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HomeMy WebLinkAbout04-6161 SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToUW 26 W, High Street Carlisle, P A II " I GAIL C. BRANDT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - DIVORCE NO. 2004 ~& Ji, f CIVIL TERM IN DIVORCE JEFFREY A. BRANDT Defendant NOTICE 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 the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY I DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 By: SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A GAIL C. BRANDT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V5. CIVIL ACTION. DIVORCE NO. 2004 - {, 1(,\ CIVIL TERM JEFFREY A. BRANDT IN DIVORCE Defendant COMPLAINT Gail C, Brandt, Plaintiff, by attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Gail C. Brandt, who currently resides at 116 Flintstone Drive, Newville, Cumberland County, Pennsylvania 17241, where she has resided since September 6, 2004, 2. The Defendant is Jeffrey A. Brandt, who currently resides at 1000 Mountain Road, Newville, Cumberland County, Pennsylvania 17241, where he has resided since February 1988. 3, The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 28, 1985 at Newville, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLAW 26 W. High Street Carlisle, P A 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: ,tf7/PY SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff rJ &/1; c / By: ~ ~ Carol J, Linqsa Esquire 10 # 44693 c 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY AlTORNEYSoAToLAW 26 W. High Street Carlisle, P A VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. ~CTh~i: Gail C. Brandt Date: n~ I Lf ' (:j-j (J ,....., 0 (..::J ~ ~~.:; c.:) --I' ...:.- C) ---I ~ r '1 ~T: or, ~ Jt C) [I'r~- ~ [11 I ,C) , C:) , ) I, "- - 1(- ~ r .. ., "j r '- -: ""'J ~ "? i:~~~ ,,~ ....... ..... " tx ~ eq i i) i-l1 .....,' ~ ...... -'"" , -, (.) - - 1 -0 <'.~ -j:~ ""- ? -"I ...< -.J -~~ \'" ~ C - SAIDIS, FLOWER & LINDSAY ATTORNEVS.AT.IAW 26 West High Street Carlisle, PA GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2004-6161 CIVIL TERM JEFFREY A BRANDT, Defendant IN DIVORCE NOTICE 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 the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 Bedford Street Carlisle, PA 17013 (717) 249-3166 SAIDIS, FLOWER & LI QSAY ? By - SAIDIS, FLOWER & LINDSAY A:llOlC'IEYS.,u.LAW 26 West High SUtl:( Carlisle,PA II GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM JEFFREY A. BRANDT, Defendant IN DIVORCE AMENDED COMPLAINT 1. The Plaintiff is Gail C. Brandt, who currently resides at 116 Flintstone Drive. Newville, Cumberland County, Pennsylvania 17241, where she has resided since September 6, 2004. 2. The Defendant is Jeffrey A. Brandt, who currently resides at 1000 Mountain Road, Newville, Cumberland County, Pennsylvania 17241, where he has resided since February 1988. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 28, 1985 at Newville, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction COUNT I DIVORCE UNDER &3301 (CI OR /01 OF THE DIVORCE CODE 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceedin9 under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. ~ SAIDIS, FLOWER & LINDSAY ATIllR'<IoYS'AT.lAW 26 West High Street Carlisle, PA II WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. COUNT II DIVORCE PURSUANT TO !l3301(A)(61 OF THE DIVORCE CODE The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 8. Defendant has inflicted such indignities to Plaintiff, an innocent and injured spouse, as to render her condition intolerable and her life burdensome. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. COUNT III EQUITABLE DISTRIBUTION 9. The averments in paragraphs 1 through 8 are incorporated hereto as if fully set forth herein. 10. During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests this Court to equitably divide the marital property. COUNT IV COSTS 11. The averments in paragraphs 1 through 10 are incorporated hereto as if fully set forth herein. 12. Plaintiff seeks the sharing of the costs necessary for presentation of the parties case. WHEREFORE, Plaintiff prays this Honorable Court to assign to Defendant a share of the costs reasonably incurred in preparation of the case. By ~- . 1, arol J. Lindsa 10# 44693 L- 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS, FLOWER & LINDSAY ATlDJlNEYS.AT.!AW 26 West High Street Carlisle, l'A VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. Cc~j C-,B Xu,. d* Gail C. Brandt Dated: 3. 31-0C /- ) v.:J , , f",~ IL - (-) r< -C:: ; ~T1 j~ C, - --, :1" ::....' "1 J C) C' Ui " , ~ 0- J: -, V; (/-:; r\ (.) ( D UJ r-..,) T- '0 , , ~ / i Q ) . J- " / _J f) , ,/'J {", SAIDIS, FLOWER & LINDSAY ATIQRr>.US'AT'lAW 2(j West High Street Carlisle, PA .1 i GAIL C BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM JEFFREY A BRANDT, Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Gail C. Brandt, Petitioner, moves the court to appoint a master with respect to the following claims: (X) Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente Lite (X) Distribution of Property ( ) Support ( ) Counsel Fees (X) Costs and Expenses (Equitable Distribution) and in support of the motion states: (1) Discovery is complete as to the claims for which the appointment of a master is requested. (2) The Plaintiff, Gail C. Brandt, appeared in the action and is represented by counsel Carol J. Lindsay, Esquire (3) The statutory grounds for divorce are S3301 (c) and/or (d). (4) Delete the inapplicable paragraph(s). (a) (b) The action is not contested. An agreement has been reached with respect to the following claims: NONE. (c) The action is contested with respect to the following claims: ALL (5) The action complex issues of law or fact. (6) The hearing is expected to take one day. . SAIDIS, FLOWER & LINDSAY ATIOIlNEYS'AHAW 26 West High Streer Carlisle, PA (7) Additional information, if any, relevant to the motion: SAlOIS, FLOWER & LINDSAY Dated: + -7 t)C [II AHiU' .(' '..... ".i::] 1'1 L - {::;V soaz ~_'J ::]Hl ::U . SAIDIS, FLOWER & LINDSAY ATlORNEYS.AT'lAW 26 West High Street Carlisle, PA GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM v. JEFFREY A. BRANDT, Defendant IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the attached Divorce Complaint originally filed in the above captioned case on December 8, 2004, Respectfully submitted, SAIDI~ FLOWE C:? Ln c'") ;- ~},~ ~: 1.1.... (:1 ',"::> ,~._-,. :~ . SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS"AT"LAW 26 w. High Street Carlisle, PA GAIL C. BRANDT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS, CIVIL ACTION - DIVORCE NO. 2004 -(.1(,,( CIVIL TERM JEFFREY A. BRANDT IN DIVORCE Defendant NOTICE 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 the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 DQ Ntlt 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. l';' CUMBERLAND COUNTY BAR ASSOCIATION 32 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 (.) ~ -, J' n , By: Indsay, Esquire ID# 4 3 26 est High Street Carlisle, PA 17013 (717) 243-6222 . SAlOIS SHUFF, FLOWER & LINDSAY AITORNEYS.AT.LAW 26 W. High Street Carlisle, PA GAIL C. BRANDT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V5. CIVIL ACTION - DIVORCE NO, 2004 - (, I (, I CIVIL TERM JEFFREY A. BRANDT IN DIVORCE Defendant COMPLAINT Gail C. Brandt, Plaintiff, by attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is Gail C. Brandt, who currently resides at 116 Flintstone Drive, Newville, Cumberland County, Pennsylvania 17241, where she has resided since September 6, 2004. 2. The Defendant is Jeffrey A. Brandt, who currently resides at 1000 Mountain Road, Newville, Cumberland County, Pennsylvania 17241, where he has resided since February 1988. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 28, 1985 at Newville, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. ~ SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT.LAW 26 W. High Street Carlisle, P A 6. The Plaintiff avers that she/he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: lYj7/~f SAlOIS, SHUFF, FLOWER & LINDSAY, P.C. Altom,ys fo, PI.'o'. . PJ By: M Carol J. Lindsa Esquire ID # 44693! 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle, P A VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. c;oSJC~~-t Gail C. Brandt Date: li~/Lf}~ , SAIDIS, FLOWER & LINDSAY AfJOIlNE\'SoM.LAW 26 \Xlest High Street Carlisle, l'A II CERTIFICATE OF SERVICE On this 7 day of ~. { , 2006, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individuals, via first class mail, postage prepaid, addressed as follows: Ronald E. Johnson, Esquire Andrews & Johnson 78 W. Pomfret Street Carlisle, PA 17013 Carol . Linas ~ Attyld.4469~ 26 West High str t Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff . SAlOIS, FLOWER & LINDSAY .4.TIORNEYS'ANAW 26 West High Street Carlisle, PA II . -.. . GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM JEFFREY A. BRANDT, Defendant IN DIVORCE ORDER APPOINTING MASTER U (1" AND NOW, this ~ day of ~ ' 2006, [. ~ f'hpj ffi 11 ,Esquire, is appointed master with respect to the , following claims: Divorce, equitable distribution, attorney's fees and costs BY~ (C \//(?)j '~.::zrr" \/~1~ J. ' .11 ,..; :::,Hl "j .j GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO.: 04-6161 v. CIVIL ACTION - LAW JEFFREY A. BRANDT, Defendant IN DIVORCE ENTRY OF APPEARANCE Please enter the appearance of the undersigned as counsel for the Defendant, Jeffrey A. Brandt, in the above-captioned matter. Respectfully submitted, ABOM & KUTULAKlS, LLP (~, Kara W. Hagge~ Attorney I.D. 869 36 South Hanover Street Carlisle, P A 17013 Attorney for Defendant Dated: May 16,2006 () s; -oft nlr' '-;7" .. ~~ r-- ~ ;~~~ ~ r--.> = = c:;;r. :Jl: ::l> -< o ." ~:!J m, -om :U. c:J ......, T ~o :r: :n ()- "...(") 6m ~ =< C'\ :x::- :::Jt C5 c..n w SAIDIS, FLOWER & UNDSAY ~ 26 West High Street Carlisle, PA II GAIL C, BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM IN DIVORCE v, JEFFREY A. BRANDT, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the daims set forth in the following pages, you must take prompt action. You are wamed 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 daim or relief requested in these papers by the Plaintiff, You may lose money or property or other rights important to you, induding 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 the Cumberland County Court House, Carlisle, Pennsylvania, 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 Bedford Street Carlisle, PA 17013 (717) 249-3166 By Carol J. Linds 10# 44693 26 West High t Carlisle, PA 17013 (717) 243-6222 SAlOIS, FLOWER. & UNDSAY ~ 26 West High Street Carlisle, PA II GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO, 2004 -6161 CIVIL TERM IN DIVORCE v. JEFFREY A. BRANDT, Defendant SECONDAMENDEDCOMP~NT 1, The Plaintiff is Gail C, Brandt, who currently resides at 116 Flintstone Drive, Newville, Cumberland County, Pennsylvania 17241, where she has resided since September 6, 2004. 2, The Defendant is Jeffrey A. Brandt, who currently resides at 1000 Mountain Road, Newville, Cumberland County, Pennsylvania 17241, where he has resided since February 1988. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4, The Plaintiff and Defendant were married on December 28, 1985 at Newville, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction, COUNT I DIVORCE UNDER 13301 (C) OR (D) OF THE DIVORCE CODE 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (e) and/or (d) of the Divorce Code. SAIDIS, FLOWER & UNDSAY A11umw.~.1A.W 26 West High Street Carlisle. PA \I I 7, Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce, COUNT II DIVORCE PURSUANT TO 13301(A)(6l OF THE DIVORCE CODE The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein, 8. Defendant has inflicted such indignities to Plaintiff, an innocent and injured spouse, as to render her condition intolerable and her life burdensome. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. COUNT III EaUIT ABLE DISTRIBUTION 9. The averments in paragraphs 1 through 8 are incorporated hereto as if fully set forth herein. 10, During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests this Court to equitably divide the marital property, COUNT IV ATTORNEY'S FEES AND COSTS 11, The averments in paragraphs 1 through 10 are incorporated hereto as if fully set forth herein, 12, Plaintiff seeks reasonable attorney's fees incurred as a result of Defendant's vexatious, dilatory and obviate conduct. 13, Plaintiff seeks the sharing of the costs necessary for presentation of the parties' case. SAIDIS, FlDWER &. UNDSAY ~-LAW 26 West High Street Carlisle, PA II WHEREFORE, Plaintiff prays this Honorable Court to assign to Defendant a share of the costs reasonably incurred in preparation of the case and to order Defendant to pay Plaintiff's reasonable attorney's fees, SAlOIS, FLOWER & UNDSAY AlI.~'1wr.lAW 26 West High Street Carlisle, PA II VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S, ~ 4904, relating to unswom falsification to authorities, &iJl G ThCLcdt ~!!fOb Gail C. Brandt Dated: g.3}-- () (, S~~ 0\- ~ c':;"'" ~;;:;> 0" (/') r-ri "";) \ CJ) o -n ~--n (11 f.;i -C't;C', ~.r! '-r' ';)2\< ',e) C"" "', ,n ~,-_'1 .. A :P.::O. ::..::. -0 ~,.. .,..:1;'" - 0"\ fV GAIL C BRANDT, Plaintiff IN 1HE CDURT OF CDMMONPLEAS CUMBERLAND CDUNIY, PENNSYLVANIA DOCK.ETNO,: 04-6161 v, QVILACTION-LAW JEFFREY A BRANDT, Defendant IN DIVORCE AFFIDAVIT OF CDNSENf 1. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on December 8, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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. CS. $4904 relating to unsworn falsification to authorities. q I~ O~ ~c n"C~~ Date: GAILCBRANDT ; --;, '" ;": --; GAIL C BRANDT, Plaintiff IN TIffi mURT OF mMMON PLEAS CUMBERLAND mUNIY, PENNSYLVANIA DCXXET NO,: 04-6161 v. OVIL ACTION - LAW JEFFREY A BRANDT, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENfRY OF A DIVORCE DECREE UNDER $3301(c) OF TIffi DIVORCE mDE 1. I consent to the entry of a final decree of divorce without notice. 2, 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. 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. 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. CS. $4904 relating to unsworn falsification to authorities. Date: C\ \ \'''1 \ W Cn.~ L '-n~,-dJ- GAILCBRANDT {.;;'-', ,~~'"" __f ...,.... c,~': GAIL C BRANDT, Plaintiff IN TIiE CDURT OF CDMMON PLEAS CUMBERLAND CDUNfY, PENNSYLVANIA DOCKET NO,: 04-6161 v, QVIL ACTION - LAW JEFFREY A BRANDT, Defendant IN DIVORCE AFFIDAVIT OF CDNSENT 2. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on December 8, 2004, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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. CS. ~4904 relating to unsworn falsification to authorities, Date: fj-/j/- 06 J~dnT~ C. ..._~ "",) ..-{ Plaintiff IN TIlE CDURT OF CDMMON PLEAS CUMBERLAND CDUNfY, PENNSYLVANIA DOCKET NO.: 04-6161 GAIL C BRANDT, v. eVIL ACTION - LAW JEFFREY A BRANDT, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF TIlE DIVORCE CDDE 1. I consent to the entry of a final decree of divorce without notice, 2. 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. 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. 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. CS. ~4904 relating to unsworn falsification to authorities, Date: '1 -//-0 (, ~/ -ri~ ~ A BRANDT !\ '" , .-' -~-~ ,.; , -"".... .' GAIL C. BRANDT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04 - 6161 CIVIL JEFFREY A. BRANDT, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 160- day of ~, / entered into an agreement 2006, the parties and counsel having and stipulation resolving the economic issues on September 14, 2006, the date set for a Master's hearing, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, cQ7J~~ Edgar B. Bayley, P.J. cc: ~Ol J. Lindsay Attorney for Plaintiff ~ ,) : "--::') SAlOIS, FLOWER & LINDSAY MIOJlNEYS.Af'IAW 26 West High Street Carlisle, PA II GAIL C. BRANDT, Plaintiff v. JEFFREY A. BRANDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM IN DIVORCE AFFIDAVIT I, Robert W. Lindsay, Constable, an adult individualllot a party to the above-referenced action, being duly sworn according to law, hereby deposes and says that on ~Ll~ , 2006 at ~_/PM, I served a Praecipe to Reinstate Complaint and Amended Complaint upon Defendant, Jeffrey A. Brandt, by hand delivering the document to him at i 0()() mm U'')tllI ()'~o. d I Uwlf; He I~n'')j (y(L;t I C. Pennsylvania. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: '-/-tq-Ol. Notarial Seal Usa A. O'Brien, Notary Public South Mk;kjleton Twp., Cumberland ColJlty My Commission Expires Sept. 24, 2006 Mc~f;;2';, '''f!nnsyJvania Association Of Notaries Q ~-::, --0 C"\', r\\ {,}.' ~::r> if) ~~;. ;;..e.,.. r::: '-' L. ~. :z"~.) y~; -;-~ ./.... ~ Q, ~ ~~ ~ ~Q "" 0/'4, t'> ;: -:Q .-0 ~~ '::J' g ~ ~ - ~ II .. ... GAIL C. BRANDT, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004 -6161 CIVIL TERM IN DIVORCE JEFFREY A. BRANDT, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2, Date and manner of service of the Complaint: Defendant was served by constable on April 13, 2006, An Affidavit signed by Robert W. Lindsay, Constable, is being filed with the Court contemporaneously herewith, 3, Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: September 14, 2006 and filed with the Prothonotary on September 15, 2006, By Defendant: September 14, 2006 and filed with the Prothonotary on September 15, 2006, 4. Related claims pending: None, 5, Date Waiver of Notice under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: September 14, 2006 and filed with the Prothonotary on September 15, 2006, By Defendant: September 14, 2006 and filed with the Prothonotary on September 15, 2006, SAlOIS, FlOWER & LINDSAY MTORNEYS'XfoIAW 26 West High Street Carlisle, PA ~ " SAllIS, FLOWER & LINDSAY MIORNEYS.X!'.IAW 26 West High Street Carlisle, PA II CERTIFICATE OF SERVICE I, Carol J, Lindsay, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Kara Haggerty, Esquire Abom & Kutulakis 36 South Hanover Street Carlisle, PA 17013 SAlOIS, FLOWER & ~INDSA Y Carol J. Lindsay, Supreme Court I 26 West High Street Carlisle, PA 17013 717-243-6222 Dated: q. 'J~. D u o c: ..".. ...." lll'r n-:'r-" ~L~- r.../j I r: ~::;.-. -:;;"':--. ~~c: z -~ -< ro-.3 c::;) = CT' (/'J fT1 -0 N N ~ -t :r:, :n nfi1 -o~ -u b ..::.t , ';:r: :n '~)o 'Zm ~ ~ -0 -".. ..... N ,. (.;'1 THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT :ti :ti Y'Ni~EEN ENTERED; :ti :ti :ti :ti :-Ii :ti :ti :ti '+' :ti '+' :ti 'I' '+' :ti 'I' 'I' :ti 'I' :ti :ti 'I' Ct' '" '" '" '+' :ii OJ; Ct'~:ii !l;'+' if.if. :ti if. if. if. if. if.if. if. if. if. if. :ii if. if. if. if. if. !l; !l;if.if. if. if.if.:tiif. if.if. if. if.if. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. GAIL C, BRANDT No. 04-6161 VERSUS JEFFREY A. BRANDT AND DECREE IN DIVORCE NOW'~~ tr.'t ~, IT IS ORDERED AND GAIL C, BRANDT DECREED THAT , PLAINTIFF, AND JEFFREY A. BRANDT , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. BY OJ; if. '" J. if. if. '" if. if. OJ; if. if. 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