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Home My WebLink About99-06416 IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF w? PENNA. !fn+ a Karl L. McManus No. 6416 1999 VERSUS Alona M. McManus DECREE IN DIVORCE AND NOW, A -4 , 2001 IT IS ORDERED AND DECREED THAT Karl L. McManus , PLAINTIFF, AND Alona M. McManus 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; 8Y THE CODU/RTT: ATTEST: U J. PROTHONOTARY ... 1. ?rr!,tj vr?rr"s•i•6%r's.:.;.rnrirr:ti. .s.;.rs.s.s.. ?.;4.s.trtrsrrtri ' 4 KARL L. MCMANUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA va. NO. 99-6416 CIVIL TERM ALONA M. McMANUS, Defendant CIVIL ACTION - LAW 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 for Divorce: Irretrievable breakdown under 53301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Service of the Complaint was made by the Cumberland County Sheriff on October 25, 1999. 3. Defendant executed the Affidavit of Consent required by §3301(c) of the Divorce Code on March 12, 2001. Plaintiff executed the Affidavit of Consent required by 53301(c) of the Divorce Code on April F, 2001. 4. There are no related claims pending. 5. Date Plaintiff's Waiver of Notice in 53301(c) Divorce was filed with the Prothonotary: On or around April 13, 2001. Date Defendant's Wavier of Notice in 53301(c) Divorce was filed with the Prothonotary: March 16, 2001. YOFFE & YOFFE, P.C. By 4d,? 40, FM Y . YOFFE, E UIRE Attorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1838 Attorney ID No. 52933 KARL L. McMANUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSSYYLV,ANIA VS. NO. qq- 10914, at'S",'0 J ALONA M. McMANUS, Defendant CIVIL ACTION - LAW 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 at 20 E. 5th Street, Emporium, PA 15834. 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 BET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 11013 (717)249-3166 or (800)990-9108 mcmenuw\notfce to defend KARL L. McMANUS, Plaintiff VS. ALONA M. McMANUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 6 1116 aua -fZ4 ? CIVIL ACTION - LAW COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Karl L. McManus, who currently resides at 3 Raylen Drive, Boiling Springs, Cumberland County, PA 17007 since February 1996. 2. Defendant is Alona M. McManus, who has resided at 105 Claridon Place, Carlisle, Cumberland County, PA 17013 since July 12, 1999. 3. Both Defendant and Plaintiff have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 9. The Plaintiff and Defendant were married on February 29, 1999 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. B. Plaintiff requests the Court to enter a decree of divorce. YOFFE 6 YOFFE, P.C. ey ?_ F R Y FED ESQUIRE ttorney for Plaintiff 214 Senate Avenue, Suite 203 Camp Hill, PA 17011 (717) 975-1030 Attorney ID No, 52933 mcmenus\complsint r KARL L. McMANUS, Plaintiff VS. ALONA M. McMANUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW VERIFICATION I hereby state that I am an adult individual who is authorized to make this verification and that the facts set forth in the foregoing Divorce Complaint are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. Dated: mcmanus\complaint N .7 N ?Y Flk Ol rj W ? KIN W • i KARL L. McMANUS, Plaintiff VS. ALONA M. MCMANUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6416 CIVIL TERM CIVIL ACTION - LAW AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 53301(c) of the Divorce Code was filed on October 20, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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 falsification to authorities. Date: 1+410/ Pa. C.S. 54904 relating to unsworn -, 7 co, f - ..z cat- KARL L. McMANUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-6416 CIVIL TERM ALONA M. MCMANUS, Defendant CIVIL ACTION - LAW OF I 1. 1 consent to the entry of a final Decree in Divorce without notice. 2. 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. 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 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. 54904 relating to unsworn falsification to authorities. Date: LfI6101 A CMAt US memanue\final Toms\vaiver r«? - ? 'ICJ r- C.' }?ILj :1 i ?p M r Q? r a N co C g, ? C V ? ? aF Y a ?? m CN r, KARL L. MCMANUS. Plaintiff VS. ALONA M. McMANUS. Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 99 - 6416 CIVIL TERM CIVIL ACTION - IN DIVORCE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 3. 1 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. AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 20,1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 1 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 Waiver and Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. DATE: 12.2001 ALONA McMANUS `soh: p'v a`c ?str.r In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ALOHA M. MCMANUS ) Docket Number 99-6416 CIVIL Plaintiff ) VS. ) PACSES Case Number 758101768 /D29,211 KARL L. MCMANUS ) Defendant ) Other State ID Number Order AND NOW to wit, this JANUARY 3, 2000 it is hereby Ordered that: THE ABOVE CAPTIONED PETITION FOR ALIMONY PENDENTE LITE IS DENIED, PURSUANT TO THE PERIOD OF TIME DURING WHICH THE PARTIES LIVED TOGETHER FROM THE DATE OF MARRIAGE TO THE DATE OF FINAL SEPARATION. DRO: RJ Shadday xc: plaintiff defendant James Kayer, Esquire Jeffrey Yoffe, Esquire Service Type M •00 BY THE COURT: A. Hess JUDGE Form OE-001 Worker ID 21005 SHERIFF'S RETURN - REGULAR CASE NO: 1999-06416 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCMANUS KARL L VS. MCMANUS ALONA M HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon MCMANUS ALONA M the defendant, at 20:45 HOURS, on the 25th day of October 1999 at POE: EAT-N-PARK 1251 HARRISBURG PIKE CARLISLE, PA 17013 CUMBERLAND , County, Pennsylvania, by handing to ALONA M. MCMANUS a true and attested copy of the COMPLAINT - DIVORCE , together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 RAF : Mine, Sneriff: u10/26/1999FfiE by A Sworn and subscribed to before me this tj = day of ASce-"wL--- 19-e)q_ A.D. D. -? wC i .ga " _ ..Q0•. C Q. v, c? C. t0 c u? d ? xaC CL g.? Y<? • J ;a i jrn 2 7 - KARL L, McMANUS, IN THE COURT OF COMMON PLEAS OF Plaintif /Rcspondcnt CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO.99 - 64116 CIVIL TERM ALONA M. McMANUS, IN DIVORCE Defcndant/Pelitioncr DR# 29,211 Pacscs# 758101768 ORDER OF COURT AND NOW, this 7 s day of December, 1999, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the panics and their respective counsel appear before R.1. Shaddav on Januan, 3.2000 ar A-00 AX for a conference, at 13 N. Hanover St., Carlisle, PA 17013, niter which the confercnce officer may recommend that an Order for Alimony Pcndcntc Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy ofyour most recent Federal Income Tar Return, including W-2's as filed (2) your pay stubs for the preceding sir (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail topics on Petitioner 12.7.99 to: < Respondent James Kaycr, Esquire Jeffrey Yoffe, Esquire Date of Order: -December 7. 1999 R. 1. SI adday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ?5? KARL L. McMANUS, : THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY VS. : NO. 99 - 6416 CIVIL TERM ALONA M. McMANUS, Defendant CIVIL ACTION - IN DIVORCE PETITION FOR RELATED CLAIMS UNDER DIVORCE. CODE COMES NOW, the Petitioner, Alona McManus, by and through her attorney, James J. Kayer, Esquire, and respectfully represents that: COUNT I - ALIMONY PENDENTE LITE 1. Petitioner lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 2. Petitioner requires reasonable support to adequately maintain herself in accordance with the standard of living established during the manage. 3. Respondent cams in excess of $50,000.00 per year and has substantial assets. 4. Petitioner requests the Court to enter an award of reasonable temporary alimony and additional sums as they may become necessary from time to time hereafter until final hearing and permanently thereafter. COUNT II - ALIMONY 5. Paragraphs I through 4 of the Petition are incorporated herein as fully set forth. Respectfully submitted, J. K'0, Esquire R¢ BROWN I ? rty Avenue e PA 17013 (717) 243-7922 Supreme Ct. # 50838 CERTIFICATE OF SERVICE hereby certify that a true copy of the foregoing Petition for Related Claims Under Divorce Code was served on Defendant/Respondent, by First class U.S. mail, postage prepaid, by forwarding a true and correct copy unto: Jeffrey N. Yoffe, Esquire Suite 203 214 Senate Avenue Camp Hill PA 17011 Date: /1 //2- , 1999 J. 4 t Liberty Avenue Carlisle, PA 17013 (717) 243-7922 sew , 1 ' ,a ;i u w? f 1 inf. n VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904, relating to unswom falsification to authorities. Date: V OW I V& rJ _11999 LtCtJM c~ {tit f l( r 11 l u vt u t ET - M ? 4) N A Off 000 . W ? ? ' Lt', '.)mot KARL L. McMANUS, Plaintiff VS. ALONA M. McMANUS, Defendant T1 1E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 99 - 6416 CIVIL TERM CIVIL ACTION - IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please enter my appearance as counsel of record for the above-captioned Defendant. Respectfully submitted, Dated: J. 4 • Lib y Avenu C isle; 'A 17013 (717)243.7922 014, I x3J' `?s CERTIFICATE OF SERVICE 1 hereby certify that a true copy of the foregoing Petition for Related Claims Under Divorce Code was served on Defendant/Respondent, by First class U.S. mail, postage prepaid, by forwarding a true and correct copy unto: Jeffrey N. Yoffe, Esquire Suite 203 214 Senate Avenue Camp Hill PA 17011 Date: W/O '1999 Libe rty Loft 4 E t Libe Avenue Carl le, P, 17013 (71 )243- 922