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Home My WebLink About05-6339 DOUGLAS W, BROWN, Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * NO. 05 - 1&,33<[ * Cw'[L~~ VS, * ALEXIS A, BROWN, Defendant * CIVIL ACTION - 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 MAYBE 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 A V AILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, I COURTHOUSE SQUARE, CARLISLE, PA 17013. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 DOUGLAS W. BROWN, Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYL VANIA * vs, * ALEXIS A, BROWN, Defendant * CIVIL ACTION - LAW * IN DIVORCE C;Q~L y~ * NO, D!:; - ~33? * COMPLAINT COUNT I - DIVORCE UNDER &3301(c) or &3301(d) OF THE DIVORCE CODE I. Plaintiff is Douglas W. Brown, who currently resides at 843 Moores Mountain Road, Lewisberry, York County, Pennsylvania, 17339. 2. Defendant is Alexis A. Brown, who currently resides at 843 Moores Mountain Road. Lewisberry, York County, Pennsylvania, 17339. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 19, 1976 in Camp Hill, Pennsylvania. 5. The parties are the parents of one minor child: Danielle Nicolle Brown, born on May 6, 1988. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. Plaintiff has been advised that counseling is available and that he may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued. 10. The cause of action and sections of the Divorce Code under which Plaintiffis proceeding are: (a) 9330I(c). The marriage of the parties is irretrievably broken; and (b) 9330 I (d). The marriage of the parties is irretrievably broken and, at the appropriate time. Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. 11. Plaintiff respectfully requests This Honorable Court enter a Decree of Divorce. WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the marriage between Plaintiff and Defendant. Dated: 1?-8-~ Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, p,c. ~~~uire 130 West Church Street Dillsburg, P A 17019 (717) 432-9666 J.D. # 77944 VERIFICATION I, Douglas W. Brown, verifY that the statements made in tms Complaint lire true and correct to the best of my knowledge, infonnation, and belief. I understand that false statements herein are made su~ject to the penalties of 18 Pa. CS. ~4904, relating to unsworn falsification to authorities. DlIte: I) In sl (75 . /,' IJ" / /- d f'i'CJ((oC' '-(/,/ If. -;/''--( J v DOUGL S W. BROWN Plaintiff (.) -{Q. '-: ~ ~ \ - ~~." ." ...0 -.., -.--\ ~ ,-,.., , ' 111 -- ~ f'....) - C> ...::t V'l - f2 -' - ~ ; " Cog < e" E ~. \ ; ~ DOUGLAS W. BROWN, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-6339 CIVIL TERM ALEXIS A. BROWN, Defendant. CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of Plaintiffs Complaint in Divorce in the above-captioned matter, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure. Date: 'bbb ~)JJ~W\ Alexis A. Brown 843 Moores Mountain Road Lewisberry, P A 17339 s:~\ c_ -- c:, -' .' - ,..~ \,.....:.1 , DOUGLAS W. BROWN, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-6339 CIVIL TERM ALEXIS A. BROWN, Defendant. CIVIL ACTION - DIVORCE STIPULATION TO TRANSFER PROCEEDING WHEREAS, Plaintiff initiated the above captioned Divorce action in the Cumberland County Court of Common Pleas on December 12, 2005. WHEREAS, Defendant Accepted Service of the Complaint on January 3, 2006. WHEREAS, said Acceptance of Service was filed with the Court in Cumberland County on January 13, 2006. WHEREAS, the parties now agree to have this matter heard before the Court in York County Pennsylvania: NOW, THEREFORE, the parties to the above captioned matter, by and through their attorneys, do stipulate and agree as follows: 1. This matter shall be transferred by the Prothonotary of the Cumberland County Court of Common Pleas to the Prothonotary of the York County Court of Common Pleas. 2. That the filing fee for said transfer shall b,e paid~bY the Plaintiff. Date: :l- rlj - cr:- (.,{{ L .1 Timothy J, I &quire Counsel for Plaintilf Date: 01/ Ole /, s: \Clients\COLGANlBROWl\l. DOllG\Transfer Stipuimion. wpd t'" " J ...; , ,,\ riECEIVED M~.~ 0; o--r, 11''' DOUGLAS W. BROWN, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-6339 CIVIL TERM ALEXIS A. BROWN, Defendant. CIVIL ACTION - DIVORCE ORDER OF COURT ,.. ....v- , 2006, upon consideration AND NOW, this L day of ofthe Stipulation of the Parties to Transfer Proceeding, the Court ORDERS and DIRECTS the Cumberland County Prothonotary to transfer this divorce action to the Prothonotary of York County. BY THE COURT: Distribution: ~ ;4 IL ( J. Timothy J. Colgan, Esquire, 130 West Church Street, Suite 100, Dillsburg, PA 17019\ Charles Rector, Esquire, 1104 Femwood Avenue, Camp Hill, PA 17011 I :; l-OG, d' 'c:t:::Vk tL jJ.i~ "