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HomeMy WebLinkAbout01-1249ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA : NO. Ot- IV?q? : 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 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 marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One 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 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, PA 17013 Telephone: (717) 249-3166 ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNTY, PENNSYLVANIA NO. 0 CIVIL ACTION - LAW IN DWORCE COMPLAINT IN DIVORCE 1. The Plaintiffis Robert L. Brubaker, is an adult individual currently residing at 116 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043. 2, The Defendant is Susan D. Brubaker, an adult individual residing at 205 Conodoguinet Mobile Estates, Newville, Cumberland County, Pennsylvania, 7241. 3. Plaintiffand Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 29, 2000, in Cumberland County. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. This action is not collusive. Plaintiff and Defendant separated on or about November 20, 2000. The causes of action and sections of the Divorce Code under which Plaimiffis proceeding are: A. Section 3301(c) - The marriage of the parties is irretrievably broken. B, Section 3301(d) - The marriage of the parties is irretrievably broken. The parties separated on or about November 20, 2000, 9. Plaintiff and Defendant have no children. 10. Plaintiffhas been advised of the availability of marriage counseling and understands that he may request that his spouse and he participate in counseling. 11. Plaintiff does not request that the Court require that his spouse and he participate in counseling prior to a divome decree being handed down by this Court. Wherefore, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. Date: Respectfully submitted, ire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 I.D. No. 33671 Attorney for Plaintiff AFFIDAVIT and correct to the best of my knowledge, information and beliefi I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unswom falsifications to authorities. Dated: ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-01249 Civil Term : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE The undersigned, Beth Lengel, hereby certifies that a copy of a Complaint in Divorce was served upon Susan D. Bmbaker, on March 10, 2000, by certified mail, return receipt requested, addressed as follows: Susan D. Bmbaker 205 Conodoguinet Mobile Estates Newville, PA 17241 I hereby certify, that the aforegoing is tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: (.~ 3 / · ~ it~m~ 1, 2, a~d 3. AI~o eoml~l~e item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reverse so that we can return the card to you. I Attach this card to the back of the mai{piece, or on the front if space permits. 1. Article A~dressed to: D. Jspe~iwq'addr~sdJffemntf~mi~l? []Yes n No , Oeliv.r to addre% , 3. ice Type ' [] Registered I-I Return Receipt for MerchandMe 7000 OOa% oOe2 ' 0 ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01-01249 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 5, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and 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 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 falsifications to authorities. Date: Robert L. Brubaker ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER, Det~ndant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-01249 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (e) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. 1 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. rote: (o- I1-01 Robert L. Brubaker ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01-01249 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 5, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and 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 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 falsifications to authorities. Date: {~ -/Z-COO/ Susan D. Brubaker ROBERT L. BRUBAKER, Plaintiff SUSAN D. BRUBAKER., Defendant : iN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01-01249 CIVIL TERM : CIVIL ACTION - LAW : iN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 OF THE DIVORCE CODE 1. I consent to the entry ora final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl 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 Cot~ 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 mlderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: (0 -/2 ~ 20O I Susan D. Brubaker ROBERT L. BRUBAKER ~ ~ SUSAN Do BRUBAEER : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 01-01249 CIVIL TERM PRAEClPE 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 §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: 3/10/01, via certified mail, return receipt requested 3. Complete either paragraph (a) or (b), (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff 6/11/01 ; by defendant 6/12/01 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5, Complete either (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: N/A (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 6/21/01 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: 6/21/01 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ROBERT L. BRUBAKER SUSAN D. BRUBAKER DECREE IN DIVORCE AND NOW ........... ~..~. ..... ././.: ...... :~X; .~.9.0~1., it is ordered and decreed that ...~9.b.e?,~. . .L....~.r. ~.b.a?.e..r ......................... , plaintiff, and ........s.u.s. ~..n..D.....B.r u.b. ~..~.e.r. .............................. defendant, are divorced from the bonds of matrimony. The court retains iurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered: none "'---~' 0 Prothonotary ROBERT L. BRUBAKER Plaintiff VS. SUSAN D. BRUBAKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001 - 1249 Civil Term : : ACTION IN DIVORCE ELECTION TO RESUME PRIOR NAME To the Prothonotary: Pursuant to the Act of the General Assembly of the Commonwealth of Pennsylvania, of April 2, 1980, P.L. 63, I, SUSAN D. BRUBAKER, Defendant in the above-captioned case, in which a Decree in Divorce from the bonds of matrimony was entered on the July 11, 2001, do hereby avow my intention and do hereby elect to resume my prior name of: SUSAN D. FYOCK. SUSAN D. BRUBAKER/FYOCK. COMMONWEALTH OF PENNSYLVANIA ) ).'SS OnUs, the d yo; ,2001 before me, the undersigned officer, personally appeared SUSAN D. BRUBAKER, known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. o~~ P~bli~ My co~sslon expires Cafltsle SEAL