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HomeMy WebLinkAbout99-07186L? l- .o 0 J Os 1 a _® In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, ) Plaintiff, 7? gW VS. No. 9 of 19 9 KAREN L. McCLEAF, ) CIVIL TERM Defendant. ) 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 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 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: 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 ONE GO OR TELEPHO T OF ICES T FORTH BELOW TO FIND OUT0 WHERE'YOU COAN GET LEGAL EHELP Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, ) Plaintiff, ) c VS. ) No. 9 7 • of 19 KAREN L. McCLEAF, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in 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 list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. t_.j In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, ) Plaintiff, ) VS. ) No. q! •'1/ y L of 19 KAREN L. McCLEAF, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by his attorney Michael S. Travis, respectfully represents: Plaintiff is Steven L. McCleaf, who resides at 4056 Caissons Court, Enola, Cumberland County, Pennsylvania 17025, since September of 1999. 2. Defendant is Karen L. McCleaf, who resides 4056 Caissons Court, Enola, Cumberland County, Pennsylvania, 17025 since October of 1999. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on September 3, 1999, at Hagerstown, Maryland. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. 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. 9. Plaintiff requests the tout to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. 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: 7Steven L. cCleaf, anf i aeS. rays Attorney for Plaintiff I.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, ) Plaintiff, ) VS. ) No. 1999-7186 KAREN L. McCLEAF, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in 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 list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, ) Plaintiff, ) VS. ) No. 1999-7186 KAREN L. McCLEAF, j CIVIL TERM Defendant. ) 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 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 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: 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 4ichael S. Travis 076 Market Street, Suite 209 ;amp Hill, PA 17011 717)731-9502 Cumberland County, In the Court of Common Pennsylvania STEVEN L. McCLE Plaintiff, ) No. 1999-7186 VS. CIVIL TERM KAREN L. McCLE Defendant. ) IN DIVORCE AMENDED COMPLAINT I. Plaintiff, Steven L. McCleaf, is an adult individual and national of the United States of America, with a mailing address of Post Office Box 666, Greencastle, Franklin County, Pennsylvania 17225. 2. Defendant, Karen L. McCleaf, is an adult individual and national of the United States of America, currently residing at 478 Thames Street, Hagerstown, Maryland 21740. 3. Paragraphs 1 through 9 of the original Complaint in Divorce filed November 30, 1999, are incorporated by reference herein. COUNT I DIVORCE 4. Plaintiff incorporates by reference herein Paragraphs 1 through 3 of Plaintiff's Amended Complaint, above, as if set forth herein in their entirety. S_ Plaintiff avers that defendant offered such indignities to render plaintiff's condition intolerable and life burdensome. 6. Plaintiff avers that plaintiff is an innocent and injured spouse. WHEREFORE, Plaintiff, Steven McCleaf, respectfully requests that your Honorable Court enter a Decree in Divorce. I_.t COUNT 11- EQUITABLE DISTRIBUTION OF PROPERTY 7. Plaintiff incorporates by reference herein Paragraphs I through 6 of Plaintiff's Amended Complaint, above, as if set forth herein in their entirety. 8, On November 30, 1999, Plaintiff filed a Complaint in Divorce in the Court of Common Pleas of Cumberland County, Pennsylvania, at the above-referenced case number. 9. Plaintiff and Defendant have acquired certain assets and liabilities during their marriage from its inception to the date of separation of the parties. 10. Plaintiff and Defendant have been unable to agree as to an equitable division of said property and debts. 11. Plaintiff requests this Court to equitably divide, distribute or assign the marital property and debt between the parties in such proportion as the Court deems just after consideration of all the factors of the Divorce Code. WHEREFORE, Plaintiff requests that your Honorable Court enter an Order of Court equitably dividing all marital property pursuant to Section 3502(a) of the Pennsylvania Divorce Code. Respectfu y submitted, i ael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Attorney for Plaintiff Date: '?l /?,,Q/ In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, Plaintiff, VS. KAREN L. McCLEAF, Defendant. No. 1999-7186 CIVIL TERM IN DIVORCE VERIFICATION I verify that the statements made in this Amended Complaint 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. ' DATED: 0/ Steven L. cLeaf Gu_ , . In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, ) Plaintiff, ) vs. ) No. 1999-7186 j KAREN L. McCLEAF, CIVIL TERM IN DIVORCE Defendant. ) CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Martha Walker, Esquire 247 Lincoln Way East Chambersburg, PA 17201 Dated: 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff By . Travis No. 77399 99 n N c> > c? 11.? G :?LLI 4' n_12 v- f C:D In the Court of Common Pleas of Cumberland County, Pennsylvania STEVEN L. McCLEAF, Plaintiff, VS. KAREN L. McCLEAF, Defendant. No. 1999-7186 CIVIL TERM IN DIVORCE PRAECIPETO WITHDRAW COMPLAINT TO THE PROTHONOTARY: Please withdraw the complaint in divorce filed by plaintiff in the above captioned matter. hae S. Travis .,1000 Attorney for Plaintiff 4076 Market Street, Suite 209 Camp Hill, PA 17011 I hereby certify that the foregoing is a true and correct statement of the above-captioned case. This statement is made subject to the penalties of 18 Pa. Cons. Stat. §4904 relating to unswom falsification to authorities. Date: By: Steven L. McCleaf, Plaintiff [q)i o ~D CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Karen L. McCleaf 497 Thames Street Hagerstown, PA 21740 Dated: ?O•i??'O/ By: cl a ravis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff h? ? 1 Lr. - - lj c7 Cd -i c u_ +t+