HomeMy WebLinkAbout01-05248DOUGLAS A. MELH7S, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION -LAW
2001- 5d`1PCIVIL TERM
FALAFHIA E. MELIUS,
Defeudant 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 maybe 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, 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. II+ 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
AIVIERICAPIS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Ctiunberland County is required by law to comply with
the Americans with Disabilifies 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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DOUGLAS A. MELIUS,
Plaintiff
v.
FALAFHIA E. MELIUS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
tool-~zy~CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(cl
OF THE DIVORCE CODE
NOW comes the plaintiff, Douglas A. Melius, by his attorney, Mark D. Schwartz,
Esquire, and files this complaint in divorce against the defendant, Falaflua E. Melius,
representing as follows:
1. The plaintiff is Douglas A. Melius, an adult individual residing at 227 Station Road, Twin
Rocks, Cambria County, Pennsylvania 14960.
2. The defendant is Falafhia E. Melius, an adult individual whose last known address is c/o
Alberta R. Wlutmer, 10805 Cazlisle Pike, Gazdners, Cumberland County, Pennsylvania 17324.
3. The defendant has been a resident of the Commonwealth of Pennsylvania at least six months
prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on September 27, 1996 in Newville,
Pennsylvania, and sepazated on August 15, 2001.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were two (2) children born to this marriage; namely Brianna H. Melius, born October
28, 1996, age four (4) years, and Douglas D. Melius, bom May 30, 1998, age three (3) years.
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 he 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 mamage between the two
parties.
submitted,
& HUGHES
By:
Mark D. Schwartz, Esquire
Attorney for Plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717)249-2353
Supreme Court I.D. No. 70216
Date: September 5, 2001
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 wrrect 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.
~il~r v ~'V
D UGLAS A. MELIUS
Date: August 21, 2001
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DOUGLAS A. MELIUS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff,
v.
FALASHIA E. MELIUS,
Defendant.
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
N0.2001-5248 CIVIL TERM
IN DIVORCE
DEFENDANT'S .AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 29, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a fmal decree in divorce.
4. 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.
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: ~~ `~' J , 2003 ~.~s~,G-~°'L-~~~'l~
DOUGLAS A. MELIUS
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