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RICHARD A. MOUNTZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
CIVIL TERM
SELENA L. MOUNTZ, 99- SH13
Defendant IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against the claims set fort h 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 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 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. 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 County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9105
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by taw to comply with
the Americans with Disabilities 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.
RICHARD A. MOUNTZ,
Plaintiff
V.
SELENA L. MOUNTZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99- SN CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301
OF THE DIVORCE CODE
NOW comes the plaintiff, Richard A. Mountz, by his attorney, Marcus A. McKnight, 111,
Esquire, and files this complaint in divorce against the defendant, Selena L. Mountz, representing
as follows:
1. The plaintiff is Richard A. Mountz, an adult individual residing at 950 Walnut Bottom Road,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Selena L. Mountz, an adult individual residing at 698 Old Mill Road,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The plaintiff 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 detendant were married on August 8, 1987 in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There was one (1) child bom to this marriage, namely, Miranda R. Mountz, born June 23,
1988, age I I 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 she 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 marriage between the two
parties.
Respectfully submitted,
IRWIN, MCKNIGIW& HUGHES
By:
MarcuSA. N
Attorney for
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 25476
nd
Date: September a , 1999
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 correct to the best of my knowledge, information and belief. 1
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unswom falsification to authorities.
_-ICNA D .MOUNTZ
Date: September '-? , 1999
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
(CIVIL ACTION)
RICHARD A. MOUNTZ,
Plaintiff
V. No. 99-5413-CIVIL TERM
SELENA L. MOUNTZ,
Defendant
NOTICE OF DISCONTINUANCE
TO THE PROTHONOTARY:
Kindly mark the above-captioned matter discontinued as to all parties.
Date: l l?!l UO
Attorn or Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
(CIVIL ACTION)
RICHARD A. MOUNTZ,
Plaintiff
V. No. 99-5413-CIVIL TERM
SELENA L. MOUNTZ,
Defendant
CERTIFICATE OF SERVICE
It is hereby certified that a true and correct copy of the Plaintiffs Notice of
Discontinuance was served in the manner indicated upon the following:
U.S. Mail/First Class /Postage Pre-Paid
Selena L. Mountz
698 Old Mill Road
Carlisle, PA 17013
Date: LlA/ / o0
So Certified,
William A. aw, Jr., Esquire
Attorney for Plaintiff