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HomeMy WebLinkAbout05-4693 SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, PA II SHAWNA S. BRENT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - DIVORCE NO. 2005 - ..y~9J CIVIL TERM GEOFFREY J. BRENT, 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, PENNSYLVANIA 17013 (717) 249-3166 By: Carol J. Linds 10# 4469 . 26 West 'gh Street Carlisle, PA 17013 (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY A1TORNEVSeATeUW 26 W. High Street Carlisle, PA II SHAWNA S. BRENT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - DIVORCE NO. 2005 - /-f/.,cp, CIVIL TERM GEOFFREY J. BRENT, Defendant IN DIVORCE COMPLAINT SHAWNA S. BRENT, Plaintiff, by her attorneys, SAlOIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is SHAWNA S. BRENT, who currently resides at 5 White Oak Circle, Lemoyne, Cumberland County, Pennsylvania 17043, where she has resided since 2002. 2. The Defendant is GEOFFREY J. BRENT, who currently resides at 845 Mandy Lane, Camp Hill, Cumberland County, Pennsylvania 17011, where he has resided since August 21, 2005. 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 June 11, 1993, at Camp Hill, 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 ATTORNEYS-AT-LAW 26 W. High Street Carlisle. P A II 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 (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, SHAWNA S. BRENT, Plaintiff requests the Court to enter a decree of divorce. SAlOIS, SHUFF, FLOWER & LINDSAY. P.C. Attorneys for Plaintiff Date: ~{7f- =31211/'5 By: Caro J. Li 10 # 446 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAlOIS SHUFF, FLOWER & LINDSAY AlTORNEVS.AT_LAW 26 W. High Street Carlisle. P A /I SHAWNA S. BRENT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - DIVORCE NO. 2005 - CIVIL TERM GEOFFREY J. BRENT, Defendant IN DIVORCE 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. ~ 4904, relating to unsworn falsification to authorities. Date: Qll105 ~,~~ ~Q --- 1l ~ ~ ~ ~ "0 '-.:) ~ - -.(:) () C5 ~ ~ ~~ (') ..-.... ,.~<: !'-) r"::::' ~\:I 'l.~"l .-{ -1- ~:, '~((:;; "'~ ( ~) ~- ---', 'n '-< c..c SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle. PA SHAWNA S. BRENT, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. CIVIL ACTION - DIVORCE NO. 2005 - 4693 - CIVIL TERM GEOFFREY J. BRENT, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, GEOFFREY J. BRENT, Defendant in the above captioned matter, accept service of the COMPLAINT IN DIVORCE and certify that I am authorized to do so. Dated: <tlnlo5 By: SEP 2 1 2003 o c ....... C::::l C' c.n o c~ -, \ 0J o "T1 ...... :Cll rn# '-0[[: ;!'}\'2'~; ,_""'f, :~;.~~;i;~ ~~ -ry. "0 '-< -0 ....',.,. .r::- c..n SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEVS-AT.L\W 26 W. High Street Carlisle, P A SHAWNA S. BRENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2005 - 4693 - CIVIL TERM GEOFFREY J. BRENT, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on September 8, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the Date 11\\,\\(> 1? penalties of 18 Pa.C.S. 4904 relating to unsworn falsification PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 Ic) OF THE DIVORCE CODE 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn fa ification to uthorities. Date 12\\,-\\06 Shawna S. Brent .,.S I '- SAIDlS SHUFF, FLOWER & LINDSAY AlTORNEYS.AT-LAW 26 W. High Street Carlisle, P A SHAWNA S. BRENT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2005-4693 - CIVIL TERM GEOFFREY J. BRENT, Defendant IN DIVORCE 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 accepted service of the Complaint on September 17, 2005. An Acceptance of Service was filed with the Court on October 3, 2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: December 20, 2005 and filed with Prothonotary on December 21, 2005; By Defendant: December 18, 2005 and filed with Prothonotary on December 20, 2005. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated December 11, 2005 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 330'1 (c) of the Divorce Code was filed with the Prothonotary: By Plaintiff: December 21 , 2005 By Defendant: December 18, 2005 SAIDIS, SHUFF, ROWER & LINDSAY o c ~~?. c~ <,:..;"1 c::J tY; ,-0 r,i N -------- n ':;'h _4 -:r:-n i-nS; ,- -0 "'1:.- ...-:-"" Cf? C) u:> -- SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle. PA II i SHAWNA S. BRENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2005 - 4693 - CIVIL TERM v. GEOFFREY J. BRENT, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under \) 3301(c) of the Divorce Code was filed on September 8, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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 I,ll rlu':; C\. Geofjr'ey J. DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST RY OF A DIVORCE DECREE UNDERl\ 3301 leI OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I rnay 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 to the best of my knowledge. information and belief. 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: 1 <--ItS/C)' Of-\. t 0 ~ -,-". <\~', \ ' (") <;; ~ ~ o ,-r\ '" N o -rl ~ ...." ~ ~"'" f\1.-r: -Om ;'~"C( .:::\q. ~--D \,)C) ;?,"\. ,-~ ':::J. -~ '-::? N cP - .......-- 71 72435510 PAGE 02/02 12/20/2005 12:57 SAlOIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street C,1,rUsle. PA SAIDIS SHUFF FLOWER SHAWNA S. BRENT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2005 - 4693 - CIVIL TERM v. GEOFFREY J. BRENT, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on September 8, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understa 1d that false statements herein are made subject to the Date 12/20105 , penalties of 18 PaC.S. 4904 relating to unsworn falsification PLAINTIFf'S WAIVER OF NOTICE OF ItlTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERtl 3301 Ie) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose riohts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before :l divorce is granted 3 I understand that I will not be :Jivorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to m, immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge. information and belief. I understand that false statements herein are made SUbject to the penalties of 18 Pa.C,S. 4904 relating to unSWOI11 falsifi ation to authori 'es, Date I J./ J 0/ ()!j DECJlmJ Cl C -;OJ/.' ~ c."? d' Cl en c'l \'-' - \"" -v :;; q, .--' ~:!J. " r: -.0 \!") ~.;:) T ""0 :.?:t\ ?~~ '() -;,:;:,.-n C) .-.-\ "E' ~ '-P. ~ \D .'ta SHAWNA S. BRENT, IN THE COURT OF COMMON PLE' ~ - Plaintiff :CUMBERLAND COUNTY, PENNS~`ANFA~ .. - . r- _._.t ,.~ .., v. DOCKET NO. 2005-4693 ~;} ~=, ~' . -, _ -_ GEOFFREY J. BRENT, :CIVIL ACTION -LAW 'Y '~ r. ~'' ~: ,. Defendant IN DIVORCE STIPULATION FOR TERMINATION OF ALIMONY s~ ®ye yhbe/ AND NOW, this ~ day of {y , 2012, Shawna S. Brent, Plaintiff, (hereinafter referred to as "Wife"), and Geoffrey J. Brent, Defendant, (hereinafter referred to as "Husband"), hereby stipulate that Husband's alimony obligation be terminated. In support thereof, the parties aver as follows: 1. Wife filed a Complaint Under Section 3301(c) or 3301(d) of the Divorce Code on September 8, 2005. 2. On December 20, 2005, Wife executed an Affidavit of Consent. Said Affidavit was filed on December 21, 2005. 3. On December 18, 2012, Husband executed an Affidavit of Consent. Said Affidavit was filed on December 21, 2005. 4. Wife's Waiver of Notice was filed on December 21, 2005. 5. Husband's Waiver of Notice was filed on December 18, 2005. 6. On December 11, 2005, the parties signed a Property Settlement and Separation Agreement, hereinafter referred to as "Agreement." The terms of the Agreement were incorporated, but not merged, into the Decree in Divorce. 7. Pursuant to Paragraph 10 of the Agreement, "Husband shall pay to Wife alimony in the amount of One Dollar ($1.00) per year..." 8. Pursuant to Paragraph 10(b) of the Agreement, alimony shall terminate upon Wife's cohabitation with a member of the opposite sex within the degrees of consanguinity. 9. Pursuant to Paragraph 10(d), alimony shall terminate on December 31, 2011. 10. Wife has been cohabitatiog with her paramour, a member of the opposite sex, for over a year. 11. As a result, under both Paragraphs 10(b) and 10(d), Husband's alimony obligation should be terminated. 12. Husband consents to the termination of his alimony obligation. 13. Wife consents to the termination of Husband's limony obligation. Witness Witne s SHAWNA S. BRENT, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA • ~: ~~ . v. :DOCKET NO. 2005-4693 -v=~ ~ ~~-~ : ~~ © fT7.._.: GEOFFREY J. BRENT, :CIVIL ACTION -LAW ~~ ~ Defendant IN DIVORCE r ~ ° ° ~~ ~`'~' ~c a~ ~ _c ~~ ~ =- ~~ ORDER ,~.. ;`~` AND NOW, this ~l/~ day of ~~ce-~~.,c~ , 2012, upon consideration of the attached Stipulation for Termination of Alimony executed by the parties, it is hereby ORDERED and DECREED that Defendant's obligation to pay alimony is terminated with prejudice. BY THE COURT: 1. Distribution: ~ iv1aria P. Cognetti, Ls:Iuire, '~1~.~aria P. Ccgnetti &; Associates, 210 CTranclview Avenue, Suite 102, Camp Hill, PA 17011 " Shawna S. Brent, 5023 Inverness Drive, Mechanicsburg, PA 17050 l.. ~{ £S /rL`ei ~ /~l~v~/ ~ ~~