The URL can be used to link to this page

Home My WebLink About00-08084 . ' .1-0 _, ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Plaintiff v. NO. fHJ. P1J 't'/.f ~ ..., L-- CNIL ACTION - LAW MARY L YN DIXON, Defendant IN DNORCE NOTICE 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the 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 (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. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENTIS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERAT 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 , ,,-- f T,w- }:i'.....l "~ I... , J J ~,'.~ "fifi'l'fi:,;i i " # IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Plaintiff v. NO. IHJ - 8" lJ P'-l (b:;...d . I..L<-- CNIL ACTION - LAW MARY LYN DIXON, Defendant IN DNORCE COMPLAINT IN DNORCE AND NOW, this 15th day of November, 2000 comes Plaintiff, JAMES SCOTT DIXON, by and through his attorney, Michael J. Hanft, Esquire, and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is James Scott Dixon, who currently resides at 1239 Harrisburg Pike, Room 417, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Mary Lyn Dixon, who currently resides at 4435 Cosey1own Road, Greencastle, Franklin County, Pennsylvania 17225. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on July 25, 1987 in Shreveport, Louisiana. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Sections 3301(c) of the Divorce Code of 1980, as amended. 7. The Plaintiff has been advised ofthe availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling. ,~ # WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, M chael J. Hanft, Es 're Attorney ill No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 L' ,',.-1.- "'i' -.;. , - ;';'~.l..; " . ':,:;, ,.,. 'c.'" " ....~" ..:L '''''' '1~;, ~ VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. F:\User Folder\Firm Docs\Forms\Family Law\Divorce\verification,divorce. wpd - d ..' "<ir~ . . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Plaintiff v. NO. 00-8084 Civil Term CNIL ACTION - LAW MARY LYN DIXON, Defendant IN DNORCE CERTIFICATE OF SERVICE AND NOW, this 28th day of November, 2000, I, Michael J. Hanft, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Divorce filed in the above-referenced matter. The Complaint in Divorce was mailed on November 15,2000, but actual service took place on November 20, 2000, by Defendant signing for a copy of the Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Mary Lyn Dixon 4435 Coseytown Road Greencastle, P A 17225 A copy ofthe signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, ~1"if1 Michael J. Hanft, Esquire Attorney ill No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249-5373 F:\User J;older\FirmDocs\Gendocs2000\1919-1certificate.service,wpd .. . ~ SliNIi'1ER: eJ'\ ';j D Complete items 1 and/or 2 for additional SD~".-r ,;.\1 fA- Complete Jtems 3,- 4a, and 4b ~S \I \ ... [J Pnnt your name and address ~ e f, tl1 can rElturn thIs ~ card to you. ~\.I ! 0 Attach this form to the front of t mmt 01 ~'11 e does not Q) pennlt. .\- ;; 0 Wnte "Retum Rec8/pt Requested" on Iplsce below the article number o The Return Receipt will show to whom the article was delIVered and the da1e 6 delivered. 'l:J 3. Article Addressed to: I mOtULlJrt Dl~ul\ ~ 4"l.rbQ e06elj hJll1fL fJ:&:i Gt1\Qo/wDs.tl-e...) Ut 17~6l S ~ o 'i" 'J{l; I also wish to receive the foUow. ing services (for a:n extra fee): 1. 0 Addressee's Address ~Restricted Delivery 4a. Article Number '7DQq l.f 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise ~ertjfied D Insured DCOD 7. Date of Delivery . - :!UJ-OtJ 8. Addressee's Address (Only if requested and" fee is paid) ~":, / j":,';-':' 102595-99-8-0223 Domestic Return Rec~ ;;. ,; u .~ m '" 1i. "ai' u, m 0:' /.p E ~ 0: '" c ;; " ~ ~ " o >- " c m r. .... ~,",,'," ,,,";"L',--" llLg~n\7''''-- ~G:.'r?"~ ";,, N"~ , 'I" I <l!jilJll"lk~~'lio.r~~{"lli'1likl!.",j;01l.>l\l'j:w:.~~~!6mi~ll:lfl~e~'iiI~~U'"~", " .... . ,~~ >- ,.," o c..::: -:?-,: -r:JC:: plfT' ;:7~:'\:'\ tfj:r" -::., ~,::: <"-' ~2 7": --> -< ~[!X~ . -~-,'" ",:) ,. f~,) t,D ,'.,. - ;--. , ". '" :';1 (.) Ii ~'"" ;.. "Wi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Civil Action - Law Plaintiff v. No. 00-8084 MARYLYNDIXON, Defendant In Divorce ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance on behalf ofthe Defendant in the above referenced matter. , )~n 71]. ~ James M. Stein, Attorney for Defendant Law Offices of William S. Dick 13 West Main Street, Suite 210 Waynesboro, Pennsylvania 17268 (717)762-1160 PABarNo.84026 ~', ,~' ,..; .^' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Civil Action - Law Plaintiff v. No. 00-8084 MARY L YN DIXON, Defendant In Divorce ANSWER COMES NOW Mary Lyn Dixon, the above named defendant, by and through her undersigned attorney, James M. Stein, and for her Answer to the plaintiffs Complaint in Divorce states to the Court as follows: 1. While the defendant admits that the plaintiff is James Scott Dixon, she can neither admit nor deny that he resides at 1239 Harrisburg Pike, Room 417, Carlisle, Cumberland County, Pennsylvania, 17013, for the reason that she has no knowledge of his current address. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. The defendant denies that the marriage is irretrievably broken and hereby requests that the Court order the parties to pursue counseling as set forth in 23 Pa. C.S. 3302(b) and (c). The defendant denies that the marriage is irretrievably broken and instead asserts that the marriage can be saved through proper counseling and effort by both parties. 6. The plaintiffs Complaint failed to include a paragraph 6, therefore no answer is made to such paragraph. ~~~~-~ I~ " ,L '," ""-;' " " , ~,' ' -'," 7. The defendant can neither admit nor deny whether the plaintiff has been advised of the availability of counseling. The defendant does, however, request that the Court order counseling as set forth above. WHEREFORE, the defendant respectfully requests that the Court order the parties to obtain marital counseling through a counselor of their mutual consent or, in the alternative, if the parties cannot agree on a counselor, that the Court order them to participate in counseling sessions with a counselor appointed by the Court. The defendant further respectfully requests that the Court dismiss this action, with costs to the plaintiff. Respectfully submitted, < \~lJJ ~ James M. Stein, Attorney for Defendant Law Offices of William S. Dick 13 West Main Street, Suite 210 Waynesboro, Pennsylvania 17268 (717) 762-1160 PA Bar No. 84026 PROOF OF SERVICE I HEREBY VERIFY that I have served the foregoing document upon counsel of record by depositing one (1) true and correct copy thereofin the United States Mail, postage prepaid, addressed as follows: Michael J. Hanft, Esquire Law office of Michael J. Hanft 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 . /~1. / Date. SIOO J~" Jh- ~ James M. Stein, Attorney for Defendant -2- ~ .'';'';~'''''''''.j~rr'''':; .;"""".....i)i~~~;;ili!t~'dl'i"-fl!#'-'-R-.'P'-,,M.ri,1''''~~!i;~t-'ii,''';*'1:>~~Mli!!Illiiiil_iilllLllI_MMiilfi....-... iii:i;\r ';,,;jrW#lll~IA,,;!iir- , , .,,~ ..~ ~" <>"""""".' 'T (') 0 .<:;i C 0 ;;;: 0 :.-:l '"'0 OJ r"1 ~':; "'T"l ~rrl ("> '''0-- :0 "-0ITl ZS;: I Cf'. ::~J ;:::J ~Z 'S~ kG -u ~o :x -0 1'3 __,-r. )>c <)'" 2~ ~ => SJ (::> -< j; ,.. ~ .I, I',-~-- .~ -- ~ ",' ", --,,~,-- ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Civil Action - Law Plaintiff v. No. 00-8084 MARY L YN DIXON, Defendant In Divorce PRAECIPE To the Prothonotary: Please file the attached Answer in the above referenced matter, and return a time-stamped copy to me in the enclosed self-addressed, stamped envelope. Please contact my office with any questions or concerns you may have. J~() /r). ~: James M. Stein, Attorney for Defendant Law Offices of William S. Dick 13 West Main Street, Suite 210 Waynesboro, Pennsylvania 17268 (717) 762-1160 PA BarNo. 84026 ~'~-~W~W!!:_""""'''''''''5f~m~~~.&Ii0.;;'Ml!**:i.<cl~''''.' Ii'i".~ I'. " ~= ~ ''>'''' .~.', " , o ^' ,_,~ d '.ll"""'. g :s: rRii\ z_c.. zt:,:" C,Q.c:-; .:.<;"- t<C J>Q Zo >c: ~ o o c::> f"1 n I 0'. -0 :x ~ -:::> {:J . iiii~~" ' 'oj",," '.,j ~ --, -1": _,""1\ " '~' I ;:::;.:. -gt~j .~~ ."c:'-(n '~ ~ ~,~ 1. ;, I.., o ';. I- ,,~~'" c. ",~\ i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Civil Action - Law Respondent v. No. 00-8084 MARY L YN DIXON, Petitioner In Divorce NOTICE TO DEFEND AND CLAIM RIGHTS TO: James Scott Dixon 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 wamed that if you fail to do so, the case may proceed without you and a decree of divorce or 31ll1ulment 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Franklin County Courthouse First Floor 157 Lincoln Way East Chambersburg, P A 17201 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. P A Bar Association Lawyer Referral Service (800) 692-7375 (pA only) (717) 238-6715 ~ Q/w.,p,)"} JJ1- ,Cri-".' James M. Stein, Attorney for Petitioner I, ~ ." ~~, 0 . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Civil Action - Law Respondent v. No. 00-8084 MARY L YN DIXON, Petitioner In Divorce COMPLAINT IN DIVORCE COMES NOW Mary Lyn Dixon, defendant in the above styled action, and for her Complaint in Divorce, and by the authority of Pennsylvania Rule of Civil Procedure 1920.15(b), states to the Court as follows: I. The original plaintiff, who is the respondent to this Complaint ("Respondent"), currently resides in Pennsylvania at an address unknown to the defendant. 2. The defendant, who is the petitioner in the present Complaint, is Mary Lyn Dixon ("Petitioner"), who currently resides at 4435 Coseytown Road, Greencastle, Franklin County, Pennsylvania, 17225. 3. The Petitioner and Respondent are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on July 25,1987, in Shreveport, Louisiana. 5. There is currently pending in this jurisdiction and bearing the case number listed above a Complaint in Divorce filed by the Respondent and alleging an irretrievable breakdown in the marriage. .'., -L,'." 1 ~o' 6. The causes of action and sections of the Domestic Relations Code under which the Petitioner is proceeding are 3301(a)(6). (a) The Respondent has offered indignities to the Petitioner, the innocent and injured spouse, by engaging in the repeated use of illegal drugs for the past nine (9) years, despite Petitioner's repeated attempts to keep him from doing so. (b) Section 3301(a)(2). The Respondent has committed adultery continuously from approximately October, 2000 until April, 2001, with Karen Spots. WHEREFORE, the Petitioner respectfully requests that the Court enter a decree of divorce, divorcing Petitioner and Respondent, and for such other relief as the Court deems just and equitable in the premises. Respectfully submitted, J ~ 7h, :5:tz,,'..., James M. Stein, Attorney for Petitioner Law Offices of William S. Dick 13 West Main Street, Suite 210 Waynesboro, Pennsylvania 17268 (717)762-1160 PABarNo.84026 -2- ''"'"'"'' . ,', .,- ~' ',;: VERIFICATION I verify that the statements made in the foregoing 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: S / g )01 Q~0~ ~~ M LynOoixon, Petitioner PROOF OF SERVICE I HEREBY VERIFY that I have served the foregoing document upon counsel of record by depositing one (1) true and correct copy thereofin the United States Mail, postage prepaid, addressed as follows: Michael J. Hanft, Esquire Law Office of Michael J. Hanft 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013 Date: .5 - 9 - 0 I J~ If"') J?7. ~ James M. Stein, Attorney for Petitioner -3- ,--~< ~c~ ,~~^.,~ ~~,1>I,IiIJ~I\Il~~~"B~~~WM..~1,~'i!>!,Jjt>.~(di-ii!iII~i~r.d.iNi6~'fii~lt . ,~ '.lJi!tl -~~~~'1111 ':1 (') C < vcr nlft'j "7_ ~-, ;.?:c_~ CD _ -<-;.. r-c"" ~;:::: ...' ~.;o ...".~ r-' p-..J C Z -~ -<. (;) n ..:or] :!: :;,::;.. :J::l ;c_J,:~ ~-----' "--,-.. ~,~}~ om --I 5; -< -< Cl ~ -~ ~ l?"~ _L , I . . <., -' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Plaintiff CNIL ACTION--LA W vs. : No. 00-8084 MARYLYNDIXON, Defendant : IN DNORCE PRAECIPE To the Prothonotary: Please mark the above-captioned matter as discontinued and dismissed without prejudice. Respectfully submitted, Dated: ~/(~{')'Z" HANFT & KNIGHT, P.C. ~?1f(! Michael J. Hanft, Esquire Attorney ill No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, P A 17013-9142 (717) 249-5373 Attorney for Plaintiff F:\User Folder\Firm Docs\Gelldocs2002\1919-1prw:dpe.discontinue.wpd ~ ,~""" ;"" -,,",' ~ i ,I 1 I ~ , I I , I J J I I , ji ii :,;1?'"NJ;C"""".'~1~"'~"'"" Iill'","'\\i-r"-!llil~~~Hlii!-~N"""",",12il,!ill,~\&~t;,"'~'~,1.bdH$,~ii;ti',,-;,,;j-...,.,.~i!Wllill~~ . 1Il JL'IIl.{"'~ "~r ,~ ......"'..- ~. ~'1IIlO ",~~ "', ~~' Q 0 0 e_ N -n S. :lI: --1 -00::; ""' ~1~ ::D rn lT1 -< ZI .- , ZC -" ':g8 cn~ ;~~(.) ~'" :,,-C) ::? ,~~ j> ZO -"'" 5>3 - Qrn ., -I ~ :- ~ rv '-< . -' " , l' 'I', "~,-~' ^ -", "^;"-,~",;,;-->!-,,~C',,,, i,<'," " M.,,' "'';''-llfu' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES SCOTT DIXON, Civil Action - Law Plaintiff v. No. 00-8084 MARY L YN DIXON, Defendant In Divorce PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark discontinued any and all actions for divorce filed by Mary Lyn Dixon in the above captioned matter. Please contact me at the telephone number listed below with any questions or concerns this may cause you. Respectfully submitted, Date: 5- '1- 02... .J c:.--..q rlJ. ~ James M. Stein, Attorney for Defendant Dick, Stein & Schemel, LLP 13 West Main Street, Suite 210 Waynesboro, Pennsylvania 17268 (717) 762-1160 Pa. Bar No. 84026 PROOF OF SERVICE I HEREBY VERIFY that I have served the foregoing document upon counsel of record by depositing one (1) true and correct copy thereof in the United States Mail, postage prepaid, addressed as follows: Michael 1. Hanft, Esquire Law Offices of Michael 1. Hanft 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 Date: .5 . 9 _ 0 'L J~ 7h. ~ James M. Stein, Attorney for Defendant ~11""' 'j("".'<'-""""""~~~il!?lA~iIill;\,@Ml~~"">i~r",'~~_IiIl!'. , ,-'",~,' I~'I'~- .,,,, .~ ~~~ ,p,' ~'^ ^~ . 0 c::> 0 c:: N 'T1 $:: :JI: :,!,~ ""OCC ;r... ~no --< " ;;g :1: " . ZC '<:::Ifn ~1E w :::Jy ~:~C) ~Ci -;!::!"' ~"j Pc- ':;..',--n Z ~, - hJ('5 )>8 om ~ --, :.n ?;5 .;::- -< tt