HomeMy WebLinkAbout99-04707i
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LISA M. MABIUS,
Plainliff )
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vs.
THOMAS MABIUS,
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-4107 CIVIL TERM
IN DIVORCE
ACCEPTANCE Ot: SERVICE
The undersigned, Thomas Mobius, does hE!reby accept service of the Divorce
Complaint filed against him in this matter and acknowledges receipt of a certified copy
of that Complaint.
Date: / / 000 d
Thomas Mabius /
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LISA M. MABIUS, ) IN THE COURT OF COMMON
Plaintiff 1 PLEAS OF CUMBERLAND
1 COUNTY, PENNSYLVANIA
1
VS. 1 CIVIL ACTION - LAW
1
THOMAS MABIUS, ) NO. 99- 100? CIVIL TERM
Defendant 1 IN DIVORCE
TO THE PROTHONOTARY:
Kindly allow Lisa M. Mabius, Plaintiff, to proceed in fo_ rma oauperis.
I, Samuel L. Andes, attorney for the party proceeding in form a ri , certify that I
believe the party is unable to pay the costs and that I am providing free legal services to
the party. The party's affidavit showing inability to pay the costs of litigation is attached
hereto.
Sa tref L. An es
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12" Street
Lemoyne, PA 17043
(717) 761-5361
LISA M. MABI US , : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
THOMAS _AABI s : NO. 99- CIVIL TERM
llefendant
AFFIDAVIT IN SUPPORT OF PE'T'ITION
FOR LEAVE TO PRO EED IN FORMA pAUpERl
1. I am the Plaintiff in the above matter and because of my financial condition am unable to pay
the fees and costs of prosecuting, defending, or appealing the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of
litigation.
3. I represent that the information below relating to my ability to pay the fees and costs is true and
correct.
(a) Name: bus
Address: lJ l UVl uJU Ql\
(b) Social Security Number: J-9,
If you are presently loyed,state
Employer: K `I `b? S S?
Address: (I( 1 CA P'?
CbXWD 4l
Salary or wages per month:
Type of work: J? I? U
If you are presently unemployed, state
Date of last employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months
Business or profession: ?J1lYl?C
Other self-employment:
Interest: ?a ?Mt
Dividends: VA(-1u,
Pension and annuities: a?
Social Security benefits:
Support payments: cT?(] - (X -
Disability payments: ?bo(A . oo
Unemployment compensation an
supplemental benefits: (I CL
Workman's compensation:
Public Assistance:
Other:
(d) Other contributions to household support
(Wife)(Husband) Name: NN ?,
If your (husband) (wife) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
(e) Property owned
Cash: '
?`l)
Checking Account: 5W ,CV) 06M Savings Account: Y-\,m
Certificates of Deposit: LnkL
Real Estate (including home): 1 \V \A
Motor vehicle: Make Y It2tlYt L lYear
Cosi4CDO, t Amount owed
Stocks; bonds: LAI F-
Other: nAkE,
(t) Debts and obligations
Mortgage: V `r
_/( ?, v ,t
Rent: ? Q (Po t )
Loans:
Monthly Expenses: 2a. 60
(g) Persons dependent upon you for support
(Wife) (Husband) Name: ?\ L &L
Child if
Y
Name:
Age: - I
4. I understand that I have a continuing obligation to inform the court of improvement in my
financial circumstances which would permit me to pay the costs incurred herein.
5. 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
authorities.
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LISA M. MABIUS,
Plaintiff
VS.
THOMAS MABIUS,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
1 PENNSYLVANIA
1 CIVIL ACTION - LAW
1
NO. 99- 91)07 CIVIL TERM
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
,egoing pages, you must take prompt action. You are warned that if you fail to do so, the
se may proceed without you and a decree in divorce or annulment may be entered against
u by the court. A judgment may also be entered against you for any other claim or relief
Guested in these papers by the plaintiff. You may lose money or property or other rights
portent to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage,
u may request marriage counseling. A list of marriage counselors is available in the Office
the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
:S OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE
E RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH
LOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
LISA M. MABIUS,
Plaintiff
vs.
THOMAS MABIUS,
Defendant
1 IN THE COURT OF COMMON
1 PLEAS OF CUMBERLAND COUNTY,
1 PENNSYLVANIA
1
1 CIVIL ACTION - LAW
1 NO. 99- CIVIL TERM
1
1 IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
ist is kept as a convenience to you and you are not bound to choose a counselor from this
ist. All necessary arrangements and the cost of counseling sessions are to be borne by you
Ind your spouse.
If you desire to pursue counseling, you must make your request for counseling within
my days of the date on which you receive this notice. Failure to do so will constitute a
ver of your right to request counseling.
2
LISA M. MABIUS,
Plaintiff
VS.
THOMAS MABIUS,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-
CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, LISA M. MABIUS, by her attorney,
uel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is LISA M. MABIUS, an adult individual who currently resides at 114
Cumberland Road, Enola, Cumberland County, Pennsylvania.
2. The Defendant is THOMAS MABIUS, an adult individual who currently resides at
14 East Cumberland Road, Enola, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
of Pennsylvania for at least six months immediately previous to the filing of this
4. The Plaintiff and Defendant were married on 26 May 1995 in West Fairview,
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
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7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
I verify that the statements made in this Complaint are true and correct. I understand
any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
falsification to authorities).
L A M. MABIUS
Sa!-I?LAncles
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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