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HomeMy WebLinkAbout00-06564 j-~' " ,;~" ' -, ,- ,', . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . STATE OF . . Joseph Pau1 Mattus . VERSUS . Mary Jane Mattus . . AND NOW, . DECREED THAT AND PENNA. No. 00-6564 DECREE IN DIVORCE . . . . . . . . . . . . . . . . . . . it ( ( ~2h#A.; . . December 29 , 2000 , IT IS ORDERED AND Joseph Pau1 Mattus , PLAINTIFF, Mary Jane Mattus , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE ElEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None . J. ~~ PROTHONOTARY . . . -'", ~'< i ,,~,,~>, '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1' -~ - -~-""":, . JOSEPH PAUL MA TTUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA v. : NO. 00-6564 CIVIL MARY JANE MATTUS, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under 330I(c) of the Divorce Code. 2. Date and manner of service of the complaint: September 27,2000 by personal service. 3. (a) Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: by plaintiff December 27, 2000; by defendant December 27,2000. (b) Date of filing and service of teh plaintiff's affidavit upon the respondent: December 28, 2000. 4. No related claims pending. 5. (a) Date plaintiffs Waiver of Notice was filed with the prothonotary: December 28, 2000. (b) Date defendant's Waiver of Notice was filed with the prothonotary: December 27, 2000. ~lCJ2~!: . Metz, Esq. Attorney for Plaintiff !.D. No. 32958 214 Pine Street Harrisburg, PA 17101 (717) 232 - 0879 , ,,^",--:,'......,J....- ~'~'~~ ~'I' y"~"" - .'~';~I~Br'<!~ . ~~ .- d,_. "=,<-"<",, - . ,<"~,.-" ~ -~;" :1 ~:.':..' ~I:I 'II \1 il ,:,1! I'll ~ II III " ~ J j I 0 0 () c C.;J ~ :?o: -c:::J -0"" ;'q fTlr"17; " --c:::-.~Ti Z::c 1'-- zr- '" . ~ ~'~2 l.O -"-, :~( r::: c :;PiL' ~::::; ~ 3> -H z c:; -.- \t': ('5 ~C) q rn ~c :z: '"," 0 ~~ =< ,~ -...! ,< . "~" N "l <-.;.'\ . IL",'1iC: ." JOSEPH PAUL MA TTUS, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA .:if OOv 65(/1 Cro\ \ MARY JANE MATTUS, Defendant IN DIVORCE NOTTCE TO DEFEND 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 without you and a decree of 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, Cumberland County Courthouse, Carlisle, PA. 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. OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-1311 =~. . " JOSEPH PAUL MATTUS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NUMBER (h) - (,,51.'( ~ ~ vs. MARY JANE MATTUS, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is JOSEPH PAUL MATTUS, who currently resides at 8 Holly Drive, New Cumberland, County of Cumberland, Pennsylvania, since 1993. 2. Defendant is MARY JANE MATTUS, who currently resides at 8 Holly Drive, New Cumberland, County of Cumberland, Pennsylvania, since 1993. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on March 25, 1993, In Harrisburg, County of Dauphin, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States of America or any of its Allies. ,"', . ' ~ ~'liMr' ," 'll:1 "".~-~@,;\ 9. After ninety (90) days have elapsed from the date of service of this Complaint, plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of service of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. I verifY that the statements made in this Complaint 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: ((7- 1Cb ~n Attorney for Plaintiff - ID No.32958 214 Pine Street Harrisburg, P A 1710 1 (717) 232-0879 2 -,"""". ,W..03- , ' JOSEPH PAUL MATTUS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NUMBER MARY JANE MATTUS, Defendant IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE I, Plaintiff herein, do hereby depose and say that I am advised and believe that the above-named Defendant is not presently in the active military service of the United States of America and I aver that the Defendant is not a member of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and is not an officer of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor is Defendant engaged in any military or Navy units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service; nor has Defendant, to the best of my knowledge, enlisted in the military service covered by this act. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. I verify that the statements made in this Affidavit 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. 117- V /(p DA ( . JOSEPH PAUL MATTUS, Plaintiff vs. MARY JANE MATTUS Defendant ',' .. . -~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NUMBER IN DIVORCE I accept service of the ACCEPTANCE OF SERVICE . I certifY that I am authorized to accept service on behalf of defendant. Date Defendant or Authorized Agent Mailing Address '=~"I!ril!i!iWii! ~I" , . . ~,' ~__ , n ___ JOSEPH PAUL MATTUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6564 CIVIL MARY JANE MATTUS, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on September 27, 2000. 2. The marriage of teh Plaintiff and Defendant is Irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to the unsworn falsification to authorities. Date: 11--l'1-t/t~ {; I / ). .1 , .,-,- ~o~~~"",,,,'~~~""~-~ , ><~'''tWl<l'-j_!<~;~~~~il:ii '., ,~.b".....,_~ -1111l!i~ >~ ~~,~. .>..y, I [' 0, r I 0 0 ~) C C) " ~~: 0 92 ~.~;~ , 1; C") 1:,~ ZC f'I-,) ~~ 7 t:-.; ~~r:: <D ;~~ ~'-'C' ;E-;: '~ ~o ....,.;;,. ",~O --C) co c:;rn Pc:::. Z :.n ::r.;1 =< SJ c:> -< JOSEPH PAUL MATTUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-6564 CIVIL MARY JANE MATTUS, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQTJEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to the unsworn falsification to authorities. Date: I ')--./?-7--./60 " , _,' '~'I:&li.J Jldil~(j -- , - -~,~. .~. ~ ~~~~~"""-- ~' - '" -" .' " ~ > L~~ ,.j' ", ",~,< ',~>, , , - .~ -' ~, ~~ .", o ~;; -oC:, rnpl ~~. <C) -'>C,' ~(~ ;Doe:: :z: ::;2 ., (:) C5 c:> ,-,. n r-.:> 1.,0 ~- .~" I I , 11 II II' ,. ii! !1 [I ,I I !I :1 'I Q " '? :.n ():) ;II m ~? Q :,~-n ",;i'C) :~in -",. :0 -< '-<~,,,,i1 r'-'~'~'_~_' ._ ~ ..;.1 ' , ." " . >"";';'~""'l', j JOSEPHPAULMATTUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6564 CIVIL MARY JANE MATTUS, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on September 27, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. . 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CoSo 94904 relating to unsworn falsification to authorities. Date: /)e{.pmW;1'7. aOoo , ~('\\n.rl-vD MARY J S DEFE ~~~~w..J'~~Jij ar-lI~;,@it-';~~J!ji~h!<f;~i-'~"'~W<"l.JJI -~~~~ """""'" o c ~ -On:' 9)r~', ffj ,S: ;5c;~',,~ <:: ~,' p 2(; '>Co -c: z :~ 1"1 \j h I I II II ~ ~ EI II 11 I I ,::::-) a CJ "" ,"") "'" co :-) "in') :'-, y :-';r:) :-"!', ,~Xf;f " " ~ c.:. SJ -< ).:,. ~9 :.....) (;:) ~ ' ~ lMI '---' ~~ - - =,<. \; JOSEPH PAUL MATTUS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00-6564 CIVIL MARY JANE MATTUS, Defendant : CIVIL ACTION - LAW. : IN DIVORCE WAIVER OF NOTICE OF Th'TENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CoSo ~4904 relating to unsworn falsification to authorities. Date: fJf1!pmW in, dooe =~~ N\nXLJ) MARYJANEMA TUS DEFE A1 1 ~~~illir"bE;jtjj{ii~~~'~~~~j\~iW'f!il"k,['j.H,j\{.~,:,~~j' ,"-~~=-.;. -~~1l:0:f~iiit.aE.,","" '-'$iiiMi' - ,~ , ~. o C <:"~ -of0 n-lr,'] Z:J) 7"::C' ~~2~ ~C:' J>.r.... ~O ;DoC Z _I -< ,,' [, i' I', :,' , r I o (..:::I r.:J '-'1 C~ f'-':) CD _J ';l --,ri :"? ,.", ...,- ':::i", :..c'~ :n '-:..~;:C') !:5iT'l i~ SJ -< :;::,".";1 :r: ...0 ,:..,.) {:::> I - . ~ ".' JOSEPH PAUL MATTUS, Plaintiff vs. MARY JANE MATTUS Defendant '., . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NUMBER 00 -(p':f&,i-/ CIVIL IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Comol.1mJ. In /)m/('(:.tJ. I certifY that I am authorized to . accept service on behalf of defendant. 9-q F -()(J Date ';:j",,-~ff,?,.';-:;s<,;:-t:c';V\~;?!~ &~{U~;d~e~ Jennifer L. Lehman, Esquire 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112 Mailing Address - ' ...,~..;,.- ~ .Jj-j ~~ t,'J' ~ .' :;,1 I: ~\, r f~ ~,1 I t! ~,! ti ~1 r:'i ~I Jl ~ .' ~] ~ ~i Iii' :~ >1 :A ;! :i , ~ ~ 1 l1 , ~ , :~ ,I ,',' ~ , #; i i t ~ 1~ fr), ~ ,~! ~ ~I , I, " ' ' ~~~~!~~~~~il!k;j~~l3ilf:~Jt:u'''''~~- . ^. ,-~" , ~ ~Ilr ~,~-""""" - . .." .' 0 c) CJ s:; 0 ~ ~ d1~r C) Z" -l Zl,~ en _"_;';; G' ~~ ==i'~' z'-~. 5>2 t;>? :z: );,: =< ~ :n -< ~;tiZA(ij~10_tif~~~~ - ~". , " '. '''' ,",,'~--',~-,,; "i_ ~,C,~; ,,,,;,,',^,;c~.,,__--" ,"C ~"'. """=~1'jj;[~ I DB NESTleO, DROOl &, HILDABRAND, LLP ATTORNEYSAT LAW 840 East Chocolate Avenue, Hershey, PA 17033 Phone (717) 533-5406 I:ax (717) 533-5717 October 18, 2002 Curt Long, Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 RE: Lindsey v. Lindsey Docket No. 00-6544 Dear Mr. Long: On April 17, 2002 I filed Plaintiff's Motion to Compel discovery in the above rnatter. I enclose herewith a proposed Order together with self- addressed starnped envelopes for distribution thereof. If anything further is required please advise. Please forward this to the Court Adrninistrator for assignment to a Judge. Thank you. Very truly yours, NESTIC , DRUBY & HILDABRANlt LLP .---; f :mlp Enclosure cc: Kevin Prosser, Esquire ~.... , -"^"~~'-~., OCT .2 3 2~(, BONNIE L. LINDSEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6544 CIVIL GERALD A. LINDSEY, Defendant : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE ORDER AND NOW, this _ day of ,2002, upon consideration of Plaintiff s Motion to Compel Discovery, said Motion is GRANTED. Defendant is directed to provide full and complete responses to Plaintiffs First Set of Interrogatories and First Request for Production within _ days of the date of this Order or suffer the entry of sanctions. J , ~ ~ , ,', '- ~ ~ J ~"""~" OCT 2 3 211G2 BONNIE L. LINDSEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6544 CIVIL GERALD A. LINDSEY, Defendant : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE ORDER AND NOW, this _ day of , 2002, upon consideration of Plaintiffs Motion to Compel Discovery, said Motion is GRANTED. Defendant is directed to provide full and complete responses to Plaintiff s First Set of Interrogatories and First Request for Production within _ days of the date of this Order or suffer the entry of sanctions. J .-.1... =. ~,,~ BONNIE L. LINDSEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6544 CIVIL GERALD A. LINDSEY, Defendant : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE ORDER AND NOW, this _ day of , 2002, upon consideration of Plaintiff's Motion to Compel Discovery, said Motion is GRANTED. Defendant is directed to provide full and complete responses to Plaintiff s First Set of Interrogatories and First Request for Production within _ days of the date of this Order or suffer the entry of sanctions. J.