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Home My WebLink About05-1049 REBECCA J. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ~ NO. Oj~./ /0 4 q : IN DIVORCE CIVIL TERM DENNIS 1. BRECHBILL, 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 will proceed without you and a decree of divorce or annulment may be entered against you for any clairn 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 rnarriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRlNG A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 REBECCA J. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW DENNIS 1. BRECHBILL, Defendant : NO. : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Rebecca J. Brechbill, an adult individual currently residing at 50 Pineknob Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Dennis 1. Brechbill, an adult individual currently residing at 8698 Pineville Road, Shippensburg, Franklin County, Pennsylvania. 3. Plaintiff is a bonafide resident ofthe 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 December 9, 2000, m Shippensburg, Franklin County, Pennsylvania. 5. There has been no other prior action for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Anned 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 (c) of the Domestic Relations Code. Respectfully submitted, ~\U\ i'd' h '\\- blL1i\f\ 1\ - J ,i\^ r\ 1\ Hannah Herman-Snyder, Esquir Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 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. DATE:~ REBECCA J. BRECHBILL, Plaintiff .' , "1 "',J '...... '.',," .' ,'-to, .,1 ,~.\:. \ .;;. .. ~ t,. ," , ~~ ~ 2 4:', "t}O] 0)~,\.\ -:>:';; en -.:;:... r> ',l'~,('j J{-:() "pC '.7 ;~ ..,' A~ ~ -. ~ - -. () ~ l.A r V '" ,...> l'" r LA ~ ....' ~ <-" -;:s:. <;", \ ~ ~ ';:It q, .-' -t'..-<'l "'V.' ~\?h...('. ~" -:.t,":~l; ".-" S;~-() . _;(,,)'i"(\ C'.;: ~,:,,"" <f\:~~1 <P . REBECCA J. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLE S OF : CUMBERLAND COUNTY, PENNS LVANIA vs. : CIVIL ACTION - LAW DENNIS L. BRECHBILL, Defendant : NO. 05-1049 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this :J \" day of March, 2005, comes Hannah Herman-Sny r, Esquire, counsel of record for Plaintiff, Rebecca 1. Brechbill, and states that a true and atte ted copy a Complaint in Divorce and Notice to Defend and Claim Rights, was sent to Defendan Dennis 1. Brechbill, at 8698 Pineville Road, Shippensburg, PA 17257, by certified rnai restricted delivery, return receipt requested. Service of said Complaint in Divorce was made 0 March 12, 2005. " Hannah Herman-Snyder, Esquir Attorney for Petitioners GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this. :)/;..r day of Iff aA eJ- , 2005 ( 2b<<-~lidn~ NOTARYP~ Lrc NOTARIAL sm ROBIU GOSHORN, NOTARY PUBLIC CARLISLE BORO., CUMBERLAND COUN1Y MY COMMISSION EXPIRES APRIL 11 2007 . 'p SENDER' COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse sn thBt we...can return the card to you. . Attach this card to the back of the maHpiec8, or on the front If space permits. ~;:::ra;el:. ~~ \ \ ~\s.q~ ~,^\\L ~ 't). . fV ..&V'-'...J'r- i \?~ ~t.-::> ( COMPLETE THIS SECT/ON ON DELIVERY o o 3. Service Type ~Certlfjed Man o Registered o Insured Ma" 0 C.O.O. 4. RestrIcted Delivery? (Extra Fee) 2. Article Number (Transfer from service labeQ PS Form .3811, AuguSl2001 '. "Domestic Return Receipt ..I,[,.J_ J~I!!:~ 7001 2510 0009 1018 9905 102595- -M-1540 U.S. Postal Service CERTIFIED MAIL RECEIPT !Domestic Mail Onlv: No In<:.urance Cover,lp-:; P,vvirled1 - --------- ----"_._- ",Coo 2.,00 )0 ;5 3'SV CJ Total Post;lge & Fees $ q ....l ~ rl ;:;-; .Sr'\'.. -::L\ - L Brec.H5\ L\m rl .~,~f:'1umm I n~,^\\JLur,<trm ~ C"'YN ZIP)~ uu ~uuRummUUUU)~iSi Ul CI IT' IT' Postage $ "" rl\ CJ Certified Fee rl Return Rec'3ipt Fee cr- : (EndorsementH3quired) CJ Restricted Delivery Fee CJ (Endorsement Required) c:J I'o"m"k r HerEft 1 ,> \ , '\. I " \ ".-',) , ,,/ '-'".___'--c- >- ..:J' (; a; ~. n -, I-c u./';:) . ~ ~'rfi ~- a.. ('.5e, C') ) c' C'... .1 'ri]o--. d1lJ :2 '-'-is .,- ,.0 .' u- (...-:-:l ::J 0 = u c-. ( REBECCA J. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW DENNIS 1. BRECHBILL, Defendant : NO. 05-1049 : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on March 2,2005, and service was made on March 12,2005. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pac.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 21 --fK' ~.i-:,\-.. " <;:. ~ "'-' ""'~ ,(or, ~>,(< ':~~;C;~ '::-~ ~ <-~ c: r" -- v:> Q, :::;l;-f\ 't\""\'-;" y-r-. "'0-'---'- ~'-"'l\./ <S{~> ,-'\--\" .:~~~;~~- :.;;:\ :a: -0 -:1:'. -- s:- -- REBECCA J. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW DENNIS 1. BRECHBILL, Defendant : NO. 05-1049 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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 . I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. DATE: 1-91:05 ~~ REBECCA J. BRI;CHBILL, Plaintiff ,..., c~ "'" <->' 'c:: r - w -tl Q. -' ...,...~ f(lf;: -'CftQ /~~S~_ '~?("'). Cs.,'" -",.' -' - D) :.:. .... N REBECCA 1. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW DENNIS L. BRECHBILL, Defendant : NO. 05-1049 : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301 (c) of the Divorce Code was filed on March 2,2005, and service was made on March 12,2005. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF IS Pa.C.S. S4904 RELATING TO UNSWORN F LSIFICA TION TO AUTHORITIES. ~I$v- DENNIS L. BRECHBILL, Defendant DATE: r o C ..::~,. g)\~: -;/ ~;) I,.;, %,'~ ~.-; .-~ ~ ~ (/) CB N N -0 ~:(, - ~ :?""71 rn f': -;::lEi :,bC:-; (.)2") :;;:.;:\-"'i;i ?'5~lJ ,.,~o ;(;:::,f\"'\ :::t "t:'" ~ L_' o REBECCA J. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DENNIS 1. BRECHBILL, Defendant : NO. 05-1049 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN F ALSIFICA nON TO AUTHORI NNIS 1. BRECHBILL, Defendant ~2,~~? ~ :;;s, 1.,_ 't~" >'-;'(. ~;~ \;- o f;'; r-> <"" ~ if) ~'''f1 '-0 N N --; ......... """'C' :"..iC Q, -l ::t::-n rnfD :gt? be':'). _.~, '4;., ''';:--';'i (::Jc-i :;::ro("'-. ';? :e: ~ - .' 0'J - REBECCA 1. BRECHBILL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW DENNIS 1. BRECHBILL, Defendant : NO. 05-1049 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under ~3301(c) 33lll(a)(I) efthe Di":ereB Cede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: certified mail, restricted delivery on March 12,2005. 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: July 1,2005 by Defendant: September 7, 2004 (b) (I) 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: (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: July 13,2005 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: September 22, 2005 I\\n""n"_~,\i\I\\l\I"\~ ~cI\l~lJ\ Hannah Herman-Snyder, Es ire GRIFFIE & ASSOCIATES Attorney for Plaintiff ......,) ~~.:~ {".;'l ~~ '.J ,1 (~; '. c.) C' ~...... \..f.') ;+,;+,;+,;+, + + + . . . . + + + + + . + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + ++ + + + ++++ ++++++++ + + + + + + + + + + + ++++++ + ++ ++:+'+++Of+++ +:+::+.Of++Of+++++:+:+:+.+OfOf+ IN THE COURT OF COMMON STATE OF REBECCA J. BRECHBILL , VERSUS DENNIS L. BRECHBILL, <+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + ++ Of +:+: AND NOW, DECREED THAT + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +:+::+:++++++:f+:f+++++++++++++? PLEAS OF CUMBERLAND COUNTY PENNA. No. 05-1049 Plaintiff Defendant DECREE IN DIVORCE October ~b , -2005_, IT IS ORDERED AND Rebecca J. Brechbill , PLAINTIFF, AND Dennis L. Brechbill , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None + + ++++++++ :+:+++++++++ Am"a ~ ~ . ___ -lPROTHONOTARY ++ + ++++ C+;;t'+:+'++:+' + +;t' Of J~ _ h 7- Ytf'rl "Yih -'" ( j / ~,,_ ~ 71" ~ "fT"'" jf:,jp" - r"'? 7" Lcd - _._--~_.."----