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Home My WebLink About00-02905 - " -~ .- ~ ~- '.... LISA M. McMULLEN, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW SEAN R. McMULLEN, Defendant. No, 00-2905 Civil Term IN DNORCE RETURN OF SERVICE United States Mail The undersigned makes the following return of service: The Complaint was mailed to Sean R. McMullen on June 19, 1000 at 214 Senate Avenue Camp Hill, PA 17011. The signed receipt, indicating service was made on June 20, 2000, is attached. SIGNATURE AND AFFIDAVIT I, Melissa Peel Greevy, Esquire, certifY that I am a competent adult not a party to the action. I verifY that the statements made in this affidavit and return of service are true and correct, I understand that false statements herein made are sub' the penalties of 18 Pa. C, S. S 4904 relating to unsworn falsification to authorities. Issa Peel Greevy, Esquire Supreme Court I,D, 77950 214 Senate Avenue Suite 105 Camp Hill, PA 17011-2336 (717) 763-8995 Counsel for Plaintiff Date: b/;;.1bo-v -----------:;:--. > LISA M. McMULLEN, Plaintiff, _~ ,J _ = IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW SEAN R. McMULLEN, Defendant. No,OO-2905 Civil Term IN DIVORCE ~. SlNOER: :I .'Complete items 1 and/or 2 for additional services. 10 . Complete ite~ 4a, and 4b. 91 . Print your nam~ address on the reverse of this form so that we can return this e: card to you. !: . Attach this formtflnhe front of the maHpiece, or on the back if space does not 4D pelfmit. "- . Write "Return Receipt Requested" on the mailpiece below the article number. ! . The Return Receipt will show to whom the article was delivered and the date ~ delivered. a 3. Article Addressed to: i 5~ ~ .}vL~MuJlett- ,l545 Lftw 70ST tAIJt e4\M5f tHLL fA ho j I I also wish to receive the following services (for an extra fee): 5, Received By: (Print Name) ~ied D Insured D COD 8. Address e's ddress (Only if requestect and fee is paid) ~ ::I o >- !II 102595-'8'B,O*,' Domestic Return Receipt ;J I J Ol C 'iij ::I ~ ,g '" g, 11 .. .c .... '1 . .,.- , 'I ;, Ii 'I I_i ji I' ;1 L )'j ; :1 [1 ~ j \1 'I ~ , i 'I lj :, 'I l 'I " [j S II :1 II II lj I, :1 i' I I ! ~~- If''''-,~.......,,,,,,,,,,,, A.... 'au-~!."""-"~~~ f' '> \' , """ - g ~ ~ r" U) (') ~ -uQ:l ~fj; ~r:;, ::< Z. <;:0 %0 _-0 "}>~ -I ..... \'-.J:;,>-, 1:'-;:-'~ ',.) -~,}) ",.,'. ~," S' 0:- .' ~p .~ f"J:"- C. "'" , , ,J""",, -.~_l_ , ;'r. ",),;i LISA M. McMULLEN, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v, CIVIL ACTION - LAW SEAN R. McMULLEN, Defendant. No, 00-2905 Civil Term IN DIVORCE PRAECIPE To the Prothonotary: Kindly reinstate the Complaint in the above captioned Divorce matter. Date: &f~ uJi}dLh Melissa Peel Greevy, Esquire 1. D, No, 77950 214 Senate Avenue Suite 105 Camp Hill, PA 17011-2336 (717) 763-8995 Counsel for Plaintiff k ^"t; "'~ -. . - """~iJIiiIlIil;iIlOlIll..~~,:>><<,.~~IIlli.jl.~ilI "1'-' - ;'t",65'_~'-~~. "'0'_ ~.'l ,.' o c :;;;: -OCT' n1r-6 2:--, 'Z= <:1>;10: i:5L. ~O "8 _ ~:=:(J ";U ~ c ~ , ,,". .. ..' a o Cj ":'h := '- Z - ;li.Id --.-.'fT; -:~' l_J "--", I ::i(:J >,~=Et 7CJ- ,:'~rn '~ -< c..~, ;r-........ :S~ '9 ':::> ...., ~ ::::l , L~, " ;"',",",,,-c" '~.,. LISA M. McMULLEN, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. SEAN R. McMULLEN, Defendant. CIVIL ACTION - LAW No.OO-.1qDS'Civil Term IN DIVORCE Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 17013 II 'I I I il :, ,I \ ), 1 i I I I I J I ~ I , I I ! NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing pages, you must take prompt action. You are wamed that if you fail to do so, the case may proceed without 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 other 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: 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 .oJ:." (.--Co ^ -c-~' ,..1-,0__' , -, "'. c_,~," ,-;;"= ..,- '~ ! LISA M. McMULLEN, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. SEAN R. McMULLEN, Defendant. CIVIL ACTION - LAW ./ tH), ;;l<iOS No. Civil Term IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302( d) ofthe Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania, You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days ofthe date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ..- ~. , ,:1 '.w_'" ",-" - - "\'~<..- .-_.",f. .., ~,,--, LISA M. McMULLEN, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, SEAN R. McMULLEN, Defendant. CIVIL ACTION - LAW P1J..;2 90:/ No. Civil Term IN DIVORCE COUNT I COMPLAINT IN DIVORCE UNDER ~ 3301 (c) OR ~ 3301(d) OF THE DIVORCE CODE Plaintiff, by and through her attorney, Melissa Peel Greevy, respectfully represents: 1, Plaintiff is Lisa M, McMullen, who currently resides at 545 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania. 2. Plaintiffs Social Security Number is 175-48-6610. 3. Defendant is Sean R. McMullen, who currently resides at 545 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania. 4. Defendant's Social Security Number is 267-84-8617. 5, Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six months immediately preceding the filing of this Complaint. 6. The parties were married on July 23, 1983 in Camp Hill, Cumberland County, Pennsylvania. 7, There are two minor children of this marriage: .1l.l , '--,,'< Name Taryn Liisa McMullen Ian Regis McMullen Age 12 8 Birth date April 29, 1988 August 21, 1991 8. Neither Plaintiff nor Defendant is in the ruilitary or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. There have been no prior actions of divorce or annulment between the parties. 10. The marriage is irretrievably broken. II. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the court require the parties to participate in counseling. 12. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT II - 23 Pa, C. S. A. ~ 3301 (a) (6) 13. Paragraphs 1-12 of this Complaint are incorporated by reference as if set forth at length. 14. The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and her life burdensome. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT 11I- EQUITABLE DISTRIBUTION 15. Paragraphs 1-14 of this Complaint are incorporated by reference as if set forth at "-~ "'~ '" ~< "., . "." .,"~"- -', 1-' length. 16. Plaintiff and Defendant have acquired property, both real and personal, during their marriage.. 17. Plaintiff and Defendant have not agreed as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all COUNT IV - ALIMONY i I i I , I i I i i I I i marital property. 18. Paragraphs 1-17 of this Complaint are incorporated by reference as if set forth at 19. Plaintiff is unemployed at this time and lacks sufficient property to provide for her i , , I i I I I I I I I I I I I length. reasonable needs. 20. Plaintiff is unable to support herself through reasonable employment. 21. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard ofliving established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony in her favor. I verifY that the statements made in this Complaint are true and correct. I uoderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities, Date: ~V\ 7J1 Lisa M. McMullen 1i1~ }tt~ o - 6/ ciJ ,'~ -, 1- , , Date: 5/9/ 0W1JV Respectfully submitted, lA{sd?DL @ Melissa Peel Greevy, Esquire J.D. No. 77950 214 Senate Avenue Suite 602 Camp Hill, PA 17011-2336 (717) 763-8995 Counsel for the Plaintiff ) 'or> " ,~:"",-'~"".,..;'~~~, .;_. ;".... 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