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HomeMy WebLinkAbout01-1462 FX .. , . , KELLY A. MELEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 0/- /4(,,^, CllJ;CT~ JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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 fuil to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. Ajudgment 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 that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of marriage counselors is available in the Office ofthe Prothonotary at the Cumberland County Courthouse, Carlisle. 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 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 LA WYERAT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 717-249-3166 - c L ~. .' "",,' "' , '~ .' ~ " . KELLY A. MELEEN, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA ; NO. OJ. /,-/(p-;)... ~ --r~ JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, KELLY A. MELEEN, by and through her counsel, Kollas and Kennedy, and respectfully represents as follows in support of the within Complaint: 1. Plaintiff is Kelly A. Meleen, an adult individual currently residing at 600 Bridge Street, New Cwnberland, Cwnberland County, PA 17070. Plaintiff's Social Security Nwnber is 194-60- 6930. 2. Defendant is James G. Meleen, an adult individual currently residing at 8 Umberto Avenue Rear, New Cwnberland, Cwnberland County, P A 17070. Defendant's Social Security Nwnber is 071-50-2089. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 11, 1996, in Sugar Grove, Peunsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. ,I ~, L '"' , , '''. ,,'.~', --, " .' , '. , . , 7. Plaintiff and Defendant are both citizens of the United States. COUNT I - DIVORCE PURsUANT TO 63301(c) OR (d) OF THE DIVORCE CODE 8. Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. The marriage of the parties is irretrievably broken. WHEREFORE, the Plaintiff prays that a Judgment and Decree be entered as follows: \':;' (a) As to Count I, that a decree be entered divorcing Plaintiff from the bonds of matrimony with the Defendant pursuantto 23 Pa.C.S. Section 3301 (c) or (d). RESPECTFULLY SUBMITTED, Mary Ko s ennedy, Esquire J.D. No. 46 KOLLAS AND KENNEDY 1104 Femwood Avenue, Suite 104 Camp Hill, Pennsylvania 17011 Telephone: (717) 731-1600 ATTORNEY FOR PLAINTIFF DATE: 3 \ ~1..,1 0 \ 2 ,-~ ._~ 'N' "," ~ .;".."," . .~ ' ,'~ .' , KELLY A. MELEEN, Plaintiff :' IN THE COURT OF COMMON PLEAS OF :1 CUMBERLAND COUNTY, PENNSYL VANIA v. " : NO. JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, KELLY A. MELEEN, verifY that the statements made in the foregoing COMPLAINT are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made su~ect to the penalties of 18 Pa. C.S.A. 4904, relating to unswom falsification to authorities. BY:~.R (lQ ~A ncJl " 0 JA-l Ke yA.Mee n DATE:~-n--D\ >~ " l. , . ~ " " , , .'''' -+ 'n':, , . . KELLY A. MELEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1462 Civil Term JAMES G. MELEEN, 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: 1. Ground fur adivor<Je: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint:03/16/0 1 Certified mAil restricted deliverv 3. Complete either paragraph (a) or ~). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff 07/06/0 1. by t\1e Defendant 06/30101. (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: I (2) Date of service of the plaintiff's affidavit upon the Defendant: 4. Related claim pending: None. 5. Complete either (a) or (b) (a) Oate and manner of service of the notice of intention to file praecipe to transmit record, a copy ofwbich is attached, if the decree is to be entered under Section 3301 (d) of the Divor<Je Code: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary 07/10/01. Date Defendant's Waiver of Notice in Section 3301(c) was with the Prothonotary 07/1 0/01. Date:M-w- Mary Ko nnedy, Esq . Attorney fur the plaintiff ''">' " 'J ",', ~', .. , KELLY A. MELEEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-1462 Civil Term JAMES G. MELEEN, Defendant CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE i r . Complete Items 1, 2, and 3. AlSo 'complete item 4 if Restricted Delivery is desired, . Print your name and address on the r.everse so that we can return the card to you. . Attach this card to the back of the mall piece, or on the front If space'permits. 1. Article Addressed to: o Agent o Addressee D. delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 'To.me.s a. f{WJ-LLV\ ~ l..,lrn'ou'-\tl (A.u-t.D\..UL.- 'RR..w- NQMJ u..l.xnWlD.rdJ PA- nOlO 3. Service Type lil Cenlfled Mail D Express Mail o Registered ~Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (CoPY, from service labeQ , 0- '.:JCO{) Of-o~i OC),*1 ~~ 1* ' ,,34> PS Form 3811, JUly 1999 'noni...!;; Return Receipt 102595-00.M-0952 BY: Date: D\ \ ~ \ 0 I ennedy, Esquire KOLLA! D KENNEDY 1104 Fernwood Avenue Suite 102 Camp Hill, PA 17011 (717) 731-1600 Attorney for Plaintiff ~.J..J." I ,- - '. .. 'L'~'~, C '"'~ ~' ~. . I, KELLY A. MELEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 01-1462 Civil Term JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301(c) or (d) of the Divorce Code was filed on March 13, 2001, and was served upon the Defendant on or about March 16, 2001. The Proof of Service was filed on March 21, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date offiling the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division ofproperty, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 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. S4904 relating to unsworn falsification to authorities. DATE: l}I..P!Ol I I ~A~^ Kelly Mel ,,' ,~ " ..... ' ,-'~, ~~ '",;; :,i, '" ".,' _ . k~ ,', ~ l< .... . , KELLY A. MELEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1462 Civil Term JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) OR Cd) OF THE DIVORCE CODE 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 ifl 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 ofthe 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. ~4904 relating to unsworn falsification to authoritie~. 1<~~INU Kelly . Me DATED: 1 ) (; / 0 I , , ,'" ~..~ . On' - " >~..,;: . . KELLY A. MELEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1462 Civil Term JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) or (d) of the Divorce Code was filed on March 13, 2001, and was served upon the Defendant on or about March 16,2001. The Proof of Service was filed on March 21, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division ofproperty, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 ofI8 Pa. C.S. ~4904 relating to unsworn falsification to authorities. DATE: Co Ir?n / ~ I f' , ,--;., ,,~, ~ ",," ,. ,~ .!, .- KELLY A. MELEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 01-1462 Civil Term JAMES G. MELEEN, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRYOF A DIVORCE DECREE UNDER U301(c) OR Cd) OF THE DIVORCE CODE 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 ifl 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 verilY 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 unsworn falsification to authorities. DATED: 0/30/0 I ~ ." ' ,'- "'" ]H""''''' "M,".' "', '.' ~" I. j ,"h"~, i"'",,, L,'.." " .", , ,-p', "\, -;~~::.X)~::.::~;:;:X.:>;:::::~:C~-;:::::~>>:~;::::,.~::~;:)::.::G'{C~::::~_::':::~>>:~;::.}M;.:::::~::C~::)>>:~;::>~::.::~;;:'::~~::.";::,;~~::C~;:.:::~>>,.r:::~::c~:::::::~:c~;::::~~::C~$>.:!;;::~~~~WA~K.~:~'~>>>;:I~!::.::~~:::::~:C~~:;::<".X'<G'r:.1 ~ ' .~ X ~ ~.'~ ~ ~.~ ~ t':: I ~,.~ ~ "~ ~~~ ~ n ~ H, ~ ~ I "'--'- . ,......--::-.." ''''''''''',' n. .",,' ,.,.----:-'...''",..-------::,....,,,..,..,,'',,.....,,"'..,,'',,,,...,.',,.....-:.',...",.;.,~...~ ;;">>:>:;' ).>>::.'" -;.>>:>,:: ''':<+::.''': .:,.::+::.;' .:~...,>;:, ":<.::~:,. ::~.::+::~': :.>>::0::. ::.::c.;;, ,::.:.>;'.:'.::.::~;". x.::~;'" ::.::.>:.. ,,:.:.::~:-. ".>>::.:" '~::.::.'''' '.:.::."-. ,.::....>. "......~". "...~...". "........~",.,~..~..... .....'IJ..... ",......."",.,.......... ..,....... ". ' ..~..."'" ..... ' .' ....', ~.s ~ ."" ~ ~.; ~ ~";~ ~ ~.",' ~.s ~ ,'.> ~.s ~ ~.; ~ ~.s ~ ~";; ~ ~.~ ~ ".", ~ ~.~ ~ ~ W. ~."! "".", ~ ~A ~ ~.~ ~ >"" ~ ~.~ I ~<~ , ~i . j.~ ~ ;'.'~ . t.~ i ~.~ ~.'~ ~ ~ ~.~ ~.~ , ~ ~.~ ~ ~ ~.~ ... , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. u.. I<.~~.r, X. .f..,. ..I:1~~,~J;;.N:,.. mhuhhUU' I II I No. ...1..4..6.:2........... ..2.Q.Ql....}i~ U .., u.!?:!.q:!.nJ:.UJhhhmh.hmh Versus ..uJ~I:1.ES.u~'" I:1E):'EJ;;.~,u Defendant,u DECREE IN DIVORCE AND NOW, . . . . . . . . . . . . .fw7' . . /t( .. " 'f!J.~~(, it is ordered and decreed that . .~~p..y. .~.'. .11~:j.!=.~~. . . .. .. . . . .. . . . . . .. . . . . .. . . ", plaintiff, and . ...:r9.I!l~.~ .G,. .tJj~J.!=.e.n.. . . .. ... . . . . ... .. .. ... . . .. . .. .. . . ", 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; .......................... ..4~.A!-!......................................., . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . By ~~~o//?i u dd.d mm7(mmUm. A..:..,........c?~~.. ______,u ._u_,_____" Prothonotary ';~' ~ ,,~~ ~i ~ .~< ~.s ~ N ~ ."." ;..~ * ~ ~ t~ ~ ~ ~ ~ a ~.~ 8 ~.s * ~.s ~ ~ i ~.~ ~.~ ~ ..' I ~ ~ ~.~ "." ~.; ~ $-:, ~.~ ~ $;.',. ; "'/ ~ ~.~ ~ ~l ~ ~ ~.~ ~ ~.~ w ~.~ ,.~ ~ ~ ~.~ ;..; ~ ~ ~.~ J. ~ '.' ~ ~ '.~ ;ti '.~ ~.~ilir.';;."~""'\ff~'~~~k';;"~ "~J';;;';:'-'y"'_~'o""""~'i---ol~~~oiNi:il"-"d ,;L' '~,'. M'"O' --- ~. .~,~ ~ ~~ fj~ r ~ ~~l -r; ~LP ":,-';''''; 4." t, < . , ~ /1?'7~C::t... JO/J('L " ., ~", J" ..