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Home My WebLink About01-7181 CECILIA BROADWATER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. No. at.... 11ft Ci..;,l ~ CIVIL ACTION - DIVORCE GEORGE BROADWATER Defendant 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 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 Prothonotary Dauphin County Courthouse, Harrisburg, P A. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA No. 01- 7/4'( Ql~~l ~~L CECILIA BROADWATER Plaintiff GEORGE BROADWATER Defendant CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Cecilia Broadwater, by Bryan S. Walk Esq., and represents as follows: COUNT I DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Cecilia Broadwater, who currently resides at 108 Rear South 16th Street, Camp Hill, Cumberland County, Pennsylvania, and has resided there for approximately 11 (eleven) years. 2. Defendant is George Broadwater, who currently resides at 108 Rear South 16th Street, Camp Hill, Cumberland County, Pennsylvania, and has resided there for approximately 11 (eleven) years. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on, November 17, 1990 in Corriganville, Maryland, 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and the Defendant. / Bry alk I. .# 63881 108 - 112 Walnut Street Harrisburg, P A 1710 1 (717) 238-5113 ATTORNEY FORPLAmTWF VERIFICATION The undersigned verifies that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties at 18 Pa.C.S, A., ZA904 relating to Unsworn Falsification to Authorities. DATE: /2 -1f3 ~o f ~~~~ Plaintiff q - ~ )::; \I '" ~ Oh~ . ~ '" GJ ' irt 3; '" ~ OOey ,..> j ~ D :Vb D -.J ~ ~ J o Q, o _ c ~ .. "'" ........ '" """' rT\ .,., -ow M ..:~tQ '::2:i) N ;1'-r' 9 ZC; -J::\:: CP~ ::t"* 'i'~~ ~c -,.. '''''.'''' b - ~ "'.~l!' >0 - C zu....., ::::> ~_\ 5>c: ., ~ z ,,,.) ~ ::t .... II CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01-7181 GEORGE BROADWATER, Defendant : CIVIL ACTION - DIVORCE DEFENDANT'S 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 December 27,2001. 2, The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalti~:s of 18 Pa. C,S, ~ 4904 relating to unsworn falsification to authorities. Date: /..f ~;U ~ Cl t/ Signature: ~/.A~~ Gl:orge Broadwater (') g ~ ~ ...,.. ~co :Do iI nlrr~ ;g """:';>- ~r ~."'.. ~- c.- I'\) (/)..,.::~ ~C: ...., ~O :::.. :;;;t2 ::.: ~ ~ ~ Q\ CECILIA BROADWATER, Plaintiff IN THE COURT OF OMMON PLEAS OF CUMBERLAND CO NTY, PENNSYLVANIA vs, : No, 01.7181 Civil GEORGE BROADWATER, Defendant CIVIL ACTION. L IN DIVORCE AND NOW COMES, the Defendant, George Broadwater, by d through his attorneys, The Law Otlices of Patrick F. Lauer, Jr., and moves the Court to appoi t a Master with respect to the following claims: (X) Divorce ( ) Distribution of Property ( ) Annulment ( ) Support ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite () Costs and Expenses and in support of the Motion states: 1. Discovery is complete as to the claims for which t e appointment of a master is requested, 2. The Plaintiff has appeared in the action by counsel BanS, Walk, Esquire, 3. The statutory grounds for divorce are 3301(c) and 33 1 (d), 4, The action is contested and no agreement has been re ched with respect to the claim. 5. The action does not involve complex issues of law 0 fact. 6, The hearing is expected to take one (1) day. Respectfully submitted, ./ / / .// Date: April12, 2005 ,Marl' L. arkley, Esquire 2108 Mar et Street, Aztec Bui1 ing Camp Hill, Pennsylvania 1701 .4706 10# 84745 Tel. (717) 763.18 0 CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND CC UNTY, PENNSYLVANIA vs, : No, 01.7181 Civil GEORGE BROADWATER, Defendant : CIVIL ACTION. L W : IN DIVORCE {"'I....rl 11<'11 'A'T'1<' 01<' "'1<'~VIl 1, Marlin L. Markley, Esquire, hereby certify that on the below.noted date, served a true and correct copy of the foregoing Motion for Appointment of Master upe n the following named counsel by depositing same, postage prepaid, in the United States Mail, addr ssed as follows: Bryan S, Walk, Esquire 114 West Chocolate Avenue Hershey, P A 17033 Date: April12, 2005 ./? /2~ -M~lin( ark1ey, Esquire 2108 Market Street, Aztec Bt i1ding Camp Hill, Pennsylvania 170 1.4706 ID#84745 Tel.(717)763.1 00 0 "" 0 (:.::-::. c- ,',:::) .., > CJ'\ :POI ---1 ::1'':':-'''1 -.:;I rl1r~ ;;0 :~;~! .. N ;' -,:t O' - 1"-) ) $:-.. .....-:. vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-7181 CIVIL TERM CECILIA BROADWATER, Plaintiff GEORGE BROADWATER, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301Cd) OF THE DIVORCE CODE 1. The parties to this action separated on or about December 2001, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. 5 4904 relating to unsworn falsification to authorities. DATE: rlt;. f1f1J O~ ~~~!1~~ - n .h-~..r..'.....,', U' I ............n....n r n\ ,,--1' '1'\ 11' : :L..., { ~ ~A'j .., 1 20~ .___._*__w______.~___~__ I"- ir: ..:J' ~ .:.:. uJ ~ ::c QQ a.. Pc~ ~~ uJO- ftiS ~ ~ I 5 ..., U':> ~ ~ ;::).:( n- b~ (;:~ ~""'W "JZ '~'~.'- j~tj d:i \".1JO- """ :;) <.:> / CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : No, 01-7181 GEORGE BROADWATER, Defendant CIVIL ACTION - DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: CECILIA BROA])W ATER, Plaintiff c/o Bryan S, Walk, Esquire PO Box 650 Hershey, PA 17033 You have been sued in an action for divorce, You have failed to answer the complaint or file a cOWlter-affidavit to the S 3301(d) affidavit. Therefore, on or after the nnd day of July 2005, the other party can request the. court to enter a final decree in divorce, If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a cOWlter-affidavit by the above date, the court can enter a final decree in divorce, A cOWlter-affidavit which you may file with the Prothonotary of the Court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date, or the court may grant the divorce and you will lose forever the right to ask for economic relief, The filing of the attached form cOWlter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER 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, P A 17013 (717)249-3166 CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No, 01-7181 GEORGE BROADWATER, Defendant CIVIL ACTION - DIVORCE COUNTER-AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): o (a) I do not oppose the entry of a divorce decree, o (b) I oppose the entry of a divorce decree because: Check (i), (ii), or both: o (i) The parties to this action have not lived separate and apart for a period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (a) I do not wish to make any claims for economic relief, I rmderstand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses in do not claim them before a divorce is granted. o (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights, I rmderstand that in addition to cpecking (b) above, I must also file all of my economic claims with the prothonotiuyin writing and serve them on the other party, If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay, I verify that the statements made in this cormter-affidavit are true and correct I rmderstand that false statements herein are made subject to the penalties of 18 Pa, C.S. 9 4904 relating to unsworn falsification to authorities. Date: Cecilia Broadwater, Plaintiff NonCE: IF YOU DO NOT WISij: TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND yOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU .SIIOULD NOT FILE TillS COUNTER-AFFIDAVIT ('; (~ ~ .;:..:-) '-" S:~ ~:.:; p.~) r-.:> .-, >n ~ ~s -- c.".) I' I CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO,: 01-7181 GEORGE BROADWATER, Defendant : CIVIL ACTION - LAW : IN DIVORCE A FFmA VTT OF SFRVTCF TO THE PROTHONOTARY: I, Marlin 1. Markley, Esquire, verifY that the Notice of Intention to Request Entry of 3301(d) divorce decree and Counter-Affidavit under g 3301(d) of the divorce decree has been served upon the Plaintiff s attorney by first class, certified mail # 7000-1670-0005- 2769-4545, postage prepaid, return receipt requested, pursuant to the requirements ofPa, R,C,P, 1930.4, ... :II .~~1_21or__. . .~""3,"''''4b. I .Print your name and addret8 on the revM'H of thiI form 10 that we can return thI, card to you. -Attach thIa fonn 10 the front of the 1'l'IIli1pq.ce, or on the bad!; If epace does not pormlt. . -Write "Return Rec8Ipt RtIqU8$t<<J" on the maHrMce below the article number. ii -The Return Receipt wm Ihow to whom the article was dltIivered and the dlle g ""'-"<I. I 3, Ar\lcI& Addfessedlo: i ~.~ Ju~, ~ n ~ ~SO , 11/ I7tiJJ I ' (PrInt(!;ldinic/ l 6. s~natur.: 'Addre .~ J! PS Form 3811, December 1994 102595-97.8.0179 i i 1i. 1 ,.- II: :s E J/JIAfY< .! .5i . " 2 " ~ J mastic Return ecelpt Respectfully submitted, ~ 7-L2'lD(J) Date: ar1i1'1 ,Markley, Esquire Law fices of Patrick F, Lauer, Jr" LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 --~., (, ....> ~ ~ ,-- c~ N N C, -n .....\ ""'--n rl'lt~ ~?Ij() -.'-)Ci --'1"'1"' '--~, ';~~~:?1 c:::.I" :i}. ~ ....-.:; - u:> " CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO,: 01-7181 GEORGE BROADWATER, Defendant : CIVIL ACTION - LAW : IN DIVORCE A FFIOA VIT OF SF,RVlCF, TO THE PROTHONOTARY: 1, Marlin 1. Markley, Esquire, verify that the Affidavit Wlder ~ 3301(d) of the divorce code has been served upon the Plaintiff s attorney by first class, certified mail # 7000-1670-0005-2769-4538, postage prepaid, return receipt requested, pursuant to the requirements ofPa, R,C,P, 1930.4, i I ! J Ii I ~u AJ4 fo 6~ -CompItIe *"- 1 tndfor 2 tor 1ddNonII.... .CompWe 1tem13. q, and 4b. .P,,", yOur name II'Id add,.. on the ~ of Ihlt form fa that we can retum tNa card 10 you.. -Attach this tonn to the front of the maHpiece. or on the back if apace doeI not permit. -Write.Refum FlocoIpt _ on Iho molIploco below tho _ nwnbe<. .n. ....um Receipt wi' show to whom the artIde was deIMnd and the date _. I aIIIO wI8h to r8C8IW "" following service. (for an sxtra tee): 1. 0 Addressee'. Address j 2. 0 RSSlricled Delivery ~ ConsuIl postmaster for fee. 4a. ArtIcle Number ) 7000 b ~ 4b, Service Type .j! o Registered ~'dIIt.d ! o Express Mall 0 Insured .Ii . o RslumRecolptlorMsrtl1en<tse 0 COD " 7, ~ ! J s-- 8. Addr....... . ress (Only If requested snd tee Is paJct) ~ " ~ Date: 7- 2-7... -2C!os 'Marlin arkley, Esquire Law Offi es of Patrick F, Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 ~'- " "'--', 1 -&\ "'. ~f_ trJ ~~ -"i '> ~~. 'iJ' ~.) '~ "'<:", (~ ,.-' .". -" 0J CECILIA BROADWATER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. NO. 01 - 7181 CIVIL GEORGE BROADWATER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this -9'^- i:2 :7' day of ~ having been f~led December 27, 2005, a divorce complaint 2001, and no economic claims having been raised in the proceedings, and the parties having been separated for a period in excess of two years as averred in the affidavit under Section 3301(d), there being no matters, therefore, pending before the Master, the appointment of the Master is vacated. BY THE COURT, cc: ~arlin L. Markley Attorney for Plaintiff ",8'"ryan S. Walk Attorney for Defendant ss:\) ! J'j e,l c,l\l\l ~o 1\ CECILIA BROADWATER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO,: 01-7181 GEORGE BROADWATER, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAF,CIPF, TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under S JJ01(~) S 3301(d)(I) of the Divorce Code, (Strike out inapplicable section) 2, Date and Manner of service of the Complaint: n"f"nnant a,oc,"pt"rl ,,,rvic,, of th" complaint in n"c-"mhef of?OOl 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by the Plaintiff ; by the Defendant (b) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: May ?Ii, ?OO~ Date of filing of the P1aiuliff,,/Defendant's affidavit upon the respondent: 111n" " ?OO~ Date of service of the rl"i1Jlii]',/Defendant's affidavit upon the respondent: llln" 9, 7005 4, Related claims pending: N{)n~ No d::Jlm~ r::1j~pcJ 5, (Complete either paragraph (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, S"rv"cl c"rtifi"cl mailnpon Plaintiff', attorney on Tnly 1. ?OO~ (b) Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: Respectfully subrIl~' // v" Date: '7 - 22,2 [} D S- arJ,irr ,Markley, Esquire Law 0 Ices of Patrick F, Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800