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Home My WebLink About04-4853 "" '-' RUTH BRENIZER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. Ol..j - '-IJ>S~ (!,O' ~l/€tL~ HAROLD BRENIZER, Defendant : CIVIL ACTION - LAW : 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 divorce or armulment 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary 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 32 South Bedford Street Carlisle, PA 17013-3308 (717) 249-3166 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 0'1- 4PG.3 C,v.L '-r~ RUTH BRENIZER, Plaintiff HAROLD BRENIZER, Defendant CIVIL ACTION - LAW DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW comes the Plaintiff, Ruth Brenizer, by and through her attorney, Jearme B. Costopoulos, Esquire, and avers the following in support of this Complaint in Divorce: L The Plaintiff, Ruth Brenizer, is an adult individual who currently resides at 30 Northview Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The Defendant, Harold Brenizer, is an adult individual who currently resides at 1829 Basin Hill Boulevard, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant 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 June 3, 1990, in Las Vegas, Nevada. Count I - Divorce 5. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 6. There have been no prior actions of divorce or for armulment between the parties. 7. The marriage is irretrievable broken. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 10. There are no dependent children from this marriage. 1 L This action is not collusive. Count II - Equitable Distribution of Marital Property Pursuant to !l3502 of the Divorce Code 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. Plaintiff and Defendant are the owners of various iterns of real and personal property, furniture and household furnishings acquired during their marriage, which are subject to equitable distribution by this court. 14. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits acquired during their marriage, which are subject to equitable distribution by this court. 15. While no settlement has been reached as of the date of the filing of this Complaint, Plaintiff is willing to negotiate a fair and reasonable settlement of all matters with Defendant. To the extent that a written Marital Settlement Agreement might be entered into between the parties prior to the time of hearing on this Diyorce Complaint, Plaintiff desires that such written Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage between the parties. , Dated: WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the rnarriage between Plaintiff and Defendant; B. Equitably distributing all property owned by the parties hereto; C. In the event that a written Marital Settlement Agreement is reached between the parties hereto prior to the time of the hearing on this Complaint, Plaintiff respectfully requests that pursuant to the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; D. For such further relief as the Court may determine equitable and just. RESPECTFULLY SUBMITTED: ~ t( /z2/ ZlOf ---------- Jearme B. Costopoulos, Esquire --., 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 P A Supreme Court ID No, 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR PLAINTWF " RUTH BRENIZER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. HAROLD BRENIZER, Defendant : CIVIL ACTION - LAW : DIVORCE VERIFICATION I, Ruth Brenizer, hereby verifY that the statements made in the foregoing Complaint in Divorce 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: r /ZZ!Zqqy Signature: ~d Ruth Brenizer -pP \\--11. .... .t Vt~ VI ~ ~ -n ~Pv::O - ~ () o v , V, Q 111 o C' ().. I I ~R- ~ ~\r: '-'--'0 n ~~~ (~i';;-' ~;:. \:", u~ . .:;: ~- ' -r-," , '5~;~ ~ c~ .,J;:..- Cr) ~ o -n ~:,S\ -,U'T N ()t) --" ','"1' ~! ;~~,~:_~-~ ='- ~ .::\ :). o c;.l ----........"..", - ~ r..f"' RUTH BRENIZER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 04.4853 CIVIL TERM HAROLD BRENIZER, Defendant : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-referenced divorce action filed on September 27,2004 discontinued and dismissed, ---'- BY: DATE: Tie Izl'!!,6 'ie:me B. Costopoulos~sq~ ATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 P A Supreme Ct ill No. 68735 ..~ ~r RUTH BRENIZER, Plaintiff ; IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. ; No. 04-4853 CIVIL TERM HAROLD BRENIZER, Defendant ; CIVIL ACTION - LAW : DIVORCE CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the person(s), and in the marmer, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid, and addressed as follows: Harold & Ruth Brenizer 1829 Basin Hill Blvd. Carlisle, P A 17013 BY: .~ ----. Jeanne B. Costopoulos, Esquire 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 P A Supreme Ct. ill No. 68735 DATED: 7f? /Zd-d (j ~. i~. ~l!~~ ~~ ~ , jO~;~ ; ~ ~ \