HomeMy WebLinkAbout06-1241
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Constance P. Brunt, Esquire
Supreme Court 10 #29933
Beaufort Professional Center
1820 Llnglestown Road
Harrisburg, PA 11110
(717) 232.7200
cobrunt@cobruntlaw,com
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CONSTANCE A. FORBES,
NO. ~ - J;L,'-IJ
C'{u~l ~8LhJ
v.
DAVID A. FORBES,
Defendant
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 Cumberland County Courthouse, One Courthouse Square,
Carlisle, PA 17013-3387.
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. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
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IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE 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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
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Constance P. Brunt, Esquire
Supreme Court \0 #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
cDbrunt@cpbruntlaw.com
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CONSTANCE A. FORBES,
NO. O~ - /dtf/
Cl-L>~l<-Y-~
v.
DAVID A. FORBES,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes the above-named Plaintiff, CONSTANCE A. FORBES, by and
through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in
Divorce from the above-named Defendant, DAVID A. FORBES, upon the grounds
hereinafter set forth.
1. Plaintiff is CONSTANCE A. FORBES, an adult individual, who currently
resides at 1804 Signal Hill Road, Mechanicsburg, Cumberland County, PA 17050.
2. Defendant is DAVID A. FORBES, an adult individual, who currently resides at
18 Briar Lane, Camp Hill, Cumberland County, PA 17011.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth
of Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
.'
4. The Plaintiff and Defendant were married on April 30, 1994, in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The Plaintiff and Defendant are both citizens of the United States of America.
7. The Defendant is not a member of the Armed Services of the United States or
any of its allies.
8. The Plaintiff has been advised of the availability of marriage counseling and
understands that she may request that the Court require the parties to participate in
counseling.
9. The Plaintiff avers that the grounds on which the action is based are that the
marriage is irretrievably broken.
10. Plaintiff requests the Court to enter a Decree in Divorce.
Respectfully submitted,
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CONSTANCE P. BRUNT, ESQUIRE
Supreme Court ID# 29933
Beaufort Professional Center
1820 linglestown Road
Harrisburg, PA 17110-3339
(717) 232-7200
Attorney for Plaintiff
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VERIFICATION
I verify that the statements made in the foregoing Complaint In Divorce 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 falsification to authorities.
DATED: .1/1 /6re
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CONSTANCE A. FORBES, Plaintiff
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglcstown Road
Harrisburg, PA 17110
(717) 232.7200
cpbrunt@cpbruntlaw.com
CONSTANCE A. FORBES,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 06 -1241 CIVIL TERM
DAVID A. FORBES,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, PAMELA L. PURDY, ESQUIRE, attorney for the Defendant, DAVID A.
FORBES, in the above-captioned divorce action, hereby accept service of the
Complaint in Divorce filed on March 3, 2006, in the Court of Common Pleas of
Cumberland County, Pennsylvania, and certify that I am authorized to do so.
Date: N/CiA Jt '1) -200 s:
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115 Pine Street
Harrisburg, PA 17101
(717) 221-8303
Attorney for Defendant
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
cpbrunt@cpbruntlaw.com
CONSTANCE A. FORBES,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 06 -1241 CIVIL TERM
DAVID A. FORBES,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on March 3, 2006.
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 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.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. S4904 relating to unsworn falsification to authorities.
DATE:
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CONSTANCE A. FORBES, Plaintiff
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Constance P. Brunt, Esquire
Supreme Court]D #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
cpbrunt@cpbruntlaw.com
CONSTANCE A. FORBES,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 06 -1241 CIVIL TERM
DAVID A. FORBES,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301 (C) AND ~3301 (D) OF THE DIVORCE CODE
1. 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 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.
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.
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: t,j,2jO/P
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CONSTANCE A. FORBES, Plaintiff
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Constance P. Brunt, Esquire
Supreme Court In #29933
Buufort Professional Center
1820 Lingle.stown Road
Harrisburg, PA 17110
(71 7) 232-7200
cpbrunt@cpbruntlaw.com
CONSTANCE A. FORBES,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
v.
NO. 06 -1241 CIVIL TERM
DAVID A. FORBES,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on March 3, 2006.
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 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.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. s4904 relating to unsworn falsification to authorities.
DATE: (;/J"lb
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DAVID A. FORBES, Defendant
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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. 94904 relating to unsworn falsification to authorities.
DATE:
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DAVID A. FORBES, Defendant
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Constance P. Brunt, Esquire
Supreme Court [D #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110
(717) 232-7200
cpbrunt@cpbruntlaw.com
CONSTANCE A. FORBES,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
v.
NO. 06 -1241 CIVIL TERM
DAVID A. FORBES,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(CI AND ~3301(DI OF THE DIVORCE CODE
1. 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 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.C.S. 94904 relating to unsworn falsification to authorities.
DATE:
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Constance P. Brunt, Esquire
Supreme Court ID #29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburgl PA 17110
(717) 232-7200
cpbrunt@cpbruntlaw.com
CONSTANCE A. FORBES,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
v.
NO. 06 - 1241 CIVIL TERM
DAVID A. FORBES,
Defendant
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:
1, Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the
Divorce Code.
2. Date and manner of service of the Complaint: By acceptance of service dated
March 9,2006, and filed March 15,2006.
3, Complete either paragraph (a) or (b).
.
(a) Date of execution of the Affidavit of Consent required by Section 3301(c)
of the Divorce Code: By Plaintiff on June 12, 2006; by Defendant on June 15, 2006.
(b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d)
of the Divorce Code: N/A.
(2) Date of filing and service of the Plaintiff's Affidavit upon the Defendant:
N/A.
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: N/A.
(b) Date Plaintiff's Waiver Of Notice was filed with the Prothonotary:
June 26, 2006,
Date Defendant's Waiver Of Notice was filed with the Prothonotary:
June 26, 2006.
Respectfully submitted,
DATE: ~(2.~(t;p
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CONSTANCE P. BRUNT, ESQUIRE
Supreme Court I.D. No. 29933
Beaufort Professional Center
1820 Linglestown Road
Harrisburg, PA 17110-3339
(717) 232-7200
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
.
OF CUMBERLAND COUNTY
STATE OF
CONSTANCE A. FORBES,
.
Plaintiff
VERSUS
DAVID A. FORBES,
.
Defendant
AND NOW,
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PENNA.
.
No. 06-1241 CIVIL TERM
.
DECREE IN
DIVORCE
.
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, 2006 ,IT IS ORDERED AND
.
.
.
DECREED THAT CONSTANCE A. FORBES
, PLAINTIFF,
AND
DAVID A. FORBES
, DEFENDANT,
. ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
. BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
.
NONE
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ATTEST: ~ ~ ~
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PROTHONOTARY
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