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Home My WebLink About06-4835Nichole M. Staley O'Gorman, Esquire ID 78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaleyna,_pkh.com SHANNON M. SMITH-BRIGAMAN, Plaintiff vs. MATTHEW B. BRIGAMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,, PENNSYLVANIA NO. OL. 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 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, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 (717) 249-3166 Nichole M. Staley O'Gorman, Esquire ID 78966 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaleyCc okh.com SHANNON M. SMITH-BRIGAMAN, Plaintiff vs. MATTHEW B. BRIGAMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0(.a - // ?3S C7jC.> CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER §3301(, OR (d) OF THE DIVORCE CODE AND NOW COMES Plaintiff, Shannon M. Smith-Brigaman, by her attorneys, Purcell, Krug & Haller, and files the following Divorce Complaint: 1. Plaintiff is Shannon M. Smith-Brigaman, an adult individual who currently resides at 16 Tory Circle, Enola, Cumberland County, Pennsylvania. 2. Defendant is Matthew B. Brigaman, an adult individual who currently resides at 504 4"h Street Rear, New Cumberland, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The plaintiff and defendant were married on November 6, 1993 in Chambersburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree of divorce pursuant to §3301(c) or (d) of the Divorce Code. Date: h U(o By Nic o e M. Stal O'Goi ID 79866 1719 North Front Street Harrisburg, PA 17102 (717)234-4178 Attorney for Plaintiff 2 PURCELL, KRUG & HALLER n Q VERIFICATION I,? c?• Plaintiff in the within action, hereby verify that the facts contained in the foregoing & M PLIRA(T are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. DATE: a4 V*t I om Sy?.Y?-?. ?QQ ? r r Nichole M. Staley O'Gorman, Esquire ID No. 79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley(a)-pkh.com SHANNON M. SMITH-BRIGAMAN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA `!85 NO. 06-4--'*& MATTHEW B. BRIGAMAN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Nichole M. Staley O'Gorman, Esquire, Attorney for the Plaintiff, Shannon M. Smith- Brigaman, in the above action, hereby swear and affirm that on the 21s' day of August, 2006, I sent, by certified mail, return receipt requested, restricted delivery, a Complaint for Divorce to the Defendant, Matthew B. Brigaman. ,, The Return Receipt Card signed by the Exhibit "A". tC?l-IOLE S LE F NO. 7986 6 TTORNEY F R PLAINTIFF Sworn and subscribed to before me this [ `' day of 2006. WEALTH OF PENNSYLVANIA Notary blic Notarialseal Angela S. Shaffer, Notary Public City Of Harrisburg, Dauphin County My Commission Expires Jan. 12, 2008 Member, Pennsylvania Association Of Notaries ched hereto as 2. Article Number 7160 YM1 %46 3107 0146 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) L ]Yes 1. Article Addressed to: Matthew B. Brigaman 504 4th St. (Rear) New Cumberland, PA 17050 A. ceiv by (PI ase ri ? B. Date of Delivery onng C. Signature , E'Agent X - C Addresses D. Is delivery dress ' erent from item 1? C Yes It YES, ante delivery ddress below! ? No Smith-Brigaman v. Brigalnan NMSO PS Form 3811, July 2001 Domestic Return Receipt EXHIBIT "A" SHANNON M. SMITH-BRIGAMAN, Plaintiff vs. MATTHEW B. BRIGAMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-48W Hiss CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 21, 2006. 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. 1 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 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. /2//2/(- '? & Date: SHANNON M. SMIT -BRIGA N, Plaintiff ?. ????' ? ?{ `C7? ? .. r?; ? .G` ? E,,,y -o ?'} w -'? ts? SHANNON M. SMITH-BRIGAMAN, Plaintiff vs. MATTHEW B. BRIGAMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4 ??35 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. §4904 relating to unsworn falsification to authorities. 1-1 Date: ? a ba l 0-4 C'-,,,- SHANNON M. SMITH- IGAMA Plaintiff ...a .? rra .; ? ? ' ? - ' ?"? SHANNON M. SMITH-BRIGAMAN, Plaintiff vs. MATTHEW B. BRIGAMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-4835 : CIVIL ACTION - 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 4-3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint in Divorce was served on Defendant, Matthew B. Brigaman, by certified mail return receipt requested, restricted delivery on August 31, 2006. 3. (Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: By Plaintiff: 12112/2007 and By Defendant: 03106/2008. (b) (1) Date of execution of the Affidavit required by §3301(d) of the Divorce Code: N/A. (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: 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 a Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 12/14/2007; Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 03/' /2008. P. Date: 3/11/2008 By: Nichole M. Stall , Esquire 1/719 N. Front St ee Harrisburg, PA 1 1 Telephone: (717) 2 1-41"718 Attorney ID No. 79866 Attorney for Plaintiff c? cz:) _a C:33 _ r m V ' ' i Fi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF }y PENNA. Shannon M Smith-Brigaman Plaintiff N 0. 2006-4835 VERSUS Matthew B. Brigaman Defendant DECREE IN DIVORCE AND NOW, Maw,' /P~ , 2008 , IT IS ORDERED AND DECREED THAT Shannon R _'-Smith-Brigaman , PLAINTIFF, AND Matthew B. Bripaman 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. BY THE OURTT: d '/t ATTEST. /1 J. PROTHONOTARY ??, ??, ? ??? r?? ? ?? _ ? ?-p ?? ? ,?G ?? . ? moo- ?? - F ., d " ?I ',': ?,