HomeMy WebLinkAbout96-05850
MIRIAM S. FLEAGLE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. CIVIL ACTION - LAW
NORMAN E. FLEAGLE, 96 - .,-f ~U eL~.-<-f j;,.-
Defendant IN DIVORCE
NOTICB TO DBPBND 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 against
you and, a decree in 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 with 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 THEft.
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.
Court Administrator
Fourth Floor
Cumberland county Courthouse
Carlisle, Pennsylvania 17013
(717) 240-6200
(717) 697-0371
By:
Andrew C. She y, E
PA. 1.0. No. 62469
1 West Main Stree
Shiremanstown, PA 17011
(717) 737-8761
Attorney for Plaintiff
MIRIAM S. FLEAGLE ,
:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
vs.
Defendant
.
.
96 - ::S ,,[, C I ;.,~_~ Tt ,-
IN DIVORCE
NORMAN E. FLEAGLE,
COMPLAINT
1. Plaintiff is Miriam S. Fleagle, who currently resides at 6598
Carlisle Pike, Mechanicsburg, Cumberland county, Pennsylvania.
2. Defendant is Norman E. Fleagle, who currently resides at 6598
Carlisle Pike, Mechanicsburg, Cumberland County, pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months immediately
previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on November 1, 1986, at
Mechanicsburg, PGnnsylvania.
5. There have been no prior actions of divorce or annulment
between the parties.
6. plaintiff has been advised of the availability of marriage
counseling and understands that she may have the right to request that
the court require the parties hereto to participate in counseling.
7. Plaintiff avers as the grounds upon which this action is based
is that:
(A) That the marriage between the parties hereto is
irretrievably broken;
(B) That Plaintiff and Defendant are now living separate and
apart and, at the appropriate time, Plaintiff will submit an Affidavit
MIRIAM S. FLEAGLE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . CIVIL ACTION - LAW
.
NORMAN E. FLEAGLE, 96 -
Defendant . IN DIVORCE
.
AFFIDAVIT
MIRIAM S. FLEAGLE, being duly sworn according to law, deposes
and says:
(1) I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling.
(2) I understand that the Court maintains a list of marriage
counselors in the Domestic Relations Office, which list is available to
me upon request.
(3) Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a
Divorce Decree being handed down by the Court.
I understand that false statements herein are made subject to
the penalties of 18 Pa.C.S.A. section 4904 relating to unsworn falsi-
fication to authorities.
S.
SWORN to and subscribed before
me this' ?,"Ie. day of (\'1'li[", '- , 1996.
(/ ~~/'I.(/ () /')(("'--'"
Notary Public
My Commission Expires:
NOTARIAL SEAL
OWIEAlIlE J. eAARA.IIOTARYPUBlIC
SHlliEMANSTOWN BORa. Cl!M5ERlAtlD co. PA.
MY COMMISS'ON Ei.fIEES SEPT. 9,1009
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STIPULATION AGAINST LIENS
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by and between COLE BROOK CONSTRUCTION COMPANY, of 208 Fairview
Road, New Cumberland, Pennsylvania, hereinafter referred to as
contractor, AND ALBERT WILLIAM HEINZ, of 906 Woodland Drive,
Lemoyne, Cumberland county, Pennsylvania, hereinafter referred to
as Owner, whereby the former undertook and agreed to erect and
construct a room addition and other home improvements to the
single-family residential dwelling on that certain lot of ground
situate in the Borough of Lemoyne, Cumberland County, Pennsyl-
vania" being the same premises which A. William Heinz and Helen
L. Heinz, by deed d~ted June 7, 1995 and recorded in the Cumber-
land county Courthouse in Deed Book 125, Page 12, granted and
conveyed unto Albert William Heinz and Helen L. Heinz, his wife.
The said Helen L. Heinz died February 13, 1996, whereupon full
and complete ownership of the within described property became
vested solely in Albert William Heinz.
NOW THEREFORE, THIS AORl!lEKENT WITNESSETH: That the said
Contractor, for and in consideration of the sum of One ($1.00)
Dollar to it in hand paid by Owner, the receipt whereof is hereby
acknowledged, and the further consideration mentioned in the
agreement aforesaid, for themselves and their subcontractors, and
all parties acting through or under them, covenant and agree that
no mechanic's liens or claims shall be filed or maintained by
them or any of them against the said buildings and the lot of
ground app~rtenant thereto for or on account of any work done or
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