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Home My WebLink About00-04326 _b'_" ,,,-", I' ''- J;o[;j ELLEN D. TAMBOLAS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 00 - "'t~~ CLo-J I~ TAYK. TAMBOLAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned 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 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, One Courthouse Square, 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 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 Phone: (717)249-3166 l'~ ~ - ,-"- .. , ;~ ". ',~' I" ELLEN D. TAMBOLAS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA (j-()-43:U ~-r~ : NO. TAYK. TAMBOLAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant 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) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, 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. Ail 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary ,~'-- '-,,"^' I ELLEND. TAMBOLAS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLANp COUNTY, PENNA ; NO. trO- '/32.<. ~ (.h- TAYK. TAMBOLAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Ellen D. Tambolas, who currently resides at 104 Orchard Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Tay K. Tambo1as, who currently resides at 104 Orchard Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 2,1973, in Parsippany, New Jersey. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. 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. liJ " 1-', _'c' ,. " b.! The parties to this action have been separated since June 23, 2000. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. Plaintiff avers that she is the innocent and injured spouse, and that the Defendant has offered such indignities to the Plaintiff so as to render her condition intolerable and life burdensome. 12. This action is not collusive. COUNT II CLAIM FOR EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 13. Plaintiff and Defendant are the owners of various real and personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by this Court. COUNT III CLAIM FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 14. Plaintiff is unable to support herself through appropriate employment. 15. Plaintiff lacks sufficient property and income to provide for her reasonable needs. COUNT IV CLAIM FOR ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 16. Plaintiff does not have sufficient funds to support herself and pay the counsel fees and expenses incidental to this action. !Jl . ~ -. - '.-- , -~<~ '''I I I I 17. Defendant is full and well able to pay Plaintiff alimony pendente lite, counsel fees and expenses incidental to this divorce action. WHEREFORE, the Plaintiff requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; c. directing the Defendant to pay alimony to Plaintiff; d. directing the Defendant to pay alimony pendente lite Plaintiff's counsel fees and the cost of this suit; and e for such further relief as the Court may determine equitable and just. JAMES, SMITH, DURKIN & CONNELLY Date to - cJ,!r Of) "" _,,_J .. ", ,";"_J-_,,_, _ -~ < """. ~' _I VERIFICATION I verify that the statements made in this Pleading 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. Date: (f- ~ !r () 6 !tk!&~ ~ '""",,,-.'- .J.'Jii""~"'- .~- ;' ," , .~~ -... ~- ---" """", ",.,-_ --"~-,," '-'''.~__-,1 <Li" ,-"", kHl n_"~ __ '~, "." ~~ iiIo.; ;;;at,..........j () (...., () (;.. C'.) -n ~ C --.{ ~ .tq ~ S; <.... 'Tl1 Ti ""0 (J\,1 c: ;-.lp ~ ~ mfn Z :~~ .~ ~--' _L 1') 's.:. ,. CS ~ cr. r::), "<L ::,~'-r.i; Cl -0 ",~. -',1 N a 8 a 8 6 r;;;:. ~- ~~,~j ...0 ~8 ..... ~,~1'1 ":::::! W S:t ~ ;P'C: ., -", (j I I Z ::0 I ~ --: -< --0 Cv ~ -- ~ ~ 1 "- ~ ---, . - -".,. mL"""~ ,-',' -- . ELLEN D. TAMBOLAS, Plaintiff I ~I ':,1 , , i:! Ii : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA ; NO. CO - ~JJJ. CO~C '7-Uu.-., v. TAYK. TAMBOLAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE Ellen D. Tambolas, social security no. 181-34-9561 Tay K. Tamb01as, social security no. 176-30-6558 E .~.~ ~~ Co ~ 28 s>c: ~ g '- c:::: :z: 1'\> 0\ -u ::r ~ o on ;!~ -r~ "'P :'Qi'll ?-~T :::::;C) ..-1- -rJ ?'~.'j ::'-0 c5rn -'.. ~ -..r ':t - .~ """ , i, ~~" ...~~".~, - \ " H 105.157 REV.S-80 COMMONWEALTH OF PENNSYl.VANiA OEPARTMENT OF HEALTH VITAL RECORDS ~UNTY UmPJERJ....AI0D DIVORCE RECORD OF OR ANNULMENT {CHECK ONE) 0 STATE FILE NUMSER STATE FILE DATE HUSBAND 1. NAME (First} 2.. ". NUMBER OF THIS MARRIAGE (' III La< MtJnth V fIST, 03--/5-39 or_"""" PEiJltJA L ~/lJ6 / JU6EI!- BLACK o OTHe~"'1 WIFE LL6U lu"" 9. DATE OF BIRTH n. PUce OF SIRTH PA ION lMantbJ 100.,J IYIJIU'} o -tX3-'-}S fJW;(;-;T<>>.-v/ a. MAIDEN NAME 10. ;:reSIOENCE Sbwr or R.O. arv. 80m. or Tw,a. TAM Coumy ..... 12. NUMBER 13.. RA BUCK OTHER ISpIci,.,. WHITE OF THIS ~ 0 0 MAARI E 15. P'LAce OF ICoumy/ (samttN'FOIfIign CoIurUyJ OF THIS (J7IJKR./j )Jew MARRIAGE 17A. !\lUMBER OF CHIL- 17S. NUMSEA OF DEPENDENT CHIL. DREN THIS OREN UNDEA I. .o.1ARRrAGE 20- NUMBER OF HUSBAND WIFE SP1..IT CUSTODY' CHILDREN TO 0 D D CUSTOOV OF 22. DATE OF DECREE lMolrthl lDa.,J IY_ 23- DATE REPORT seNT TO VITAL RECORDS IS. DATE OF T!<'S MARRIAGE Y...., HUSBAND o WIFE OTHER (Sgecifyl o tLo /) & . '" 24. SIGNATURE OF TRANSCRIBING CLERIC. - " . . ~- ~: L . ,-~,: '-";';,,,," ,~~."", " ' - ELLEN D. TAMBOLAS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-4326 Civil Term TAYK. TAMBOLAS, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this cJlJJ:i day of 2000, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce was served on the Defendant, Tay K. Tambolas, on July 3, 2000 by certified mail number 7099340000092912 1961, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and subscribed before me this ~{)a day of 2000. NOTARIAL SEAL Jean l, Kosier, Notary Public City ot Hummelstown,County at Dauphin My Commission Expires Feb. 9, 2004 .- - " 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 jf space permits. 1. Article Addressed to: '" fi:.. ~Addressee ddr6SS different from item 1? 0 Yes ter delivery address below: 0 No /fY X ~?4'S /0"1' BrC/7aY'd Sd. ~C}a-?/i5.6k[}?-, /:/,.4 /7< - o Express Mail o Retum Receipt for Merchandise o C.O.D. , 4. Restricted Delivery? (Extra Fee) Ves 2. Article Number (Copy frqm service label) ,,7;)9'9 -<.?1/oo oa:J9 r-?9/cZ /7'0/ PS Form 3811 , July 1999 Domestic Return Receipt 102595-99.M-1789 \ -.:..A'r-Y.J '. ]~. '-7- .:...) C' l,;.:. w..::.'- '- .;:0 " N , :5 ~ Z ::><( 8~ o~ ~(j) :J~ rr; ~~:., '-' .' -