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Home My WebLink About10-3053 ,aL.. NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF COLLEEN J. BRUMBACH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DALE L. BRUMBACH, : NO. 2010 - 3053 CIVIL TERM Defendant : IN DIVORCE NOTICE 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 in 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, Carlisle, Pennsylvania 17013. 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 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 * 55a.oO PIJ KRY ce aq(c7 P_ 2q / 1747 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF COLLEEN J. BRUMBACH, Plaintiff V. DALE L. BRUMBACH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2010 - CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C1 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is COLLEEN J. BRUMBACH, an adult individual residing at 1266 Brandt Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The defendant is DALE L. BRUMBACH, an adult individual residing at 5051 Ravenwood Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on September 21, 1985, in Camp Hill, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this Complaint 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. 41'11J?2 2010 S 1? d , 2010 BY: COLLEEN J. MBA CH, Plaintiff WOLF & WOLF, Attorneys at Law N C. WOLF, ESQUIRE Su a Court ID #87380 10 est High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff ~,~ .~,r NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF 2010 ~~Y ~ 8 f Iii 1~' 1 J rc~tiPJSYLV;~{~;A COLLEEN J. BRUMBACH, Plaintiff v. DALE L. BRUMBACH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.2010 - 3053 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO.1920 4 (al(11(il NOW, Nathan C. Wolf, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about May 17, 2010, by certified mail "restricted delivery," addressed to the defendant at 5051 Ravenwood Road, Mechanicsburg, Pennsylvania 17055 return receipt No. 7008 1830 0003 0543. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit 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. May .~, 2010 ~,~.! ~~ ' `" N .WOLF tto y for Plaintiff ~ ^ Complete items 1, 2, and 3. Also complete ftem 41f Restricted Delivery is desired. ~ ^ Print your' name and address on the reverse so that we can return the cans to you. ^ Attach this card to the back of the mailpiece, I or on the front if space permits. 1. Article Addressed to: Y ~ ~~; ~I Uv~l,.. (/ ^ Agent B. Fjeceived byf~poLpgjVame) ~ C. Date of Delivery p~1~ ~.. '~~rv-rnbac.i~ Fj 0~ 1 'R-o~ve~,n wool ~l . VUI ~a~ - cs bvt ~~ ~ ~--~ /~ D. Is rasa diffens ` ^ Yes If Met delivery add No '~' d^7 ?~ 3. Service Type ____ ~ertlfled Mail ^ Express, Mail ^ Registered O Retum Receipt for Merohandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) Yea i 2. Article Number ~-'~ I ~~„~,~onse„~etaeer~ 7228 1830 2223 5942 2543 ~I PS Form 3811, February 2004 Domestic Return Receipt ~o2sas-o2-M-tsao COLLEEN J. BRUMBACH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW m co =z DALE L. BRUMBACH, : NO. 2010 - 3053 CIVIL TERM =M^- =s -n 'r= Defendant : IN DIVORCE r- cn C) ear -- DEFENDANT'S AFFIDAVIT OF CONSENT =' 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about May 10, 2010 and served upon defendant on May 17, 2010 (see affidavit of service filed May 18, 2010). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the 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 of the divorce. I verify that the statements made in this affidavit 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. 2- , 2011 ;Qa4a--.&4 ALE L. BRUMBACH COLLEEN J. BRUMBACH, Plaintiff V. DALE L. BRUMBACH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2010 - 3053 CIVIL TERM : IN DIVORCE rtv :Ern to ? <, r"a a?• cri !,_3 7i WAIVER OF NOTICE OF IN NTioN To REQuE ENTRY OF A DIVOR .F. DEcRF.F. UNDER SECTION 3301(C) OF THE DIVORCE COD 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. Section 4904 relating to unsworn falsification to authorities. S- , 2011 ?. DALE L. BRUMBACH Colleen J. Brumbach V. Dale L. Brumbach IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3053 DIVORCE DECREE AND NOW, MPi? 011 , it is ordered and decreed that Colleen J. Brumbach plaintiff, and Dale L. Brumbach , 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 marital settlement agreement dated April 28, 2011 is incorporated by r er nce u n merged in is decree. By the Court, \1? Attest: J. Prothonotary 51iok - Ced-. e y n?a,% r? a wv??' 1tlo?c? ? Copy ,hay%d r4? r?y?,?m