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Home My WebLink About00-08147 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~+~~~~~~~~~+~~~~~ . . : IN THE COURT OF COMMON PLEAS : . . : OFCUMBERLANDCOUNTY : . . . . . . : STATE OF PENNA. : . . . . . . . . . . . . . . : MARK M. MELTZER No. 8147 ::>nnn: . . . . . . ~ VERSUS ~ . . . . . . . . . . . . . . . CAROL L. MELTZER . . . . . . . : DECREE IN : . . . . ~ DIVORCE : . . . . . . . . . . . AND NOW, 2003 , IT IS ORDERED AND . . . . . . . : DECREED THAT MARK M. !"IELTZER , PLAINTIFF, : . . . . . . : AND CAROL L. MELTZER , DEFENDANT, : . . . . . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . . . ~ THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE ~ . . . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT . . . : YET BEEN ENTERED; None. : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;:; ATTES ~ J. ~ ~ iJtlA'._ ~ . PROTHONOTARY . . . . . ~ "- J + ~~++~+~++++~~~ ~~~~~~~++~+~~~~~~~~~+~~~+~~~~~~~~+~~~~++~+~~~+~~+~~+~~~+~~~~~+~ , MARK M. MELTZER, Plaintiff : IN THE eOURT OF eOMMON PLEAS OF : eUMBERLAND eOUNTY, PENNSYLVANIA v. : eIVIL AenON - LAW : IN DIVOReE eAROL 1. MELTZER, Defendant : NO. 00-8147 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the eourt for the entry of a Decree of Divorce. I. Ground for divorce: irretrievable breakdown of the marriage under Section 3301(c) of the Divorce eode. 2. Date and manner of service of the eomplaint: the complaint was served on earol L. Meltzer, on November 24, 2000, by certified mail. 3. Date of execution ofthe affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on March 10, 2003; by defendant on February 10,2003. 4. Related claims pending: No economic claims raised. 5. (a) Date plaintiffs Waiver of Notice March 10, 2003, and it is being filed contemporaneously herewith. (b) Date defendant's Waiver of Notice February 10, 2003, and it was filed on March 5, 2003. DATED: 3-IO~ 03 Respectfully submitted, of Counsel BEeKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 171 08 (717)233-7691 MARK M. MELTZER, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND eOUNTY, PENNSYLVANIA v. :eNIL AenON - LAW :IN DNORCE CAROL 1. MELTZER, Defendant :NO. 00 - f/47 Cu~( ~l NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN eOURT. 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 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 connseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary eumberland County eourt House 1 eourthouse Square earlisle, 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 TillS 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 eounty Bar Association 2 Liberty Avenue earlisle, PA 17013 (717) 249-3166 (800) 990-9108 MARK M. MELTZER, Plaintiff :IN THE eOURT OF eOMMON PLEAS OF :eUMBERLAND eOUNTY, PENNSYLVANIA v. :CNIL AenON - LAW :IN DNOReE : 1<4, "/Ll'7 (2~-<...e I~ :NO. ,'v' d , CAROL 1. MELTZER, Defendant COMPLAINT AND NOW comes the Plaintiff, Mark M. Meltzer, who, by and through his attorneys, Thomas A. Beckley, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, ofeounsel, files this Complaint, in which he avers that: 1. Plaintiff, Mark M. Meltzer, is an adult individual residing at 2 Spartan Circle, eamp Hill, eumberland eounty, Pennsylvania 17011. 2. Defendant, Carol L. Meltzer, is an adult individual residing at 600 3rd Street, New Cumberland, Pennsylvania 17070. 3. Both parties were bona fide residents of the eommonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on December I, 1999, in the Bahamas. 5. There have been 110 prior actions in divorce or for annulment between the parties other than the original complaint filed at this docket number. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. COUNT I REQUEST FOR A NO-F AUL T DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs I through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiff s marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that he may have the right to request that the eourt require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.SA 99330I(c) or (d), Plaintiff, Mark M. Meltzer, respectfully requests the eourt to enter a Decree of Divorce. DATED: 1/-- 15-()j Respectfully submitted, of Counsel ~ /' ~. Tho s . Beckley BEeKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 2 VERIFICATION I, Mark M. Meltzer, hereby verifY that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. DATED: 11-/5-c{J ~#i'#/~ Mar . Meltzer I MARK M. MELTZER, Plaintiff :IN THE eOURT OF COMMON PLEAS OF :CUMBERLAND eOUNTY, PENNSYLVANIA v. :CIVIL AenON - LAW :IN DIVOReE eAROL 1. MELTZER, Defendant :NO.00-8147 AFFIDAVIT OF SERVICE I, Elizabeth S. Beckley, being duly sworn according to law, do depose and say: I. I am an adult individual over eighteen years of age. 2. I served the Divorce eomplaint of Mark M. Meltzer upon earol 1. Meltzer, at 600 3rd Street, New eumberland, PA, on November 24, 2000, by certified mail, parcel number 7099 3400 0016 3621 5981, return receipt requested. Attached hereto is the return receipt (green card) signed for by the Defendant. I swear that I have read the foregoing and that it is true to the best of my knowledge, information and belief. Sworn and subscribed to before me this ,;( 1M day of ~0&2000. 1f)a^ 7; ~ Notary~bliC (SEAL) ~~==__~~~~~~~_.~Z>_~"O'_'~_ _____~___~__c II NOTAHIAL. SEAL ; : !\Ili\RY V. DAVlS, Noltill)' PulJllo .,;i I CIIy of Harrisburg Oilllphln Coulliy / 1~.~~m.r~I~~~~!J~I~!:lay 3ll. 2~~! 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 if space permits. 1. Article Addressed to: fns'(}al"'c/L. /Yie./n-e.r &, rro J rd ..s+-~-f ;Veu! C;{..mbe-r/~p1J !t9 l'1c70 , s delivery address different from item If YES, enter delivery address below: 3. ServJ9-e Type Btertified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchancl Dc.O.o. 4. Restricted Delivery? (Extra Fee) 2.",1 rticl~ Number (Copy from service label) 7,:of? ~/# tH/k 3J,.;J / ,,-'If?! PS Form 3811, July 199f Domestic Return Receipt Yes #' 1';;'3f'/ 102595-99-M-1789 MARK M. MELTZER, Plaintiff : IN THE COURT OF eOMMON PLEAS OF : CUMBERLAND eOUNTY, PENNSYL VANIA v. : CIVIL AcnON - LAW : IN DIVOReE eAROLL. MELTZER, Defendant : NO. 00-8147 AFFIDAVIT OF eONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce eode was filed on November 20, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a flllal decree of divorce after service of notice of intention to request entry ofthe 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 penalities of 18 Pa.e.S. 9 4904 relating to unsworn falsification to authorities. Dated: 3 -10 - 03 MARK M. MELTZER, Plaintiff :IN THE eOURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :eIVIL AenON - LAW :IN DIVOReE CAROL L. MELTZER, Defendant :NO.00-8147 WAIVER OF NOnCE OF INTENnON TO REQUEST ENTRY OF A DIVORCE DEeREE UNDER SEcnON 3301 (C)OFTHE 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! 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. 1 understand that false statements herein are made subject to the penalties of 18 Pa.e.S. 1:i4904 relating to unsworn falsification to authorities. Dated: 3 --/0 -03 MARK M. MELTZER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : eUMBERLAND eOUNTY, PENNSYL VANIA v. : CNlL ACnON - LAW : IN DIVOReE CAROL L. MELTZER, Defendant : NO. 00-8147 AFFIDAVIT OF eONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on November 20, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the eomplaint. 3. I consent to the entry of a [mal 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 penalities of 18 Pa.e.S. S 4904 relating to unsworn falsification to authorities. c51ttJ03 t/:,tUtA 0( /JZod,-- Dffie~L /~)~ arol L. Meltzer MARK M. MELTZER, Plaintiff :IN THE eOURT OF COMMON PLEAS OF :CUMBERLAND eOUNTY, PENNSYLVANIA v. :eNIL AcnON - LAW :IN DNOReE CAROL 1. MELTZER, Defendant :NO.00-8147 W ANRR OF NOTleE OF INTENTION TO REQlJEST ENTRY OF A DNORCE DECREE 1ft-mER SECTION 33Q1(C)OF THE I2NORCLCODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I 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 nntil a divorce decree is entered by the eourt and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I v~rify that ia.;.e- statements made in thi~ ~ffi-davit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. ,~// {; / (J _3 Dated: ( 6~?~ ".'.' c~ C;( / . C Carol 1. Meltzer ' In the Court cf Comnon Pleas CUMBERLANDCoun ty, Pennsyl vani a MaTk^1 ^lp It--pr plaintiff flo. 00-8147 ,~ Vs. Caml L. ~1eIt=eT De:endant ;'.:=ID.:'.VIT OF INTE:N'T7:C)~J TO ?':::SC~~'::: F?IOR St:?-~!~E c:Jr~~ot~.~.==;.L r~ OF PE:NNSYL VAlJI.ll.. COCNTY or DAUPHIN CAROL L. ,MELTZER 8einq duly s~c=n cc==rcin~ ~= 12~} de~cses 2~d says that she 15 the DEFENDANr . 1-' 1:1 ,-ne 22CV~-C28tic~ec divorce actic~ in ~hich a final cec~ee f=c~~he ~C~C5 c: ~c~=:rc~y was entered 2~d she hereby elec~s ~~ resume rer c:-i:;= surnane of CAROL 1. KENNEDY 2!"'.C, there::::re. ~lves this w=itten notice avc~lng said i~tention, i~ acco=~ance with H704 0: the he'": of November 15, 1972, P.L. 1063, 54 ;:'2.C.S.A. 704. To , 'Uj;~;(>~(~ I:~:~:W~::", fkt'~P-.Lfr CAROL L. MELTZER Sworn and subscribed to before me thi~~ day of (~ ' dJ)3 ~JlIJJtu,L? 1J~ NOTARIAL SEAL BARBARA E. PALMER, Notary Public Harrisburg. Dauphin County M'J Commission Expires May 23, 2005 . -