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Home My WebLink About07-0151 LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prussoftyirlaw.com Attorneys for Plaintiff SHAWN BRUBAKER : IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW JENNIFER ZOE BRUBAKER : NO.67 - ZV CIVIL TERM 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 w- , % . Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 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, 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 717-2494166 1-800-990-9108 LAW OFFICES OF PETER J. RUSSO, P.C. BY. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso@pjdaw.com Atbomeys for Plaintiff SHAWN BRUBAKER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW JENNIFER ZOE BRUKEBAKER : NO.O'j - %?/ CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301 c AND 3301id) OF THE DIVORCE rr? vary AND NOW COMES the above-named Plaintiff by and through his attorney Peter J. Russo, Esquire and seeks to obtain a Decree in Divorce from the above- named Defendant, upon the grounds hereinafter more fully set forth: Plaintiff is Shawn Brubaker, an adult individual who has resided at 845 Heck Hill Road, Lewisbery, Cumberland County, Pennsylvania since May of 1996. 2. Defendant is Jennifer Zoe Brubaker, an adult individual who has resided at 541 Pennsylvania Avenue, York, York County, Pennsylvania since December of 2006. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 34 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for 31 years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on December 7, 2004, in Cumberland County, Pennsylvania. 6. Plaintiff and Defendant separated on November 5, 2006 7. Plaintiff is in the PA Army National Guard and is currently inactive. 8. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 9. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling, but does not request the same. 10. Plaintiff and Defendant have property which will be subject to a property settlement agreement, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, Shawn Brubaker, prays that a decree be entered in favor of the Plaintiff and against Defendant dissolving the marriage between the two parties. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plain Peter J. Russo, Esquire ID #72897 Scott A. Stein, Esquire ID # 81738 Elizabeth J. Saylor, Esquire ID #200139 Date: I Z?2 8 p LAW OFFICES OF PETER J. RUSSO, P.C. By. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 2WMQ@&rlaw.com AftMey$ for Plaintiff SHAWN BRUBAKER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW JENNIFER ZOE BRUBAKER : NO. Defendant : IN DIVORCE CIVIL TERM VERIFICATION I, Shawn Brubaker, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: a Shawn Brub ker 0 ? w G -Icz C_s C_ na p G? +.J CD W 0 -r „QF? r(.-77 ?i O LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso(a-_)pirlaw.com SHAWN BRUBAKER Plaintiff, V. JENNIFER ZOE BRUBAKER Defendant. Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 07-151 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the complaint in divorce. I certify that I am authorized to accept service as I am the defendant in the above action. Date Jennif Zoe baker 541 Pennsylvania Ave York. PA 17404 Mailing Address r -4 l cn ±* - LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prussoa2idaw.com SHAWN BRU13AKER Plaintiff, V. JENNIFER ZOE BRUBAKER Defendant Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 2007 -151 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the foregoing documents indicated below upon the person(s) and in the manner indicated below: Documents: a) Plaintiffs Affidavit of Consent b) Plaintiffs Waiver of Notice c) Defendant's Affidavit of Consent d) Defendant's Waiver of Notice e) Praecipe to Transmit Record U.S. Mail addressed as follows: Jennifer Zoe Brubaker 541 Pennsylvania Ave York, PA 17404 Date: / a 7 shley Sipe, P ralegal c? k _ F u ? ?l Y - s LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso@pjrlaw.com Attorneys for Plaintiff SHAWN BRUBAKER : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JENNIFER ZOE BRUBAKER : NO. 07-151 CIVIL TERM Defendant. : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on January 8, 2007. 2. The marriage of plaintiff and defendant is irretrievable 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 authoriti Date: 1G ?;? `C 7- VIA t M co LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso@pjrlaw.com SHAWN BRUBAKER Plaintiff, V. JENNIFER ZOE BRUBAKER Defendant. Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 07-151 CIVIL TERM : 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. 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 statement 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: I0 NNIFEVR ZOO BRUBAKER of Yr.. ? I ??? ..1 IT LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso@pjrlaw.com SHAWN BRUBAKER Plaintiff, V. JENNIFER ZOE BRUBAKER Defendant. Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 07-151 CIVIL TERM : 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. 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 statement 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: 101 9, 1 ?,C)o AWN BRU AKER 1 < a 5 ? R "' LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso@pjrlaw.com SHAWN BRUBAKER Plaintiff, V. JENNIFER ZOE BRUBAKER Defendant. Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 07-151 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on January 8, 2007. 2. The marriage of plaintiff and defendant is irretrievable 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. Date: I o a ?e'° ?" 5?u.xd??L AS?fIAWN BRUBAKER 5 J 1 1 LAW OFFICES OF PETER J. RUSSO, P.C. BY: PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 prusso Qtplrlaw.com SHAWN BRUBAKER Plaintiff, V. JENNIFER ZOE BRUBAKER Defendant Atkwneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007 -151 CIVIL TERM 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 broken under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint filed on January 8, 2007; Personal service with an acceptance of service on January 27, 2007. 3. Date of execution of the Affidavit of Consent required by § 3301(d) of the Divorce Code: (a) By Plaintiff Shawn Brubaker, on October 2, 2007; (b) By Defendant Jennifer Zoe Brubaker, on October 2, 2007. 4. Date of execution of the Waiver of Notice was executed: (a) By Plaintiff Shawn Brubaker, on October 2, 2007; (b) By Defendant Jennifer Zoe Brubaker, on October 2, 2007. 5. No other related claims are pending. Both parties have executed a Martial Settlement Agreement that shall be incorporated but not merged into the Divorce Decree. 6. Plaintiffs Affidavit of Consent and Waiver of Notice has been filed with the prothonotary simultaneously herewith. 7. Defendant's Affidavit of Consent and Waiver of Notice has been filed with the prothonotary simultaneously herewith. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff Peter J. Russo, Esquire I D # 72897 Elizabeth J. Saylor, Esquire ID # 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Date: i, o Lp 2i 1 r l al l r„? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. SHAWN BRUBAKER, ain N O . 07-151 VERSUS JENNIFER ZOE BRUBAKER, Defendant DECREE IN DIVORCE AND NOW, 0[-1'L -?'( , 2?, IT IS ORDERED AND SHAWN BRUBAKER DECREED THAT , PLAINTIFF, JENNIFER ZOE BRUBAKER AND 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; Parties stipulated property settlement agreement dated BY THE COURT: PROTHONOTARY December 28, 2006 is incorporated but not merged. .4111v -7 <Q - l - lr -e-, o - /-0/