HomeMy WebLinkAbout01-05272,.u~.~ _ _ _. f.l . _
ANDREW G. FAIDLEY
vs.
KATHLEEN A. MACKAY
Plaintiff .
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,/PENNSYLVANIA
NO. UI ' Spa 70~ l.:lc.>~(,~El~-.1'"1
CIVIL ACTION -
Defendant
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 in the Office of the Prothonotary, Cumberland
County Courhouse, 1 Courthouse Square, Carlisle,
Pennsylvania.
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.
COURT ADMINISTRATOR
Cumberland County Courthouse
4th Floor, Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
ANDREW G. FAIDLEY,
Plaintiff
V.
KATHLEEN A. MACKAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, n/PENNSYCL__V_A_NIA
CIVIL ACTION-DIVORCE
COMPLAINT IN DIVORCE
COUNT N0. 1
1. The Plaintiff is Andrew G. Faidley who currently resides
at 10 Marshall Drive, #I-O1, Camp Hill, Cumberland County,
Pennsylvania.
2. The Defendant is Kathleen A. Mackay who currently
resides at 1904 Paces Landing Avenue, Rock Hill, South Caroline
29732.
3. Plaintiff has been a bona fide resident of the
Commonwealth of Pennsylvania for at least three (3) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant are both citizens of the
United States of America.
5. The Defendant is not a member of the Armed Services of
the United States or any of its allies.
6. The Plaintiff and Defendant were married on May in
Benton County, Arkansas.
7. There have been no prior actions of divorce or annulment
between the parties.
8. The marriage is irretrievably broken.
9. Plaintiff has been advised of the availability of
counseling and that the Plaintiff may have the right to request
that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff requests the Court to enter a
Decree:
(a) Dissolving the marriage between Plaintiff and
Defendant;
PANNEBAKER AND JONES, P.C.
Attorneys for Plaintiff
Dated: / 0 By:
Peter R. Hen finger, ., Esquire
I.D. #44873
4000 Vine Street
Middletown, PA 17057
Telephone: (717) 944-1333
_ ~.a. u., 1-L
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VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalty of 18 Pa. C.S.A. X4904, relating to unsworn
falsification to authorities.
Andrew G. Fai , P aintiff
:sls FAIDLEY DIVORCE
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ANDREW G. FAIDLEY,
Plaintiff
V.
KATHLEEN A. MACKAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~~- 5'~~I~ ~I vI ~ Tt'I"Yri
CIVIL ACTION-DIVORCE
PROOF OF SERVICE BY CERTIFIED MAIL
I, Peter R. Henninger, Jr., Esquire, of the law firm of
Pannebaker and Jones, P.C., being duly sworn according to law,
deposes and says that he did serve a copy of the Complaint in
Divorce in the above-captioned matter, filed on behalf of Andrew
G. Faidley, to the above term and number on the 11th day of
September, 2001, by mailing a copy of said Complaint in Divorce
by Certified Mail, Return Receipt Requested, to the last known
address, that being: 1904 Paces Landing Avenue, Rock Hill, SC
29732. The original Return Receipt, as well as the receipt for
Certified Mail No. 70993400001548929495 are attached evidencing
the delivery of the above referred Complaint in Divorce.
Date: ~~/~j 2001
SWORN and subscri ed to
before~%r~~]],~,~vve,,~~t~~his day
o f GIC~Ti'6vtAP\ ~, 2 0 01
-°Not~ry Pub11C
:51s FAS EY PROOFOFSERVICE
PANNEBAKER & JONES, P.C.
Attorne~for P lntiff
BY ~ /i~' ~' Lfl.I~
Peter R. Henninger, fir., Esquire
I.D. #44873
4000 Vine Street
Middletown, PA 17057-3596
Telephone: (717) 944-1333
NOTARIAL SEAL
STACEY L. SECHLER, Notary Public
Middletown, Dauphin Counly
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or on [he front if space permits,
1. Article Addressed to:
ItATIi~EEN A. i~ittCriiiY
1901+ Paces Landing Avenue
Rock Hill, SC 29732
by
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4. Restricted Delivery? (E#ra Fee) ^ yes
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ANDREW G. FAIDLEY, IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY,PENNSYLVANIA
V. NO. 01-5272
KATHLEEN A. MACKAY, :CIVIL ACTION- DIVORCE
Defendant
CERTIFICATE OF SERVICE
I, Courtney L. Kishel, Esquire, hereby certify that I have served a true and correct
copy of the Preliminary Objections to Plaintifi's counsel via United States certified mail
this 13~' day of December, 2001 addressed to:
Mr. Peter R. Henninger, Jr., Esquire
Law Offices of Pannebaker and Jones, P.C.
4000 Vine Street
Middletown, Pennsylvania 17057-3596
Attorney ID# 8
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ANDREW G. FAIDLEY, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V.
KATHLEEN A. MACKAY, :CIVIL ACTION- DIVORCE i
Defendant Q/-Sa~~ C,~r~
COURT ORDER
AND NOW, this _ day of November, 2001, after due consideration of
Defendant's Preliminary Objections To Plaintiff s Divorce Complaint In The Nature Of
A Motion To Dismiss, IT IS HEREBY ORDERED AIsII} DECREED THAT, the
Plaintiff s Complaint in Divorce is hereby dismissed for failing to comply with the
provisions of Pa.R.Civ.P. 1920.12.
J.
ANDREW G. FAIDLEY,
Plaintiff
V.
KATHLEEN A. MACKAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENN5YLVANIA
. NO.
CIVIL ACTION- DIVORCE
DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAII~TTIFF'S DIVORCE
COMPLAINT IN THE NATURE OF A MOTION TO DISMISS
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AND NOW, this ~ day of November 2001, comes the defendant, Kathleen A.
Mackay, by and through her attorneys, Courtney L. Kishel, Esquire, and The Law Offices
of Richard C. Gaffney, and respectfully requests this Honorable Court to dismiss
plaintiff's divorce complaint, and in support thereof, avers the following:
1. Plaintiff, Andrew Faidley, filed a divorce complaint in Cumberland County on
September 7, 2001.
2. Defendant, Kathleen Mackay was served a copy of the divorce complaint via
certified mail, on September 27, 2001.
3. The divorce complaint avers that Defendant is a resident of South Carolina.
Defendant Mackay admits that she resides at 1904 Paces Landing Avenue, Rock
Hill South Carolina 29732.
4. Ms. Mackay has in fact never resided in Pennsylvania.
5. The parties last resided as husband and wife in South Carolina.
6. The divorce complaint further avers that Plaintiff Faidley has "been a bona fide
resident of the Commonwealth of Pennsylvania for at least three (3) months
immediately previous to the filing of this Complaint."
Accordingly to Pa.R.Civ.P. 1920.12, a divorce complaint must aver that either
party is a bona fide resident of the Commonwealth of Pennsylvania for at least six
(6) months immediately prior to the commencement of action.
Plaintiff has not averred that either party has been a bona fide resident of the
Commonwealth for at least six (6) months immediately previous to the
commencement of the action.
9. The divorce complaint fails to aver the necessary period of residence and is
therefore void for failing to comply with the provisions of Pa.R.Civ.P. 1920.12.
10. Ms. Mackay subsequently filed a divorce complaint in South Caroline on October
19, 2001. Mr. Faildley was subsequently served a copy via certified mail.
11. A heazing is temporarily scheduled for November 28, 2001 on that matter.
WHEREFORE, the Defendant respectfully requests this Honorable Court to
dismiss the divorce complaint in Cumberland County since Plaintiff failed to comply
with the provisions of Pa.R.Civ.P. 1920.12, and permit the divorce to proceed in South
Carolina where personal jurisdiction exists.
Respectfully Submitted,
Law Offices of Richard C. Gaffney
5~~~
Courtney L. e , squire
PA Supreme C ID# 81509
2120 Market Street, Suite 101
Camp Hill, PA 17011
975-9033
11/2613001 16:35 6033291189 D.S. N~LYfA~EiSC PAGE 01
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I verify that the siataneats trade is this complaint are true and correct. I
ioadeist~d that fal~ statenuttts hereia are made sulrjerct to tlu; penalties off 8
Pa.C.S.A. §49Ef4, refatiag to tayswom falsification to aatharities.
Date ~9~ 3Cy .so61 l~a~ er_ ~~1".r~,~~
lt:athleen A. Mackay
dw "a,~ h`~r "33fiPdc.<~~s ~ .d;~masti. z. ` . --tea.,., B~
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ANDREW G. FAIDLEY, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V.
KATHLEEN A. MACKAY, :CIVIL ACTION- DIVORCE
Defendant
COURT ORDER
AND NOW, this _ day of November, 2001, after due consideration of
Defendant's Preliminary Objections To Plaintiff's Divorce Complaint In The Nature Of
A Motion To Dismiss, IT IS HEREBY ORDERED AND DECREED THAT, the
Plaintiff's Complaint in Divorce is hereby dismissed for failing to comply with the
provisions of Pa.R.Civ.P. 1920.12.
J.
ANDREW G. FAIDLEY,
Plaintiff
V.
KATHLEEN A. MACKAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
. NO.
CIVIL ACTION- DIVORCE
COMPLAINT IN THE NATURE OF A MOTION TO DISMISS
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AND NOW, this2? day of November 2001, comes the defendant, Kathleen A.
Mackay, by and through her attorneys, Courtney L. Kishel, Esquire, and The Law Offices
of Richazd C. Gaffney, and respectfully requests this Honorable Court to dismiss
plaintiff's divorce complaint, and in support thereof, avers the following:
1. Plaintiff, Andrew Faidley, filed a divorce complaint in Cumberland County on
September 7, 2001.
2. Defendant, Kathleen Mackay was served a copy of the divorce complaint via
certified mail, on September 27, 2001.
3. The divorce complaint avers that Defendant is a resident of South Cazolina.
Defendant Mackay admits that she resides at 1904 Paces Landing Avenue, Rock
Hill South Cazolina 29732.
4. Ms. Mackay has in fact never resided in Pennsylvania.
5. The parties last resided as husband and wife in South Cazolina.
6. The divorce complaint further avers that Plaintiff Faidley has "been a bona fide
resident of the Commonwealth of Pennsylvania for at least three (3} months
immediately previous to the filing of this Complaint."
~.
7. Accordingly to Pa.R.Civ.P. 1920.12, a divorce complaint must aver that either
party is a bona fide resident of the Commonwealth of Pennsylvania for at least six
(6) months immediately prior to the commencement of action.
8. Plaintiff has not averred that either party has been a bona fide resident of the
Commonwealth for at least six (6) months immediately previous to the
commencement of the action.
9. The divorce complaint fails to aver the necessary period of residence and is
therefore void for failing to comply with the provisions of Pa.R.Civ.P. 1920.12.
10. Ms. Mackay subsequently filed a divorce complaint in South Caroline on October
19, 2001. Mr. Faildley was subsequently served a copy via certified mail.
11. A hearing is temporarily scheduled for November 28, 2001 on that matter.
WHEREFORE, the Defendant respectfully requests this Honorable Court to
dismiss the divorce complaint in Cumberland County since Plaintiff failed to comply
with the provisions of Pa.R.Civ.P. 1920.12, and permit the divorce to proceed in South
Carolina where personal jurisdiction exists.
Respectfully Submitted,
Law Offices of Richard C. Gaffney
Courtney L. e , squire
PA Supreme C ID# 81509
2120 Market Street, Suite 101
Camp Hill, PA 17011
975-9033
11l26J2001 15:35 8033291189 D.S. hOLLYCtEpC PAGE 01
a~uv ~.s v• ..~. ...~~ ... _.._. _ ... _.
vEiu>~cnrialy
I verify that tha statemenu made iu this complaint arc true and correct. I
understand that false statements herein are made subject to the penalties of I8
1'a.GS.A. §4904, relating m unswom falsification to authorities.
Date ~~L,...t<~ IX~~ ~_ ~7°~Q~
Kathleen A. Mackay
.~ ti
ANDREW G. FAIDLEY, :1N THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V.
KATHLEEN A. MACKAY, :CIVIL ACTION- DIVORCE
Defendant
COURT ORDER
AND NOW, this _ day of November, 2001, after due consideration of
Defendants Preliminary Objections To Plaintiff s Divorce Complaint In The Nature Of
A Motion To Dismiss, IT IS HEREBY ORDERED AND DECREED THAT, the
Plaintiffs Complaint in Divorce is hereby dismissed for failing to comply with the
provisions of Pa.R.Civ.P. 1920.12.
J.
ANDREW G. FAIDLEY,
Plaintiff
V.
KATHLEEN A. MACKAY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
. NO.
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:CIVIL ACTION- DIVORCE n
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AND NOW, this 27 day of November 2001, comes the defendant, Kathleen A.
Mackay, by and through her attorneys, Courtney L. Kishel, Esquire, and The Law Offices
of Richard C. Gaffney, and respectfully requests this Honorable Court to dismiss
plaintiff s divorce complaint, and in support thereof, avers the following:
1. Plaintiff, Andrew Faidley, filed a divorce complaint in Cumberland County on
September 7, 2001.
2. Defendant, Kathleen Mackay was served a copy of the divorce complaint via
certified mail, on September 27, 2001.
3. The divorce complaint avers that Defendant is a resident of South Carolina.
Defendant Mackay admits that she resides at 1904 Paces Landing Avenue, Rock
Hill South Carolina 29732.
4. Ms. Mackay has in fact never resided in Pennsylvania.
5. The parties last resided as husband and wife in South Cazolina.
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6. The divorce complaint further avers that Plaintiff Faidley has "been a bona fide
resident of the Commonwealth of Pennsylvania for at least three (3) months
immediately previous to the filing of this Complaint "
COMPLAINT IN THE NATURE OF A MOTION TO DISMISS
Accordingly to Pa.R.Civ.P. 1920.12, a divorce complaint must aver that either
party is a bona fide resident of the Commonwealth of Pennsylvania for at least six
(6) months immediately prior to the commencement of action.
8. Plaintiff has not averred that either party has been a bona fide resident of the
Commonwealth for at least six (6) months immediately previous to the
commencement of the action.
The divorce complaint fails to aver the necessary period of residence and is
therefore void for failing to comply with the provisions of Pa.R.Civ.P. 1920.12.
10. Ms. Mackay subsequently filed a divorce complaint in South Caroline on October
19, 2001. Mr. Faildley was subsequently served a copy via certified mail.
11. A hearing is temporarily scheduled for November 28, 2001 on that matter.
WHEREFORE, the Defendant respectfully requests this Honorable Court to
dismiss the divorce complaint in Cumberland County since Plaintiff failed to comply
with the provisions of Pa.R.Civ.P. 1920.12, and permit the divorce to proceed in South
Carolina where personal jurisdiction exists.
Respectfully Submitted,
Law Offices of Richard C. Gaffney
Courtney L. e , squire
PA Supreme C ID# 81509
2120 Mazket Street, Suite 101
Camp Hill, PA 17011
975-9033
_ _ _..... ... .. .,.._.. v..„.w6a~t~:..
11/26/2001 16:35 6033291169 D.S. FgLLYCFECK PAGE 01.
vE><ur+~cnnaly
I verify That the statements made in this complaint arc true and correct. I
undustand that false statements herein eve made sutyect to the penalties of I8
1'a.C.S.A. §4904, relating to unswora falsification to authorities.
Date ~L,...rfy so..1 ~~ .~_ ~~~Q~
Kathle®t A• Mackay
.,
ANDREW G. FAIDLEY, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. 01-5272 CIVIL
KATHLEEN A. MACKAY, : CIVIL ACTION -LAW
Defendant
IN RE: DEFENDANT'S MOTION TO DISMISS COMPLAINT
ORDER
AND NOW, this a 8 ~ day of January, 2002, a rule is issued on the plaintiff to
show cause why the relief requested in the within motion to dismiss ought not to be granted.
This rule returnable ten (10) days after service.
BY THE COURT,
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Hess, J.
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ANDREW G. FAIDLEY, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. ;'~ -.~2~a
KATHLEEN A. MACKAY, :CIVIL ACTION- DIVORCE
Defendant
COURT ORDER
AND NOW, this _ day of January, 2002, after due consideration of
Defendant's Preliminary Objections To Plaintiffs Divorce Complaint In The Nature Of
A Motion To Dismiss, filed pursuant to Pa.R.Civ.P 1028 (a)(2), Defendant's foregoing
Motion to Dismiss, and after a review of the record in this case, IT IS HEREBY
ORDERED AND DECREED THAT, the Plaintiff s Complaint in Divorce is hereby
dismissed for failing to comply with the provisions of Pa.R.Civ.P. 1920.12.
J.
ANDREW G. FAIDLEY,
Plaintiff
V.
KATHLEEN A: MACKAY,
Defenalant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
NO. 01-5272
CIVIL ACTION- DIVORCE
DEFENDANT'S MOTION TO DISMISS COMPLAINT
AND NOW, this 7`h day of January 2002, comes the above-named Defendant, by
and through her attorneys, Courtney L. Kishel, Esquire and The Law Offices of Richard
C. Gaffney, and respectfully requests This Honorable Court to dismiss the above-
captioned action, and in support thereof avers the following:
1. On September 7, 2001, plaintiff, Andrew Faidley filed a divorce complaint in
Cumberland County.
2. The divorce complaint averred that plaintiff was a bona fide resident of the
Commonwealth of Pennsylvania for at least three (3) months prior to filing the
complaint.
3. According to Pa.R.Civ.P. 1920.12, a divorce complaint must state "an averment
that the plaintiff, defendant or both have resided in the Commonwealth for at least
six months immediately previous to the commencement of the action."
4. Accordingly, the divorce complaint filed by plaintiff was deficient on its face for
failing to comply with Pa.R.Civ.P. 1920.12.
5. On November 27, 2001, defendant, Kathleen Mackay, filed Preliminary
Objections to Plaintiff s Divorce Complaint In the Nature of a Motion to Dismiss,
stating that the plaintiff failed to comply with Pa.R.Civ.P 1920.12.
6. The preliminary objections were filed pursuant to Pa.R.Civ.P 1028 (a)(2), which
states that preliminary objections maybe filed for "failure of a pleading to
conform to law or rule of court..." Pa.R.Civ.P.1028(a)(2).
7. Accordingly, under Pa.R.Civ.P. 1028 (a)(2), a responsive pleading is not
necessary as the Court may rule based on information provided in the record.
8. Opposing counsel, Mr. Peter Henninger, Esquire, was served a copy of the
Preliminary Objections on December 14, 2001. (See Exhibit A).
9. Twenty (20) days have expired from the date of service of Defendant's
Preliminary Objections on opposing counsel, and there has been no response filed
on behalf of Plaintiff.
10. Defendant has properly filed a divorce complaint in South Carolina on October
19,2001, whereupon Mr. Faidley was served a copy via certified mail. Said
action is still pending in the Courts of South Carolina.
WHEREFORE, the Defendant, Kathleen A.Mackay, respectfully requests This
Honorable Court to dismiss the divorce complaint pending in Cumberland County, as
it is deficient on its face for failing to comply with Pa.R.Civ.P 1920.12, and permit
the divorce to proceed in South Carolina.
Respectfully Submitted,
T~hje~L,aw~~Offices of Richazd C. Gaffney
L..CCIJ.Tt' ~~~Si'~~
Courtney L. Kish 1, Esquire
EXHIBIT A
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CERTIFICATE OF SERVICE
I, Courtney L. Kishel, Esquire, hereby certify that I have served a true and correct
copy of the Preliminary Objections to Plaintiff s counsel via United States certified mail
this 7u' day of January, 2002 addressed to:
Mr. Peter R. Henninger, Jr., Esquire
Law Offices of Pannebaker and Jones, P.C.
4000 Vine Street
Middletown, Pennsylvania 17057-3596
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Courtney L. Ki el, Esquire
Attorney ID# 81509
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ANDREW G. FAIDLEY, IN THE COURT OF COMMON PLEAS
Ptaintiff/Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 01-5272
KATHLEEN A. MACKAY, :CIVIL ACTION- DIVORCE
Defendant/Respondent
COURT ORDER
AND NOW, this /r day of February, 2002, after due consideration of
Attorney's foregoing Motion to Dismiss, filed pursuant to Pa.R.Civ.P. 1920.12, and after
a review of the record in this case, IT IS HEREBY ORDERED AND DECREED THAT,
the Plaintiff s Complaint in Divorce is hereby dismissed for failing to comply with the
provisions of Pa.R.Civ.P. 1920.12.
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ANDREW G. FAIDLEY,
Plaintilf/Petitioner
V.
KATHLEEN A. MACKAY,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5272
CIVIL ACTION- DIVORCE
PETITION TO MAKE RULE ABSOLUTE
AND NOW, this 12th day of February, 2002, comes the Defendant, Kathleen A.
MacKay, by and through her attorneys, the Law Offices of Richard C. Gaffney, who
respectfully requests that this Honorable Court grant this Petition to Make Rule Absolute
and in support thereof avers as follows:
On November 27, 2001, the Defendant filed Preliminary Objections to Plaintiffls
Divorce Complaint in the Nature of a Motion to Dismiss for failing to comply
with Pa.R.C.P. 1920.12, which states that a party must be a bona fide resident of
the Commonwealth of Pennsylvania for at least 6 months prior to filing,
2. On January 7, 2002, the Defendant subsequently filed a Motion to Dismiss
Complaint asking this Honorable Court to dismiss the Complaint in Divorce.
3. In January 28, 2002, the Honorable Kevin A. Hess, issued a Rule to Show Cause
on the Plaintiff regarding said Motion to Dismiss, returnable within 10 days of
service.
4. Ten days have passed from the issuance and service of the Rule to Show Cause
and no response to the Rule has been filed by Plaintiff.
WHEREFORE, Defendant, Kathleen A. MacKay, respectfully requests that this
Honorable Court grant her Petition to Make Rule Absolute and Dismiss Plaintiff's
Complaint in Divorce.
Respectfully Submitted,
THE LAW OFFICES OF RICHARD C. GAFFNEY
C
Courtney L. Kis I, Esquire
The Law Offices of Richard C. Gaffney
2120 Market Street
Suite 101
Camp Hill, PA 17011
(717)975-9033
CERTIFICATE OF SERVICE
I, Courtney L. Kishel, Esquire, hereby certify that I have served a true and correct
copy of this Petition to Plaintiff's counsel via United States certified mail this 12a' day of
February 2002 addressed to:
Mr. Peter R. Henninger, Jr., Esquire
Law Offices of Pannebaker and Jones, P.C.
4000 Vine Street
Middletown, Pennsylvania 17057-3596
Courtney L. I
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