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HomeMy WebLinkAbout05-3971VALERIE BROWN, Plaintiff VS. WILLIAM BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. nS- .3471 (f[utCE-0-1?-rl CIVIL ACTION - AT LAW IN 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 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 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 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 800-990-9108 VALERIE BROWN, Plaintiff vs. WILLIAM BROWN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. ng-j4~/f atu'-?c--7 ? CIVIL ACTION - AT LAW IN DIVORCE The Plaintiff, Valerie Brown, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., LLC makes the following Complaint in Divorce: 1. The Plaintiff, Valerie Brown, is an adult individual who currently resides at 10 Catalpa Court, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant, William Brown, is an adult individual who currently resides at 10 Catalpa Court, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The Parties 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 parties were married on August 28, 1983, in East Meadow, New York. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff and has been advised that counseling is available and that either party may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. Date:O7 ??seplp. Caracibi6, Esquire '/d"aw Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID4 90919 Tel. (717) 763-1800 VALERIE BROWN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. WILLIAM BROWN, CIVIL ACTION - AT LAW Defendant : IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Signature: VALERI" ROWN Date: C u, i ?? ti VALERIE BROWN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : NO: 05 - 3971 CIVIL TERM WILLIAM BROWN, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on August 15, 2005, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 falsification to authorities. Date: tb C Val6rie brown, Plaintiff C. ...a a.. -ct?? ? ?: CI') ,? : W < to '"? L? . `_ ?7 M ?w ..? N -?