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Home My WebLink About07-6100 Nicole Mabius, ) Plaintiff ) v. ) Stephen Mabius, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No.Q?'- L !~d CIVIL 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. Since the ground for the divorce is irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the: Office of Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF 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, Pennsylvania 17013 (717) 249-3166 Nicole Mabius, ) Plaintiff ) v. ) Stephen Mabius, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. a ~- G~ ~ CIVIL IN DIVORCE NOTICE REGARDING THE AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint 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 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 (20) days of the date you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. .r Prepared by: I)AN BEGAN ATTORNEY AT LAW 1300 MARKET ST., SUITE 1 LEMOYNE, PA 17043 (717) 757-4433 DAN_RE GAN@C OMCA ST .NET Nicole Mabius, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Stephen Mabius, Defendant CIVIL ACTION -LAW No.~7 -L/Od CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Nicole Mabius, who has been residing at 1713 Kent Road, Camp Hill, Cumberland County, Pennsylvania, since 2001. 2. Defendant is Stephen Mabius, who has been residing at 1713 Kent Road, Camp Hill, Cumberland County, Pennsylvania, since 2001. Defendant's mailing address is 1713 Kent Road, Camp Hill, PA 17011. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 20, 2001, in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or annulment between Plaintiff and Defendant. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. .r- 7. The marriage between Plaintiff and Defendant is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require Plaintiff and Defendant to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 25 Pa.C.S. § 3301(c). Respectfully submitted, ~1~- DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Nicole Mabius, Plaintiff Dated: October 16, 2007 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Nico a Mabius, Plai jiff Dated: October 16, 2007 -2 - Nicole Mabius, Plaintiff v. Stephen Mabius, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Dan Regan, certify that I have this day served a true and correct copy of the foregoing Complaint via certified mail with return receipt requested and restricted delivery, and a second copy of the foregoing Complaint via first class mail, each addressed as follows, upon: Stephen Mabius 1713 Kent Road Camp Hill, PA 17011 ~ e DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Nicole Mabius Plaintiff Dated: October 16, 2007 -~ n (' V -J -~ C> c r~~ ~ , y ~; ~, _ ev -_., O C"") ""~ ....~ taD ~~ O ~--{{ EZt' r 1~ 1 - -1 _ .~ r _~'~ .J ~ • w y~ ~(~ 1 ~lT~ DAN REGAN ATTORNEY AT LAW 1300 MARKET ST. , SUITE 1 LEMOYNE, PA 17043 (717) 737-4433 D AN_RE GAN@C OMCA ST .NET Nicole Mabius, Plaintiff, vs. Stephen Mabius, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW > No. 2007-6100 CIVIL ) IN DIVORCE AFFIDAVIT OF RETURN OF SERVICE BY MAIL On October 17, 2007, I mailed a true copy of the "Complaint under Section 3301(c) of the Divorce Code" by certified mail, with return receipt requested and restricted delivery, to Defendant, Stephen Mabius, at his address. The Defendant signed the return receipt upon delivery and the receipt, attached hereto as Exhibit "A," was returned by the post office on or about October 20, 2007. I make these statements pursuant to 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities, and I understand that false statements may subject me to criminal penalties under that statute. Respectfully submitted, ~~ Dan Regan Dated:' (d / 2• 2 ~ COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND 1 BEFORE ME, A NOTARY PUBLIC, THIS 2ND DAY OF NOVEMBER, 2007, PERSONALLY APPEARED DAN RERAN, KNOWN TO BE (OR SATISFACTORILY PROVEN) TO BE THE PERSON WHOSE NAME IS SUBSCRIBED TO THE FOREGOING "AFFIDAVIT OF RETURN OF SERVICE BY MAIL" AND ACKNOWLEDGED THAT HE EXECUTED THE SAME FOR THE PURPOSES THEREIN CONTAINED. IN WITNESS WHEREOF, I HAYE HEREUNTO SET ME HAND AND SEAL. COMMONVI~ALTH OF PENNSYLVANIA Notaeial Seal Soo1t Boa~erx3C, Nolitry PtbIC Lemoyne 9oro, GlanberMrld Ooulry My Carmlladon Eaptr'ea AuS.1,2011 llAembsr, PsnnsylwMa Association o/ Notar'les ~~ ~~xHtgi- "A `' ^ Complete items 1, 2, and 3. Also complete A. Sfg item 4 if Restricted Delivery is desired. X ^ Print your name and address on the reverse so that we can return the card to you. g, p by ~ ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: STE P u ~ mi4~ ~ U s 17 {3 KENT p~q , ~h'llrlT ~~ IL~-r FJ~ i70t{ D. Is delivery address dif If YES, enter delivery C. r ~, 3. ice Type Certified Mail ^ Egress Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Exha Fee) Yes 2. Article Number (fn~r-sfer from se-v/c» 7 0 0 6 010 0 ^0 0 0 3 4 87 5 6 83 P'3 Faint 3811, February 2004 Domestic Return Receipt 102595~Q2~it-150 ~f Nicole Mabius, ) IN THE COURT OF COMMON PLEAS Plaintiff, ) CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL ACTION -LAW Stephen Mabius, ) No. 2007-6100 CIVIL Defendant ) IN DIVORCE CERTIFICATE OF SERVICE I, Dan Regan, certify that I have this day served a true and correct copy of the foregoing document by sending one copy via first class mail upon: Stephen Mabius 1713 Kent Road Camp Hill, PA 17011 ~~--~~-- DAN REGAN Pa. Lic. No. 72461 1300 Market Street, Suite 1 Lemoyne, PA 17043 (717) 737-4433 Counsel for Nicole Mabius, Plaintiff Dated: " l ~ ~~ Z ~ 7 ~ ./ t' . •. Cw y = -~ S. -~7 r A'; : "! G^ d . ~ ,-: ~ - _ - ~„`. :: r T y;. N ~, ~ ~V