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Home My WebLink About06-6192 TANYA BRANDT, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. CIVLL ` GEORGE W. BRANDT, CIVIL ACTION - AT LAW Defendant IN DIVORCE NOTICE TO DEFEND 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 0. TANYA BRANDT, Plaintiff VS. GEORGE W. BRANDT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. O` - L19Z Ci"iL"_T,. CIVIL ACTION - AT LAW IN DIVORCE DIVORCE COMPLAINT The Plaintiff, Tanya Brandt, by and through her attorneys, the Law Offices of Patrick F. Lauer, Jr., LLC makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE §§3301(c) or 3301(d) 1. The Plaintiff, Tanya Brandt, is an adult individual who currently resides at 3945 Enola Road, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant, George W. Brandt, is an adult individual who currently resides at 3945 Enola Road, Newville, Cumberland County, Pennsylvania 17241. 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 Plaintiff and Defendant were married on March 11, 1995 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. There are three minor children to this marriage, namely Chelsea Brandt, born March 24, 1997, Connor Brandt, born July 13, 2002, and Chase Brandt, born September 24, 2003. . 8. The Plaintiff is not a current or former member of the United States military. 9. The Plaintiff and has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 10. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. COUNT II - EQUITABLE DISTRIBUTION 11. Paragraphs one (1) through ten (10) of this Complaint are incorporated herein by reference as if set forth specifically below. 12. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, the Plaintiff respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to § 3502(a) of the Divorce Code. COUNT III - CUSTODYNISITATION - § 5303 13. Paragraphs one (1) through twelve (12) of this Complaint are incorporated herein by reference as if set forth specifically below. 14. Plaintiff seeks custody of the following children: Flame. Present Address - Age.: Chelsea Brandt 3945 Enola Road 9 years Newville, PA d.o.b. 03/24/1997 Connor Brandt 3945 Enola Road 4 years Newville, PA d.o.b. 07/13/2002 Chase Brandt 3945 Enola Road 3 years Newville, PA d.o.b. 09/24/2003 15. The children were not born out of wedlock. 16. The children are presently in the custody of Plaintiff/Mother and Defendant/Father, 3945 Enola Road, Newville, Cumberland County, Pennsylvania, 17241. 17. During the past five years, the children have resided with the following persons and at the following addresses: Mother & Father 3945 Enola Road, New Cumberland 18. The Mother of the children is Tanya Brandt, who resides at 3945 Enola Road, Newville, Cumberland County, Pennsylvania 17241. 19. She is married to the Defendant, George W. Brandt. 20. The Father of the children is George W. Brandt, who resides at 3945 Enola Road, Newville, Cumberland County, Pennsylvania 17241. 21. He is married to the Plaintiff, Tanya Brandt. 22. The relationship of the Plaintiff to the children is that of natural mother. She currently resides with the Defendant and subject children. 23. The relationship of the Defendant to the children is that of natural father. He currently resides with the Plaintiff and subject children. 24. Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the children in this or another court. 25. Plaintiff does not know of a person not a parry to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 26. The best interests and permanent welfare of the children will be served by granting the relief requested because: (a) The Plaintiff is desirous of continuing the close, loving relationship she has with the children; (b) The Plaintiff is economically able to care for the children; (c ) The Plaintiff has been the caretaker of the children since birth. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order granting her primary physical custody of the children. Respectfully submitted, f Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 Date: October 19, 2006 ID# 84745 Tel. (717) 763-1800 .. TANYA BRANDT, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. GEORGE W. BRANDT, 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 falsification to authorities. Signatur . l T A BRANDT Date: 161 15b A Y N `o oc I n( rO I.7 1 f •. yh. ? a? .? Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor z?CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573