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Home My WebLink About97-06910 ",.\' , , ,\\ <.\ '\':~' '>.'" ~s. " .', \~<, '\,\~ . " :;,~,>~' ,,':' ~., .~ ,. " ,. '," ,\ ',,'< , , ,\ '\ " , , \," " " " , '\', .- - , , ''', , , , \,' \ , , , , " '\~ :,'\ \- :", " ," ~-'\ " " ,"., "\: .' " " ,', ,~ , ' ,'\"'. , , '- ~' :-,\." ,\ ~,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHY Z. MULHOLLAND, Plaintiff v. NO. 9?~(,?{c) C~( ['''"7frJ f>} CIVIL ACTION - LAW DIVORCE DENNIS K. MULHOLLAND, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you mus t take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of dlvorce 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, lncluding custody or visitation of your children. When the ground for divorce is indignities or irretrievable hreakdown 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. IE' YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVIS ION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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, PA 17013 (717) 249-3166 OIANE O. RADCLIFF 34018 TRINDlE ROAD CAMP Hill. P^ 17011 1711l7~7.0100 DIANE a. RIIDCllFF :Ml4l TRINDlE ROAD CAMP Hill. PA 17011 1717) 737.0100 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHY Z. MULHOLLAND, Plaintiff v. (" ( '--- No.9'l'(".9/0 'W(' If",<.J>/ CIVIL ACTION - LAW DIVORCE DENNIS K. MULHOLLAND, Defendant COMPLAINT AND NOW, this \S1'--day of ~UL.... \0", , 19_C(L, comes the Plaintiff, KATHY Z. MULHOLLAND, by her attorney, DIANE G. RADCI,IFF, ESQUIRE, and files this Complaint in Dlvorce of whlch the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is Kathy Z. Mulholland, an adult individual residing at 268 West South Street, Carlisle, Pennsylvania 17013 since 1987. 2. The Defendant is Dennls K. Mulholland, an adult individual having a mailing address of 446 North Pitt Street, Carllsle, Pennsylvania l70l3, although he is bel~eved to be actually residing in Harrisburg, Dauphin County, Pennsylvania since November 7, 1997. 3. Plaintlff and/or Defendant have been bona fide residences of the Commonwealth for at least six (6) months previous to the flllng of this Complalnt. 4. Plalntiff and Defendant werE,! marrled on December 23, 1994 at Carlisle, Pennsylvania. 5. There have been no prlor actlons of divorce or annulment between the parties. DIANE O. RAOCLlFF 3448 TRINDlE ROAO CAMP Hill, PA 17011 1717) 7J7.o100 6. Plaintiff has been advised of the availability of counseling and the rlght to request that the Court require the parties to participate in counsellng. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marrlage is irretrievably broken; Or ln the alternative, b. That Defendant has offered such indlgnities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, and that this actlon is not collusive. Or on the alternative, c. That the partles are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleglng that the parties have Ilved separate and apart for at leas t two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acqulred property and debts, both real and personal, during thelr marriage from December 23, 1994 until November 7, 1997, the date of separation, all of which is "marital property" or "marital debts". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value slnce the date of marriage and/or subsequent to its acqulsition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an equitable division of sald property as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. Respectfully submitted, ..-: , e oad , PA 17011 (71 ) 737-0l00 Attorney for Plaintiff 1.0. No. 32112 .1' . j i' k, I \ , : ! ./ _. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHY Z. MULHOLLAND Plaintiff NO. 97-6910 CIVIL TERM V. DENNIS K. MULHOLLAND Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce has been served upon the Defendant, Dennis K. Mulholland, by Certified Mail, Restricted Delivery on the 24th day of December, 1997. 'rhe return receipt is attached hereto as Exhibit "A" and made a part hereof. ~ , PA 1.7011 100 32112 for Plaintiff DIANE G. RADCLIFF 344$ TRINOLE ROAD CAMPfIlLL. PA 17011 1717) 737.0100 I " " , "... C:) ~- I , '~T.; , .:J t,-;; rt.. " .) .' e, t"....,: , J US' ) ~ '.. p:'.,' 'I~' I ~.. :".1 i';r , _I--~ ~' (.. '_-~1:', I ~; li.\1 t.. ' ....-~ .._lO,. ,,, """ ~ (f:~ ;..J 0' (...l '"'- A, ....~