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HomeMy WebLinkAbout94-01130 I ,~ o o <- cD j t:1 ~I I I a r0; __f ---: ,} <~ , i, ~ ~ ~ ~l1SS.E.~~,~E.E...BR()()I<S, , ,SR~....,....,.,. . 8 ~ 8 ~ ~ ~ " ~ , ~ ~ ~ ~ ~ 8 ... a " 8 ~ . ~ , ~ ~ ~ D y The C 0 u r I: /' /1' /t .', 8 ' . ~ \., !J./t4,~ O~( ! ,(, ,., ~ M AuellU . 0 .. J. ~ ~ ~i:~Q, ~ .}/ /'" ~ M ~ XJerl Prothonotary . : ~ -- ---- -~ . ------ ' ~ ,r.o:- ... _ ~:' ... .. .... ...' '.' ... .. .... _ ... ,*' ... ... .:tt. .It> ... 'lIe' .;". .:oe~ 'lie' .:oe, ..:-::.;-:;;.:-:->>::~: ~...' '...' ... ,)ICo' >>>:'... ->>' _: _.... _ '...: ... -:oe, '-:C-' '..' '....:c-: ,>> .:.,;,'X:,lC{'X",....:.ollQo(;.a< :.)ICo':_ --~ , ~ ~ S . ;;; " $ 8 8 CINDY BATES BROOKS $ ..'""""""",,""""'" ,,', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. Plaint;~ff,.." .,.....,. ,.,...' II Ii Ii , II II N o. ..,..~,P9..J;:JV:J;~,........... 19 94 VcrslIs p~fenc,iant DECREE IN DIVORCE AND NOW, , :J Wl,~.. i!.". .. .. .. . .. . .. " 19,1.':1.., it is ordered and decreed that. , , ,. , " ~.~':lc;1y. .~~~~!!. ~1=.C!C?~!3,.. ,. , , ...... .. ...., plaintiff, and....".."..,.. ~~~~~.~~. ~.~E7. ~!.~C?~~.', .~~:.,..,."....... 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; . ... .... .... ........ .... ... ..... ...... .................................... .. ........ .......... ...... ............................... $ ~ ~ . ~ ~ $ . 8 8 ~ . - ! ~ ~ ~ " , . 8 ~ ~ '" , ;,: ~ ~ ~ a " ~ " ~ ~ .'. ~ .. . . td~ ~ ?//,,$y -::r :;n > r'" ~;.) ~. .....1 .'" ~ - ::~ ~ - ~ Iii 2: ! ~H~ I ~ ~~.8C1: ; J~ ,0 ' ! lJ) .!!l t a) D..:s .. ~~. ~ I . . . . CINDY BATES BROOKS, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA Civil Action - Law VS. : RUSSELL LEE BROOKS, SR., Defendant DIVORCE NO. 1130 CIVIL 1994 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this 16th day of June, 1994 by and between Cindy B. Brooks, of 12 Peacock Drive, Carlisle, Pennsylvania 17013 (hereinafter referred to as "WIFE") and Russell Lee Brooks, Sr., of 5146 Erbs Bridge Road, Mechanicsburg, Pennsylvania 17055 (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on September 7, 1974 and WIFE instituted an action in divorce to No. 1130 CIVIL 1994 in the Court of Common Pleas of Cumberland County Pennsylvania on March 9, 1994. The pleadings in the case raised the issues of equitable distribution of marital property, alimony pendente lite, counsel fees and expenses and custody of the children; and WHEREAS, The parties have reached an agreement as to the settling of all these matters between them. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which I is hereby acknowledged by each of the parties hereto, HUSBAND and I WIFE, each intending to be legally bound, hereby covenant and I I agree as follows: Ii !: !' I; , , 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The terms of this Agreement and their effect have been fully explained to the parties by their counsel, Jane M. Alexander, Esquire who has, after explaining to them their right to each retaining counsel agreed to represent both parties. The parties acknowledge that they have received legal advice from counsel and have been fully informed as to their legal rights and obligations or have fully chosen not to do so. The parties understand the facts and acknowledge and accept this Agreement as fair and equitable and release Attorney Alexander from any and all liability thereunder. 3. The parties have attempted to di',ide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of I the parties that such division shall be idetermine their respective rights. The Imarital property is not intended by the ! i Ii !! final and shall forever division of existing parties to constitute in , any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. 4. Further, the parties agree to continue living separately and apart from the other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carryon and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 5. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. . 6. It is further mutually agreed and understood by and between the parties that all joint debts have been paid including open accounts, credit cards, and bank liabilities except as hereinafter set forth: a. The HUSBAND shall assume all liability for and pay and indemnify the WIFE against all debts and bills in his name alone, particularly those incurred since date of separation. b. The WIFE shall assume all liability for and pay and indemnify the HUSBAND against liability for all debts and bills in her name alone, particularly those incurred since date of separation. c. The parties do acknowledge that they do have the following outstanding obligations and agree to responsibility for payment as follows: 1) HUSBAND has or will assume payment of the balance due on the Household Finance Company account with a balance due of approximately $1,900. This account shall be refinanced in HUSBAND'S name alone or account shall be paid in full and closed. 2) WIFE will continue to assume payment of the balance due to Blazer Finance company with a balance due of approximately $2,000. This account shall be refinanced in WIFE'S name alone or account shall be paid in full and closed. 2. HUSBAND shall receive title to the 1993 Chevrolet and assume the responsibility of payment of the balance do the General Motors Acceptance Corporation which is approximately $13,000. 3. HUSBAND shall receive the 1986 Kawasaki cycle and the 1991 Kawasaki jet ski and ski trailer. 4. WIFE shall receive title to the 1987 Subaru which is presently titled in both names and be reoponsible for any indebtedness thereon. 5. WIFE shall receive title to the 1983 "pop-up" trailer. 6. WIFE shall receive title to 1991 Sedu jet ski. c. BANK ACCOUNTS: The account of the HUSBAND shall become his sole property and any bank account of the WIFE shall remain her sole property. d. PENSION AND/OR RETIREMENT FUND: Neither party shall make any claims concerning existing pension and/or retirement funds and therefore, neither party is making any demand for payments from same. If releases are required by either party to remove spousal rights said documents shall be promptly executed upon request. 7. a. RESIDENCE OF THE PARTIES: The marital residence of the parties, being a mobile home located at 12 Peacock Drive, (Township of Middlesex) Carlisle, Pennsylvania 17013, shall be titled in WIFE'S name free and clear of all encumbrances. The agreed upon consideration for the transfer of six thousand ($6.000) dollars has been paid. Other real estate owned by the parties is an interest in a hunting camp in Juniata County. No change is to be made in the ownership. b. PERSONAL PROPERTY: The parties have heretofore divided their personal property to their mutual satisfaction. Henceforth, each of the parties shall own, have, and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were married. Specific disposition of major items of personal property is as follows: 1. HUSBAND shall retain the ownership of the 1985 Ford pickUp truck which is titled in his name alone. There is no indebtedness thereon. 8. There were two children born of this marriage, Russell L. Brooks, Jr., born June 20, 1977, age sixteen (16) shall reside with the HUSBAND, the natural father, who shall have primary physical custody of his son, Russell L. Brooks, Jr., and stacy M. Brooks, born November 30, 1978, who shall reside with the WIPE, the natural mother, who shall have primary physical custody of her daughter, Stacy M. Brooks. a. HUSBAND and WIPE shall have joint legal custody of both children. b. Both parties agree that, because of the age of the children, visitation with the non-custodial parent shall be arranged on a schedule mutually convenient to all parties. c. Should a medical or other emergency arise in regard to either child, the parent having custody at that time shall immediately notify the other parent. d. The parties agree that there' shall be no claim for support filed by either the HUSBAND or the WIPE unless the aforementioned custody arrangement changes and one parent would have custody of both children. e. The parties agree that the college expenses for the son, Russell L. Brooks, Jr. shall be equally divided between the parties. f. WIPE will continue to provide medical insurance coverage for the children as long as they are eligible. 9. Alimony: The parties agree that neither party shall seek alimony or support from the other. 10. The property settlement as provided herein between the parties shall be considered an equitable distribution of marital property and both parties waive any and all rights or claims which they may have been entitled to raise with respect to the issue of equitable distribution under the provisions of the Pennsylvania Divorce Act. 11. The parties agree that simultaneously with the signing of this Agreement they will sign the necessary affidavits of consent and affidavits acknowledging notice of marriage counseling in order to conclude the divorce action filed by WIFE under the no-fault provisions of the Pennsylvania Divorce Act. 12. The waiver or unenforceability of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered to be a waiver of or forfeiture of right to enforce any other term, condition, clause or provision of this Agreement. 13. This Agreement shall be construed and interpreted according to the laws of the Commonwealth of Pennsylvania. 14. It is understood and agreed that the heirs, administrators, executors and assigns of the parties hereto shall be bound by all the terms, conditions, clauses and provisions of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written, intending to be legally bound. Brooks . ~i '. . " I- 7{/ z/.-d. .,/ ~(r / ..' / K.~-( L. ,tfJiJ(SEAL) Russell Lee Brooks, Sr. L) undersigned officer, a Notary ~~L Public, , 1994, before me, the in and for said COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK On this, the )t:Liay of : 55. . . Commonwealth and County, personally appeared Cindy Bates Brooks and Russell Lee Brooks, Sr. known to me (or satisfactorily proven) to be the persons whose names are subscribed to the foregoing Marriage Settlement Agreement and in due form acknowledged that they executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and year aforesaid. /' " ~~f /(>f/~i 'Notary Public [, -"" "." In'!nl( t~,:~F-, ~.,~^.tt-1PltJb " r,,!~',_, ,I: L',:,: ',';rl>\CO'.rrry f\.t;' l,_'("'-~""'-': .;<;r; r~\~jll.':', FdJ. 4. 1995 ,. ~fu~sy;\;';1(',l,",Ar~'1blol m ,- -:> --i ::) '-',_.J . _.~ , 00 Ii o<t; 51 riI ...:l 0 P<o<t; ~ .... U P< ~ .s:: !:! Z ..-4 D:1tl ~ ~; 0 . .... 00'0 ~~ ... s:: s:: Eo< ~ - C5 en ...-4 .Ql H ~... ~ en ~~ 00,,", :E: '" ".':Ip M :':Ql 00 1:1 ~ . .; I 0 gP< 00 ~ " dl 0{ , ~u ...:l ~ :...;l n. ; 0 H D: ~ ~~ . ~~ > III III .' ... o~;, , 15"'n.' l H ~;~ ,~ U 00 riI 0 5~ riI riI Eo< ~~.. 0 I 0 ~ ...:l UriI M . riI riI~ M III III ...:l P< M > ...:l H ~u ~ riI U Ul ~ . Ul Z~ 0 H ::> i' ;H.r.~.""":J CINDY BATES BROOKS, . IN THE COURT OF COMMON PLEAS . Plaintiff . OF CUMBERLAND COUNTY, PENNA. . VS. . Civil Action - Law . . . RUSSELL LEE BROOKS, SR. . NO. 1130 CIVIL 1994 . Defendant 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 Section (X) (3301 (c) or () (3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: bv U.S. Postal Service. Certified and Restricted with received. MARCH 18. 1994 return receiPt 3. (Complete either paragraph (a) or (b) ) (a) Date of execution of Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: June 16, 1994 , By Defendant: June 16, 1994 (b) Date of execution of the Plaintiff's Affidavit of required by Section 3301 (d) of the Divorce Code: and, date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: satisfied. All claims are settled and 5. Date and manner of service of notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 (d) (1) (i) of the Divorce Code. /t.?. Jane M. A . Attorney for , sq re (Plaintiff) (Defendant) -::r ~ ~.~.. ~ -4 ~ J 1~~ ~4~t * ~ . "'li ",- ~ ~ ,- ~ ~ ~ g ~ ~ ~~~ ~ - - 'iIt- rr'\ (;"\n -..!) ~ iF '-.90 ~"1\ ~~ - .'... ~; cr> c:: ., :.:-::. - .~ ~ . ~ -~ P:: , ~ za 1II-iJ au 1II~ s:: " It. :j-. ~ Q ~'M -Ill ~~ 1II'tl roll 0- a~ ~s:: u I:l- U 8~ P:: '- ~ii! III III g .-l P::Ql ~ i"~ a roll 1IIP, . IllQ H /t., t,~~ \l E-t ~ ~ roll 1II Q ~ > roll Z P:: H roll '::) gu~ III ...:l H ~ ~ i"1 ('('\ u~> ~ ...:l ~ _ roIla~ ...:l roll H -:X:1II111 H 1II ~ " E-t<~ U 1II ...:l ~ z~ ~ ~ "- ";2 H P, P, a "~, u .......",.... ..)..~,.<i.'lU{....,. 10,td,' O"'f\tfOJO--)l~""9)1].US'" INDY BATES BROOKS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW DIVORCE VS. USSELL LEE BROOKS, SR. Defendant NO. //3 (] &:.t /qqtf NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against he claims set forth in the following pages, you must take prompt ction. You are warned that if you fail to do so, the case may roceed without you and a decree of divorce or annulment may be ntered against you by the Court. A Judgment may also be entered gainst you for any other claim or relief requested in these apers by the Plaintiff. You may lose money or property or other ights important to you, including custody or visitation of your hildren. When the ground for the divorce is indignities or irretriev- ble breakdown of the marriage, you may request marriage counsel- ng. A list of marriage counselors is available in the Office of he Prothonotary at the Cumberland County Court House, Carlisle, ennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION ~F PROPER- , LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS RANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU o NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator CUmberland County Courthouse 4th Floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 CINDY BATES BROOKS, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW DIVORCE RUSSELL LEE BROOKS, SR. Defendant NO. NOT I C I A Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted de be presentar una apariencia escrita 0 en persona qr por abogado y archivar en la corte an forma escrita sus defensas 0 sus objeciones alas demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. US TED PUEDE PERDER DINERO 0 PROPIEDADES 0 OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI USTED NO TIENR 0 CONOCES UN ABOGADO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEQUIR ASISTENCIA LEGAL. Court Administrator Cumberland County Courthouse 4th floor 1 Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 Telephone: (717) 854-8755 , ~"'f-:";I4'l',..~....... COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE AND NOW, this 2nd day of March, 1994, comes the Plaintiff, Cindy Bates Brooks, by her attorney, Jane M. Alexander, Esquire and filed this Complaint in Divorce upon a cause of action of which the following is a statement. 1. Plaintiff is Cindy Bates Brooks, 37 years of age, who currently resides at 12 Peacock Drive, Carlisle, Pennsylvania 17013 (Middlesex Township) County of Cumberland and Commonwealth of Pennsylvania. 2. Defendant is Russell Lee Brooks, Sr., 37 years of age, who currently resides at 12 Peacock Drive, Carlisle, Pennsylvania 17013 (Middlesex Township) County of Cumberland and Commonwealth of Pennsylvania. 3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married September 7, II 1974 in Pennsylvania by a minister. I Ii I' II Ii r~'-"I;;":'1':" ".~~~,';t ._- , ~ 5. There were two (2) children born to them. Russell L. Brooks, Jr., age sixteen (16), born June 20, 1977, and Stacy M. Brooks, age fifteen (15), born November 30, 1978. 6. There were no prior actions in divorce or annulment commenced by the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, costs and property division. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indigni- ties to the person of the Plaintiff as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT II 10. The allegations of Paragraphs one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT III 12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10) and eleven (11)) are incorporated herein by reference and made a part hereof. 13. Plaintiff and Defendant have acquired property, both real and personal during their marriage. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may I deem equitable and just. Respectfully submitted, DATE: /]~ ~ ,'#; t-U',I(;: 1tJ'f' Y 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. Section 4904 relating to unsworn falsification to authorities. &l~(ill- &t:tlA Aw"'k<Jj cindy Bates Brooks DATE: March 2, 1994 COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK . . S.S. Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, personally appeared Cindy Bates Brooks who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. ~l/ui:/: O/.t[4- &(M-iJ Cindy B es Brooks Sworn to and subscribed before me this 2nd day of M"rch, 1994 / '\ . . c--..~ I.. -,,'" 'i!t'r~ ~{)4~, Notary Public " NoIIlriaISeal .'oyce SlJ..Idoey. NcMry ~ W..........T\\1lo,'lb1tCOlltV MyCOlM'lSsion ElIpiresAi-O.4, 1997 .w, _:anes '. ~,.. -i"" · ~_.r . :.~ ~:'':'f' ; :.::~:: Cn ,;. .;- .., '-:.'" ,.;... ;(.-" -> t.. 1II f:i o-:l PloeC zffi . " P: ~ C;; 1II iPl M J~vi ~ . . u ..~'" o . ~:::: ~ H ~... tI\;!o ~~ ffi -!~!: 8~ ~ ~ ~ ell! P:s:l 1II 0 Ill',.j III ~ ~ '0' E-tU 1\1 t.. ~ ~Ul",~ ~~ 1IIr-i M 0 ~~~ ~ ~Pl g? M o-:l E-t oeC H wP1 III o-:l ~ o-:l ~w >< w Cl z~ ~ 1II H 1II t.. H ::> ..... ~...'" ." ~.....' '11110" IjO. ..11"<0... ''''__'j 01'"'''' .."lll..l~'.... CINDY BATES BROOKS, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO. PENNA. Civil Action - Law VS. USSELL LEE BROOKS, SR. Defendant COMPLAINT IN DIVORCE : No. 1130 CIVIL 1994 AFFIDAVIT OF SERVICE OMMONWEALTH OF PENNSYLVANIA SS: OUNTY OF YORK . . AND NOW, this 30th day of March, 1994 personally appeared ane M. Alexander, Esquire, who swears according to law, that a true and correct copy of the Complaint in Divorce under Section 3301(c) of the Divorce Code was caused to be served by certified ail with return receipt requested upon the said Russell Lee rooks, Sr., at his last known address: 12 Peacock Drive, carlisle, Pennsylvania 17013, on March 18, 1994, at 3:00 P.M. by leaving the same at the Dillsburg Post Office with postage re-paid thereon as evidenced by the mailing receipt and return eceipt hereto attached and made a pa thereof. " '.-f"'!t'.;; ,,-.,:j'<~~"';:',;~j ,-! ;,>1":::-~(:",\:;~'\'~~. rNDY BATES IrSSELL LEE BROOKS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO. PENNA. Civil Action - Law COMPLAINT IN DIVORCE No. 1130 CIVIL 1994 VS. BROOKS, SR. Defendant PROOF OF SERVICE PS FORn 3800, M.rch 1993 .~ilBl ~ f n ! i'~ ~ ~ i~ n ~ & if ~~ ~ & J i 4 d ~i J !.Iii i i is & Sf 0 -= \ '":\ ;- )., UJ UJ C- o VI ~ X'l () t; CI __'h__.._ , .... ,-I SE ER: :"1 . Complet. iI."" 1 and/or 2 fot Iddltkmll IIrvJc... I 1110 wl,h to receive the . i t- Complet. hi"" 3. Ind ol. · b. following ..rvlce. Itor In I.trll i Print your n.mt .nd add,... on the flY'rI' af thl, lorm sa thllt WI Cln fee)' I .turn tf", Ctrd to you. . .', ',. ~ AUlCh thlt 'orm to the "onl or themall~c..orontheb.cklf 'PIC. 1. 0 Addre.s..', Addr... . . .... 01. not permit. : .! Writt "R,tum R.ceipt RlqUttltd.. on 1M malIpitc. betaw the '"leSe number . ..... TheR.tumR.c-'ptwlll.howto""homthe.rtk:"wltdellvered.ndthedll. 2. Restricted DeUvery " . : g deN.,.,Itd. Consult os'mlllter 'or-'", ;: . , 1 e:~:a;;:.."l.to~: Htf.s., ~ 4a. Artlcl. NU;~7 II- ~.3 ja: , , ~ b1 'p.c.i9C<<X 'I tie 8'R~:r::~~JYP. Dln.ur.d . {!.t9;r?J..I'"sJ...E. J ~ / 7 N.3 C.rtlfled 0 COD ,2' / Expr... M.II 0 Raturn R.c.lpt 10' g, 7, D.t. 01 D.llv.ry MAR 1 81994' ~: .. 8. Addr....a.. Addr... (Dnly II ,.qu..t.d and I.. I. p.ldl 6\J.a GPO: ,... ... ,.. DOMESTIC RETURN RECEIPT -r en . -, ,~. f ,.' '.' r"',.,' ,-..,J '" :~ '-, . . ~ ZO ~ OU III ~ ~~~ I ~~ III qo , , ~ 0\ ~'l-l ~... 0\ U ~~ .-l 8:::: 81:: l ~ -: ~ c.. "'" ~... ~flI 0 r" · Eo<~<~ PIc PI'g Eo< ~ ~~ 11 '0-1 IalGl g; HH III III ~ ou~u ~P: Ial'l-l uc..>o ""'2l Q ~ - 6 r o~... PI "'" H Ial .-l . "'" c.. ~~IIl.-l ~ ~ Ial ~ z~ffio III III H Ii! Hll<ll<Z U VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY', PA Civil Action - Law CINDY BATES BROOKS, Plaintiff RUSSELL LEE BROOKS, SR. Defendant : DIVORCE : NO 1130 CIVIL 1994 AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on MARCH 9. 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of final decree in divorce, the right to claim any of them will be lost. 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 lS Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ - /& - ?~ , ~ ~ ,LJ i ~ !)a. if I Cindy Bates Brooks 8AI-t--kJ , en o .'.; .~ (~l .,",J ...." "-., . . ffi zo n; ou VI ~t:l VI ~ N f . . Z ~ ~ I 8~ .... ~~ VI 0 ~-~ m :.:~ u looN 0 l ~i;'! m 8~ 8s:: '" ~: ~ rl ~ ~ ,- c8 n;1lI - <: 0 OW n;~ 0 ~;a ,"" " E-<~~::l Ills:: Ill'g E-< ~ ~ ~q & I ..-1 W4I n; H> VIlli H "". I ::>U~H ~.-i W~ ~ ~ ofiI o U . ..:l~ ~' - ;5 I U~> ~Pl ~ t:l 0:;10 III ..:l H W M ..:l ~ :I:VlVlrl )l W ~ E-<~~rl ~ VI VI Z..:lWO H ~ HPlPlZ U . , CINDY BATES BROOKS, plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Civil Action - Law VS. RUSSELL LEE BROOKS, SR. Defendant DIVORCE NO 1130 CIVIL 1994 AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on MARCH 9. 1994. 2. The marriage of plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of final decree in divorce, the right to claim any of them will be lost. I verify that the statements made in this Affidavit are true I I I I I I I I .L~kt44/ ! and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ?,-/ft>-fJ1 Russell Lee Brooks, Sr.