the attached documentation is true and correct to the best of my knowledge,
information, and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached
Marital Property Settlement Agreement and to be bound fully and completely by the terms and
conditions as set forth within said Marital Property Settlement Agreement documentation.
Stacie Robin Brower, Defendant Pro Se
On this a. "°~ day of ,~~ ~ ~ 20 i U ,before me, a Notary Public, the
undersigned officer, personally ed Stacie Robin Brower, Defendant, known to me to be
the person whose name is subscribed to the written instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF~Jhereunto set my hand and official seal.
'ARY
COMMONWEALTH OF' PENNSYLVANIA
Notarial .Spl
~r,~,Cy M. Omrr, N~ootlaar-yy PtR~o
Loww, a~~~,n T xp., CumbaMand C.OIM'1ty
M Conf~n+aN;zsn Explros Oeo. 2d, 2t~12
atMiylvarifa AYSOalrtidr
Defendant's Acknowledgment Page 1 of 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower
Plaintiff Pro Se,
vs. No. to - a 9s l c; ~.~~
~:, ~;
Stacie Robin Brower ~__ ~ ~=;
Defendant Pro Se. -~rv e::r ,. ~~
~~ -n
_ - r ~.~
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PRAECIPE TO TRANSMIT RECORD
-i-j' w f.p.T
T.~
To the Prothonotary: -- - o ~ _
Transmit the Record, together with the following information, to the Court for entry of a
divorce decree:
1. Crround for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: on or about _~/~`la~/ a.G~U
via Certified Mail.
3. Date of execution of the Affidavit of Consent:
by Plaintiff (_ 2~/~/ z o i p ); by Defendant ~/~,/ ZG I b ).
4. Related claims pending: None.
5. Date of filing of Waiver of Notice of Intention to Request Entry of Divorce Decree Under
Section 3301(c) of the Divorce Code:
by Plaintiff ( .Z /,~/ ~ o /~ ; by Defendant ( ~- /.q~_/ ~ ~ / y ).
Michael Ray Brower, Plaintiff Pro Se
4182 Antelope Ct. Apt# 111
Mechanicsburg, PA 17050
717-480-9301
Praecipe to Transmit Record Page 1 of 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower :
Plaintiff Pro Se,
• r,_. ~ c ~
Stacie Robin Brower : ~ ~~ ~~ ~_ _ ; i=, ~ ;
Ca 1 ~._
Defendant Pro Se. v
- ~~_
AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) - ~ t:
OF THE DIVORCE CODE ==~ ~ ~- =~=
1. A complaint in Divorce under Section 3301(c} of the Divorce Code was filed on
"~ ~G y ~.0 ~d and served on ~/~la,y,Z G /G
2. The marriage of the 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 are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: 2. Ac, ~. 0 /U
Michael Ray Brower, Plaintiff Pro Se
Plaintiffs Affidavit of Consent Page 1 of 1
IN THE COURT OF COMMON PLEAS. OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower ~,,,
Plaintiff Pro Se, ~ ~ =n
~_,
v. ~ s {~..
-=;
Stacie Robin Brower , ~ ~~
Defendant Pro Se.
.- W~.,
-- o ~~ ~ ~~
,~~ ~ ~ . ~.
AFFIDAVIT OF CONSENT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
3~ a2 G i U and served on y /Y~ „ ,zQ /D
2. The marriage of the 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 are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: ~ /w~, ~. U ~U
Stacie Robin Brower, Defendant Pro Se
Defendant's Affidavit of Consent Page 1 of 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA ~~ ~ ;
CIVII. ACTION-LAW cM.
-~
:.- -..~ - .ten
,~, =`~ t ;_ ~;_,
Michael Ray Brower ~m"" "~' _ .
Plaintiff Pro Se, -~-
vs. : - ~ ~
Stacie Robin Brower "-= ~ c..
Defendant Pro Se.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§ 3301(c) OF THE DIVORCE CODE
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
unsworn falsification to authorities.
Date: ~ ~v S ~ 0 ~U
~'~ :~'
Michael Ray Brower, Plaintiff
Plaintiff s Waiver of Notice of Intention Page 1 of 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION-LAW
Michael Ray Brower ~
Plaintiff Pro Se, ~~` `~
- .. _. `r'
' - ~~~
Stacie Robin Brower _ S ~ ~;
Defendant Pro Se. ~ ~ -_ W r.,~,
~-
=-~ o f--
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§ 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 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
unsworn falsification to authorities.
Date: a ~v y o2G / jJ
~1 ~o n~ir 6~.EL C~'t~P/)
Stacie Robin Brower, Defendant
Defendant's Waiver of Notice of Intention Page 1 of 1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Brower, Michael Ray
Plaintiff
VS.
Brower, Stacie Robin
Defendant
FILE No. 2010-02951
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
20
_O nc
r
-C
Notice is hereby given that the Plaintiff/Defendant in the above matter, having
been granted a Final Decree in Divorce on the 18th day of August
hereby elects to resume the prior surname of Emswiler
and gives this written notice pursuant to the provisions of 54 P.S. 704.
DATE: //,? /-? o/O
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Signature
?-C
t
W
iv
iv
Signature of name being resumed
SS.
r-cl
On the c
day of Novi, , 20 Id ,before me, a
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 Whereof, I have hereunto set my hand and official seal.
1
COMMONWEALTH OF PENNSYLVANIA N blic
Notarial Seal
Stacy M. Omer, Notary Pubb
Lower Allen Twp., Cumberland Caa+ty
My Commission Expires Dec. 25.2012
Member, Pennsylvania Association of Notaries
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