HomeMy WebLinkAbout06-7209
Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Defendant
CIVIL ACTION - LAW
NO. 06 - 7UJOJ CIVIL TERM
IN DIVORCE
Isaac Brumfield,
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, High and Hanover Streets, Carlisle.
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, P A 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or hearing.
Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Defendant
CIVIL ACTION - LAW
NO. 06 -7.:2dJ CIVIL TERM
IN DIVORCE
Isaac Brumfield,
COMPLAINT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Nicole M. Brumfield, who currently resides at 33 Trine Avenue, Mount Holly
Springs, Cumberland County, Pennsylvania 17065.
2. Defendant is Isaac Brumfield, who currently resides at FCI- Allenwood, P.O. Box 2000,
White Deer, Union County, Pennsylvania 17887.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on July 14, 2000, in Hagerstown, Maryland.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken, and the parties separated on October 13,2004.
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 in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
Respectfully submitted,
ROMINGER & WHARE
Date:
/2/20/b
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Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court J.D. # 81924
Attorney for Plaintiff
,
Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Defendant
CIVIL ACTION - LAW
NO. 06 - CIVIL TERM
IN DIVORCE
Isaac Brumfield,
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 unsworn
falsification to authorities.
Date;J'2. I ~. c::.:l.-p
Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Defendant
CIVIL ACTION - LAW
NO. 06 - CIVIL TERM
IN DIVORCE
Isaac Brumfield,
CERTIFICATE OF SERVICE
I, Karl E. Rominger, Esquire, attorney for Nicole M. Brumfield, do hereby certify that I this
day served a copy of the Divorce Complaint upon the following by depositing same in the United
States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at
Carlisle, Pennsylvania, addressed as follows:
Isaac Brumfield, No. 12738-067
FCI-Allenwood
P.O. Box 2000
White Deer, Pa 17887
Date: ! ?/?c/2
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KarlE. Rominger, Esquire
155 South Hanover Street
Carlisle, Pa 17013
(717) 241-6070
Court Id. No. 81924
Attorney for Plaintiff
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Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Defendant
CIVIL ACTION - LAW
NO. 06-7J-6Q CIVILTERM
IN DIVORCE
Isaac Brumfield,
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow, Nicole M. Brumfield, Plaintiff, to proceed in forma pauperis.
I; Karl E. Rominger, attorney for the party proceeding in forma pauperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the party.
Date: (2(21"~
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Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, Pa 17013
(717) 241'-6070
Attorney Id No. 81924
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Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Isaac Brumfield,
CIVIL ACTION - LAW
NO. 06 - i;)...cf1 CIVIL TERM
IN DIVORCE
Defendant
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-
affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be
admitted.
AFFIDAVIT UNDER
SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on October 13, 2004, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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. S 4904 relating to unsworn
falsification to authorities.
Date: "2. I~. OLP
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Nicole M. Bru d, Plaintiff
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Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Isaac Brumfield,
CIVIL ACTION - LAW
NO. 06 - 7:J.DQ CIVIL TERM
IN DIVORCE
Defendant
DEFENDANT'S COUNTER-AFFIDAVIT UNDER
SECTION 3301 (dl OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because:
Check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart for a
period of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. 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.
(b) I wish to claim economic relief which may include alimony,
division of property, lawyer's fees or expenses or other
important rights.
I verify that the statements made in this counter-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:
Isaac Brumfield, Defendant
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Nicole M. Brumfield,
Plaintiff
v.
Isaac Brumfield,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06 - 7209 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE FOR A
SENDER. COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
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2. Article Number
(Transfer from service label)
PS Form 3811, February 2004
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A Signature
X;t"..R!cz t-L~t
D Agent
D Addressee
B. ~iv,d,bY(.PrinJed Name) C. Date of Delivery
<:> .) he<-.A- 1.2/2//06
D. Is delivery address different from item 1? ~es
If YES, enter delivery address below: " No
3.~~rvice Type
JQl Certified Mall D ~ress Mall
o Registered ~etum Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extm Fee) as
7005 2570 0000 3796 5497
102595-02-M-fs40
~
Domestic Return Receipt
PROOF OF SERVICE FOR B
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
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2. Article Number
(Transfer from service label)
PS Form 3811, February 2004
x
B. Recei~d by j.Ertflted. d pI~me)
L. /- / C ~ J
D. Is delivery address different from item 1? Yes
If YES, enter delivery address below: ~ No
3. Service Type
r;iCertifled Mail
D Registered
D Insured Mail
D Express Mail
~eturn Receipt for Merchandise
DC.O.D.
4. Restricted Delivery? (Extra Fee)
o.JZIJYes
7006 2760 0002 7405 9676
10259S-Q2-M-1540
Domestic Return Receipt
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Nicole M. Brumfield,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Defendant
CIVIL ACTION - LAW
NO. 06 - 7209 CIVIL TERM
IN DIVORCE
Isaac Brumfield,
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. Grounds for divorce: irretrievable breakdown under ~ 3301(d) of the Divorce Code.
2. Date and manner of service of the Complaint: December 20,2006, was served on
Defendant by Certified Mail and the green card was signed on December 21, 2006
(attached hereto as Proof of Service A).
3. Related claims pending:
4. (1) Date of execution of the Plaintiffs Affidavit required by ~3301 (d) of the Divorce
Code: December 15,2006;
(2) Date of filing and service of the Plaintiff s Affidavit upon the
Respondent: December 20,2006.
5. Date and manner of service of the Notice of Intention to file Praecipe to transmit record:
Certified mail, January 11,2007. (Attached as Exhibit "B").
Date: February 5, 2007
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, P A 17013
(717) 241-6070
Supreme Court ID No. 81924
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IN THE COURT OF COMMON PL
AS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
Nicole M. Brumfield
No.
2006- 7
9
Plaintiff
VERSUS
Isaac Brumfield
Defendant
DECREE IN
DIVORCE
AND NOW,
f~L
IFF,
L.60r'), IT I S OR
q
DECREED THAT
Nicole M. Brumfield
AND
Isaac Brumfield
,DEFE:
DANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS \ HICH HAVE
BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDE
HAS NOT
YET BEEN ENTERED;
None.
ATTES
NOTARY
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