The URL can be used to link to this page

Home My WebLink About04-5995CHRISTOPHER P. BRUNNER, Plaintiff V. ELIZABETH J. BRUNNER, Defendant NOTICE T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 0 CIVIL TERM IN DIVORCE O 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 CHRISTOPHER P. BRUNNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW ELIZABETH J. BRUNNER, NO. ??? 9yS CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Christopher P. Brunner, an adult individual currently residing at 4121 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Elizabeth J. Brunner, an adult individual currently residing at 4121 Nantucket Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 14, 1993, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. 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. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (d) of the Domestic Relations Code. COUNT H ADULTERY 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed adultery by having sexual relations with a man individual contrary to her wedding vows and the Plaintiff is the innocent and injured spouse. WHEREFORE, Plaintiff requests you Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (a) (2). C tTNT III EOUITABL? DISTRIBUTION 13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full text. 14. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 15. Plaintiff and Defendant are joint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 16. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties. Respectfully submitted, Wendy I F. Grell s Attorney for PI 'nti 3618 North 60' S Harrisburg, PA 17110 (717) 234-6001 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. /l J ][)ATE: ][)ATE: ( CHRISTOPHER tBR&UNNAE'/FL,, Plaintiff ?- O LIP Q) V ca4 Gn\ C7 N <,. r7 `TS c CHRISTOPHER P. BRUNNER, Plaintiff V. ELIZABETH J. BRUNNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 045995 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE: AND NOW, this '?'t i tAay of December, 2004, comes Wendy J. F. Grella, Esquire, Attorney for Plaintiff, Christopher P. Brunner, and states that a true and attested copy of a Complaint in Divorce was sent to the Defendant, Elizabeth J. Brunner, at 4121 Nantucket Drive, Mechanicsburg, Pennsylvania, 17050, by certified mail, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on December 6, 2004. Wendy J. F. Grella, 99q& Attorney for Pla' tff 3618 North S' Street P.O. Box 5292 ?--- Harrisburg, PA 17110 (717) 234-6001 befo e e this day of 2004. 1 A NOTARY PUBLIC Sworn and subscribed to NC" .? ' F"Wy SA A. RIC._ Y ' , -5LIC F H6RRISEsI, _ . rilN COUNTY Mti "? FK' !BES ` 8ER 10, 2006 NOTARIA=DAUPHINCOUNTY LISA A. RICE, NCITY OF HARRISBURGMY COMMISSION EXPIR -0 ..n Ln , . rt m Tu Ln Postage C] Certified Fee C3 Q Return Reclept Fee (Endorsement Required) C] Restricted Delrve Fee -D (Endorsement Required) r-q r-9 Total Postage & Fees C] Sent To ¦ Complete items 1, 2, and 3. Also complete A. Sig ure item 4 If Restricted Delivery is desired. X ¦ Print your name and address on the reverse so that we can return the card to you. by (Pdnred IJarrte) Z C. Date of Del i ¦ Attach this card to the back of the mailpi EC 6 204 or on the front if space permits. D. Article Addressed to: D. Is delivery address different 1? ? Yes ? M YES, enter delivery address bolo ? N o RE- r ..OSPS ' 3. Serv t CertMied MaU ? Express Mail ( ? Registered ? Return Receipt for Merchandise ? Insured Mail 13 C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number ^A ' (' (Transfer from service label) Z Y H {IlLXJ WIC; /?-r O? Ps Form 3811, February 2004111 ??' Domestic Return Receipt 1102595-02-M-11540 C=1 ? `... a n C-1 i ? ? s:. y ?7 - x? ?JTI Curtis R. Long Prothonotary office of the Vrotbonotarp Cumbertartb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor InAl -n9.5 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square - Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573