HomeMy WebLinkAbout00-05850
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MINERVA A. BEAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
2000- ~ CIVIL TERM
RICHARD V. BEAM,
Defendant
IN DIVORCE
NOTICE
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 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 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, Cwnberland County Courthouse, Carlisle, Pennsylvania 17013.
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
717-249-3166
1-800-990-9108
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AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
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MINERVA A. BEAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- 61'50CIVIL TERM
RICHARD V. BEAM,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 330Hc)
OF THE DIVORCE CODE
NOW comes the plaintiff, Minerva A. Beam, by her attorney, Mark D. Schwartz, Esquire, and
files this complaint in divorce against the defendant, Richard V. Beam, representing as follows:
1. The plaintiff is Minerva A. Beam, an adult individual residing at 371 Claremont Drive,
Apartment #16, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Richard V. Beam, an adult individual whose last known address was 440
Northrup Street, Sail Jose, Santa Clara County, California 95126, however, his present whereabouts is
unknown.
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months
prior to the filing of this action in divorce.
4. The plairltiff and the defendant were married on January 13, 1981 in Harrisburg, Pennsylvania
and separated in July of 1994.
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5. There have been no prior actions of divorce or for annulment between the parties.
6. There were no children born to this marriage.
7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which
this action is based that the marriage between the parties is irretrievably broken.
8. The plaintiff avers that she has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
. Respectfully submitted,
By:
Mark D. Schwartz, Esquire,
Attorney for Plaintiff, Cheryl K. Tritt
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 70216
Date: August 21st ,2000
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VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
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MINERVA A. BEAM
Date: August 21st . 2000
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MINERVA A. BEAM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- 5150 CIVIL TERM
RICHARD V. BEAM,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, 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 Prothonotary's
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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: August 21st ,2000
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MINERVA A. BEAM
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