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Home My WebLink About01-6182NElL P. MALADY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA LESLIE A. MALADY, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are wamed 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 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 Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania. 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 Phone: (717) 249-3166 NEIL P. MALADY, Plaintiff LESLIE A. MALADY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant 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 decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your fight to request counseling. Prothonotary NEIL P. MALADY, Plaintiff LESLIE A. MALADY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Neil P. Malady, who currently resides at 515 Country Club Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Leslie A. Malady, who currently resides at 6109 Club House Road, Nevillewood, Allegheny County, Pennsylvania 15142. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married on July 24, 1993, in Bridgeville, Pennsylvania. 5. 6. 7. There have been no prior actions for divorce or annulment between the parties. The Plaintiffis a citizen of the United States of America. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. The parties to this action have been separated since October 1, 2001. 10. Plaintiff requests the Court to enter a Decree in Divorce. CLAIM FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 11. Plaintiff and Defendant are the owners of various real and personal property, motor vehicles, bank accounts and insurance policies acquired during their man/age which are subject to equitable distribution by this Court. Date ?,~ .-,~,;'-o / JAMES, SMITH, DURKIN & CONNELLY ~Ax~ey for ylaintiff Po§t O~fiee~Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 I verify that the statements made in this Pleading are Ixue and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: /o/~K'Jo I Od./"--- J Neil P. Malady, Plaintiff cou~ Cumberland V~R RECORD OF DI CE OR ANNULMENT (CHECK ON~ [] HUSBAND E,.m 11 24 1960 Neil P Malady 515 Country Club Road. Cam~ Hill, Cumberland, PA Pennsylvania MAIDEN NAME Hall Leslie WIFE 7. USUAL OCCURA~ON Regional Manager Malady E,~rr. 10 06 1966 6109 Club House Road. Nevillewood, Allegheny. PA NUMBER 6. RACE ~RE,^GE Allegheny Pennsylvania 17A. NUMBER OF . 17E. NUMBER OF DE.ENDENT 10. P~AIN31FF CHILDREN THIS CHI~R~ UN=ER 18 HUS~O WI~ M~RIAGE NA NA ~ ~ CHI~R~N ~ ~ ~ ~ NA 24. SIGNATURE OF TRANSCRIBING CLERK S.m~ Florida 'F~?J SUAL OCCUPATION Attorney U^RR,A~E 07 24 1993 0 [] [] [] Sect±on 3301 o~ the ];)±voice oo~e TO YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSE[3 WITHIN TWENTY 12OI DAYS OF SERVICE HEREOF OR LAW OFFICE JAMES, SMITH, DURKIN & CONNELLY, LEP R O BOX 65O HERSHEY, PENNSYLVANIA 17033-0650 WE HEREBY CERTIFY THAT THE WITHIN IS A TRUE AND CORRECT COPY OF THE ORIGINAL FILED IN THIS ACTION. BY NEIL P. MALADY, Plaintiff LESLIE A. MALADY, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA :NO. Or-- CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO ENTER SOCIAL SECURITY NUMBERS TO THE PROTHONOTARY: Please enter the following social security numbers in the above-captioned divorce action: Neil P. Malady - 173-46-3373 Leslie A. Malady- 192-56-9930 Date: JAMES, SMITH, DURKIN & CONNELLY LLP J~hn~J. CtOnn~y, ~r., Esquire 4tto]ney~r p2!hintiff [, Pbsf Office~B~ox 650 ~ Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 NElL P. MALADY, Plaintiff LESLIE A. MALADY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA _. : NO. 01-6182 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF DAUPHIN : AND NOW, this _f~day of~~f/°~} ,2001, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce was served on the Defendant, Leslie A. Malady, on November 9, 2001, by certified mall number 7000 1670 0011 1697 9999, as evidenced by the retom receipt card attached hereto and made a part hereof. Sworn to and subscribed before m~ .this /~ · day of ~2001- lic ! NOTARIAL SEAL Jean L. Kosier, Notary Public City of Hummelstown,County of Dauphin My Comml~alon Expire~ Feb, 9, 2004 · Complete items 1, 2, and 3. Also complete item 4 it Restricted Delivery is desired. · Print your name and addr~es on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Received by (Pteaee Print Clearly) C. SIg r,~t~ x D. Is daiivery address diffem~ fro~,ftem 17 E YES, ,~'Ce~tifled Mail [] Registered r-I Insured Mall [] Express Mail [] Return Flecaipt for Me=handlse [] C.O.D. 4. R~tr~ed ~*~'b' ~ Fee) 7~9 ),~ 7,2 ,,~9// ,,',~ ~,7 q~ ? ;9 PS Fern 3811, J~l,/lB oeme~lc Ra~um R~e~t NElL P. MALADY, Plaintiff LESLIE A. MALADY, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01 - 6182 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO DISCONTINUE THE ACTION TO THE PROTHONOTARY: Please discontinue the Complaint in Divorce filed on October 26, 2001 in the above- captioned action. Date: Lg~-/~- O~ By: JAMES, SMITH, DURKIN & CONNELLY LLP ~~r~,Esquir(~ ~' Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615 NEIL P. MALADY, Plaintiff LESLIE A. MALADY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01 -6182 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, John J. Cormelly, Jr., Esquire, of James, Smith, Durkin & Connelly LLP, attomey for the Plaintiff, Neil P. Malady, hereby certify that I have served a copy of the foregoing Pmecipe to Discontinue the Action on the following on the date and in the manner indicated below: U.S. MAIL. FIRST CLASS. POSTAGE PRE-PAID Leslie A. Malady 515 Country Club Road Camp Hill, PA 17011 JAMES, SMITH, DURK1N & CONNELLY LLP BY: ~~O. [~ ~ Hershey, PA 17033 (717) 533-3280 PA I.D. No. 15615