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Home My WebLink About01-0688SUSAN M. BROWN, Plaintiff BRETT K. BROWN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01- (g~?/ CIVIL TERM ; : CIVIL ACTION - LAW : 1N 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 may proceed without you and a decree of divoree 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 Prothonotary's Office at the Cumberland County Courthouse, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SUSAN M. BROWN, Plaintiff BRETT K. BROWN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01- (-~f CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Susan M. Brown, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Susan M. Brown, is an adult individual who currently resides at 657 Grahams Woods Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, Brett K. Brown, is an adult individual who currently resides at 135 Oakhill Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 2, 1992 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Susan M. Brown, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Date: Respectfully submitted, "ff-h~mas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX VERIFICATION I verify that the statements made in this Complaint are tree 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. SUSAN M. BROWN, Plaintiff SUSAN M. BROWN, Plaintiff BRETT K. BROWN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-688 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 6th day of February 2001, comes Thomas S. Diehl, Esquire, Attomey for the Plaintiff, Susan M. Brown, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Brett K. Brown, at 135 Oakhill Road, Carlisle, Pennsylvania by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on February 5, 2001. Respectfully submitted, Thomas S. Di~l Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX RE: DIVORCE COMPLAINT .2o ~.~-- $ 7.15 '~~, PA 17013 1. A~tlcle Addressed to: if YES, enter delive~ address below: [3 No BRETT K. BROWN 135 OAKHILL ROAD CARLISLE, PA 17013 2. Article Number (Copy from service 3. Service Type 7099 3220 0009 5573 8382 PS Form 3J~'J 1, July 1999 Domestic Return Receipt Ph/intiff :IN I-HE('OLiP,'I ()FCOMMONPll \S{~I. :L't!MBERI.~NI)('O[iN'IY. PI:NNNYI .\NI\ 01-688 ( 'IVII II:R\I BRETT K. ( IVII. ACll{ N - I.AW : IN DIVORCI AFFID,\VI'I OF CONSENI' 1. \ c,m/pltunt ill dj\oreo under §3301(c) of tile I)ixorce ~'odc ~:~, l~lcd on 2. lhc n/an'iago o1' Cnc Plaimil'l and Defendant is irrctrie\ablx brol,.en and ninc~x (90) days have elapsed t'tnm thc ditto of filing and service of the Complaint. 3. J COIISC11~ tO thc Ct/fY\ intention to request cntrx of thc I I veril? lhat lhc Maltine]its n/adc il/ Lhis al~davil a~:e true and corrccl. [ tlndcrMal/d [hal false statemen[s herein arc made ~ubjcct t[~ lhc penalties or' 18 Pa. CS. 49[)~> rclalin5 ~o tlltsxxorll falsification to authorities. Date: ~ // ':'" ' ~' ~' ' Susall M ~rown. Plail~liJT WAIVER OF NOTI( E ()F IN'[I<NI'I()N TO REQUEST ENTR~' OF ,\ I)IVOR('E I)E('RI<I,i I NI)ER §3301(c) OF Till,; DIVORCE CODE 1. [ consent to the cnti'x o1' a I' inal Decree in Divorce \\ill~otll: notice 2. I understand thai I max h~',c rights conceriling alimon>, divis~e,n oi propcn>. lawyer's tbes or expenses ill do not clailn Ihom before a di,,orce is granted 3. I understand that I \\ill not be divorced until a Divorce Decree ~s entered h> thc Court and a cop? of Ibc l)ccrcc \~ill hc sent to me immediately alicr i~ i>; filed xxith ti~c Prothonotary. I verify that the shttcnK:nls made in this affidavil are true and correct. I /]ndetstm/d thai false statements herein arc made xubicc~ to d~e penalties of 18 Pa.C.S. ~ 4909 rclaling t~ unsxxorn falsification to auflmrities Date: _~Z :7 ::::: Nc k , ,, " . Susan M. Brown, Plaintiff ~d~ 15LITe, KY ANt SUSAN M. BROV,'N. Plainti : IN IHE COURT ()1. : ('[ ;MBERLAND ('()( iN'FY. Xr. : N(). 01-688 CIVIl I IRM BRETT K. BROWN. Dcfendam : ('IVll, ACTION - I AW :IN DIVORCI! AFFIi)A~, I I OF CONSLNT 1. A comp tim in ,t, ~,'c: ,re,lyf §330!(c) of the Dix. m':c February 2,200l. 2. The man'iago of lilt l'kfintifF and Defendant is irretricxabl5 broken and ninctx (90) days have elapsed Ii'om Ibc date of fi ling and service of the ( 'omplaint. 3. I COFISCI}[ intention to request Clqll'X O1' t/~C I),CCFCC. // I / [ verify,hat thc :qatcmcnls made m ibis a~ldav~rc ,ru~':!d Zon-cct.' ;i undcrqand that falsification t~ auth/~rifics. ' I ~ / Brett K. Brown, l)clkmdant WAIVER OF NOTI('E I)F INTENTION TO REQUEST EN'FR~ OF I)ECREI;: I~NI)ER §3301(O OF THE I)IVORCE CODE l, ] consent lo thc cmrs ota Fh}al Decree in Divorce wJlhotlt re>rice. 2. 1 understand thai I ma) lose rights concerning alimon), division ol pJ'opcrty. lawyer s fees or expo ~scs iii d{. ilol claim lhem before a divorce is granted. 3. I understand dm~ I will not be divorced until a Divorce l)ccrcc Court and a cop5' of thc l)ccrcc will bo sent to me immediateb after Prothonota~. I veri~ mt,c s,awm,:nts ,,,adc in this affida4are triCO ~,,rrec hlse statemets ,t¢i~,.arc made subicci to lhe penaltie/~f 18 ~.~.] 4907 falsificatio~to ~ tt~ormes. &, . ~ ~" I/ .e-}, ...... Brett K.-~i~}~t ~1 ]NAN 'xl. DclL:nclai~ : 1N THE COURT OF COMM( )N I'l I '~ 'q ()1 : CUMBERLAND ('OUNTh. : NO. 01-688 CIVIl, I IRM : CIVIL ACTION - : IN DIVORCE PRAECIPE TO TRANSMIT RECORD I() '1 Ill( ]'ROTtI()Nt)I'ARY: 1 raasmit the recor& together with the following information, to the ('ourl l,,t c Ii~, ltl' il ,.Ii*, Ol'CC c~ecree: I Ground Ibr dixorce: irretrievable breakdown under § 3301(c) 3~h~+~ t~l :he I)ixorcc lode. (5;t,'ike out inapplicable section). 2. Dam m~d manner of service of the Complaint. Service was made ou l;'ehruarx 5, 2001 b> ccrtilScd mail, restricted delivery signed for by the Defendant. (Complete eilher I)aragraph (a), or (bi.) Date of execution of the Affidavit of Consent required by ~ 3301(c) of th~ i )ix ~)rcc the Plainfff: Ma) 19, 2001; by the Defendant: May 22, 2001. (bi ~1) Date of execution of the PlaintifPs Affidavit required by § 3Y01(d)~ I ~hc (2) Dale of service of the PlaintifPs Affidavit upon the 4 Related ckfims pending: None, 5. (( ompleie either (~0 or (bi; {al Date and manner of service of the Notice of Intention to File t'raccipc Record. and a copy of which is altached: ih) Date of' execution of the Waiver of Notice of Intention to File ~cquired b3 ~ 3301(c) of the Dix. orce Code: by the Plaintiff: May 19, 20111: Ma) 22, 22111. ~ehl, Esqmre Attorney for Plaintiff IN THE COURT OF COMMON PLEAS SUSAN M. BROWN, Plaintiff OF CUMBERLAND COUNTY STATE OF PENNA. No. 2001-688 VERSUS BRETT K. BROWN, Defendant DECREE IN DIVORCE AND NOW, DECREED THAT SUSAN M. BROWN AND BRETT K. BROWN , IT IS ORDERED AND ,PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; NONE.