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Home My WebLink About99-07315i PHILOMEANNA McCABE, Plaintiff V. THOMAS MARTIN McCABE, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 73/! CIVIL TERM CIVIL ACTION - LAW 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 will proceed without you and a decree in divorce or annulment may 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, PA 17013 (717) 249-3166 PHILOMEANNA McCABE, Plaintiff V. THOMAS MARTIN McCABE, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 731i CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Philomeanna McCabe, an adult individual, currently residing at 139 Lime Kiln Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Thomas Martin McCabe, Sr., an adult individual, currently residing at 1843 Starrets Gap Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on August 29, 1969 in London, U.K. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since November 25, 1999 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Date Respectfully Submitted TURO LAW OFFICES Robert'. Mulderig, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff 4 tl VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Philomeanna McCabe $ b \l t 41 - r L. J W? I lL I C. v c'( U n? ? b PHILOMEANNA McCABE, Plaintiff V. THOMAS MARTIN McCABE, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7315 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE HEREBY CERTIFY THAT I served a true and correct copy of the Divorce Complaint filed in the above captioned case upon Thomas Martin McCabe, Sr., by certified mail, return receipt requested on December 7, 1999 addressed to: Thomas Martin McCabe, Sr. 1843 Starrets Gap Road Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post office receipt card dated December 8, 1999. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURD LAW OFFICES /cam//GI /5?5 Date - / ?IWXI Robert J. Ideng, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Z 452 476 359 N !n C 0 w U) I m SEND a n O cp comp a El Print y Ord 11 m ?ach pe m prior Th 0 e C ThOR O deliver °m 3. Attic[( a US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do nN usn Inr Inlnm,linnel Ilell to-....... ?.,., /h r ?[ Num r o , tala,d Zl 0 $ SS Fee r / yr) elive ry Poo Delivery Fee aceipt Showing l0 Dale Delivered ?y eesW igbYRani, essea's /d6ess AftesWsAftm TOTAL Postage d Fees $ 3 ?d Postmark or Dale /C.1. (.M -v Al Items 1 anNor2 loraddltlonal services. Items 3.4a, and Cb. name and address on IM reverse Of this loan so that we wn retum this w loon to the (rant at the madpiece, or on the back it Spam does not um Receipt Raqueslad'an the madgoce below the aside number. 1 Receipt will show la whom the amdowas detwered and the data E Thomas Martin McCabe, Sr. U 1843 Starrets Gap Road 1.1 Carlisle, PA 17013 0 0 6. Re it 0 6. Signal T N PS Form , December 1994 I also wish to receive the follow. ing services (for an extra fee): I. O Addressee's Address 2. ? Restricted Delivery Registered Certified Express Mail ?Insured Return Receipt for Merchandise ?COD lee is paid) 102595.99 6-0223 I m' u? Z? 61 m? m' E: z' a? c, N? `o 01 r e? ?I 1 'n Receipt ?' I r. "._-- >- ?? ?, r- ' ?: ?. ' u,i. - _ ?. u. _J LL1.- _J? ?/.. ? G Ct 1.:. ?-? r? O i CJ DANIEL Fl. EICHENLAUB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-7317 CIVIL TERM STEWART CRAIG, Defendant PRAM To the Prothonotary: Please enter a default judgment in the amount of $2,481.73 in favor of the Plaintiff and against the Defendant for failure to enter an appearance or file an answer to the Complaint endorsed with a Notice to Defend. The undersigned hereby certifies that the attached written notice of intention to file this Praecipe was mailed to the Defendant on the date shown thereon, which was after the default occurred and at least ten (10) days prior to the filing of this Praecipe. HANFT & KNIGHT, P.C. TO: Curtis R. Long, Prothonotary DATE: April 2, 2002 By. e ?ez- William A. Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorneys for Plaintiff i( i --- DANIEL H. EICHENLAUB, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-7317 CIVIL TERM STEWART CRAIG, Defendant NOTICE TO TAKE DEFAULT JUDGMENT TO: Stewart Craig P.O. Box 102 Newburg, PA 17240 DATE OF NOTICE: March 5, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU 14AVEFAILED TO TAKE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITI4IN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P 17013 (717) 249-3166 HANFT & KNIGHT, P.C. By:, William A. Addams Attorney I.D. No. 06265 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 r%u., roWar,,m D.AWAAWISCimNo m-1i1"d S i c r ? 'i ? NJ ? ? ? 2