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HomeMy WebLinkAbout08-5250Evelyn M. Nagy, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene C. Nagy, Defendant : NO. 08 - f0-0 CIVIL TERM 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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Evelyn M. Nagy, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene C. Nagy, Defendant : NO. 08 - 5--6 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Evelyn M. Nagy, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE 2. 3. 4. 5. 6. 7. 8. Plaintiff is Evelyn M. Nagy, who currently resides at Enola Commons Senior Apartments 16 South Enola Drive, Apt. 103 Enola, Cumberland County, PA 17025, since July 1, 2008. Defendant is Eugene C. Nagy, who currently resides at 508 14th Street Donora, Washington County, PA 15013, since April 4, 1991. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on February 2, 1988 at Bellevernon, Fayette County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since January 17, 2007. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Michael Light oot Certified Legal Intern "JI 411.1 ROB FAT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. - ~. &-/Z 1710V I ?R - Date Evelyn A Na Plaintiff " c? il ? ? ??LL' 7 -- ? ?-?' - --_ ,r,n ?- .,_... _? <. ?. `"' Evelyn M. Nagy, Plaintiff V. Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 08 - Sa,520 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Evelyn M. Nagy, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 4 Respe t y sub itted, L41; Victor Davidson II Certified Legal Intern 4"Z- ROBERt E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C: rn _a -Y ? s Evelyn M. Nagy, Plaintiff V. Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : No. 08-5250 CIVIL TERM To The Prothonotary: PRAECIPE TO REINSTATE COMPLAINT Please reinstate the Divorce Complaint at the above-captioned docket. Victo-rDaMrson II Certified Legal Intern October 24, 2008 THOMAS M. PLACE ROBERT E. RAINS ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 C C= c? ca C3 Evelyn M. Nagy, Plaintiff v Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : No. 08-5250 CIVIL TERM To The Prothonotary: PRAECIPE TO REINSTATE COMPLAINT Please reinstate the Divorce Complaint at the above-captioned Certified Legal Intern Anne Id-Fox 7] Supervis ng Attorney February 11, 2009 t'a ? C7 rn r.) -+ Ul Evelyn M. Nagy, Plaintiff V. Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : IN DIVORCE : NO. 08 - 5 , 5'0 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Evelyn M. Nagy, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date' ( / ep 9 ROE S THOMAS . PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 Certified Legal Intern N _ 7-i er. . .... - l ? . ,, - f ?.Fl'i ? ? 1 GIN Evelyn M. Nagy, Plaintiff V. Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 08- 5250 CIVIL TERM AFFIDAVIT OF SERVICE i I, -:Yq, yg g S v t c-e , hereby certify that I personally served a true and correct copy of the Divorce Complaint, on Eugene C. Nagy, by handing it to . tee aas at .5D$ ?l'A sZ . ?4 at 1n. on 2,r 13"02 I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: , 13, oq _ 0./YYZ2v0 Z--A-k C es Brice, Superintendant ? ?a V _ {`- M ;? ?` -??? 5 s '? ? ? ,. tea Evelyn M. Nagy, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Eugene C. Nagy, Defendant :NO. 08-5250 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in January 17, 2007, and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. 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. 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. §4904, relating to unworn falsification to authorities. Da '? N Evelyn M. Na Plaintiff i t 'r- C ?' a,? Evelyn M. Nagy, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE Eugene C. Nagy, Defendant NO. 08-5250 CIVIL TERM AFFIDAVIT OF SERVICE I, Victor Davidson II, hereby certify that I served a true and correct copy of the Plaintiff's Affidavit, on Eugene M. Nagy, by mailing it first class mail to 508 14th Street, Donora, PA 15033 on Thursday May 7, 2009. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: Vx,/-o 9 ictor Davidson II BLED-Oi SCE OF THE PPM`'INJOIARY 2009 MAY -8 APB 10: 4 Q CUM ,. . w Evelyn M. Nagy, Plaintiff V. Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 08 -5250 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): V (a) I do not oppose the entry of a divorce decree. () (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): () (i) The parties to this action have not lived separate and apart for a period of at least two years. ( ) (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): 00 (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I gnderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date / Z? / p 9 ugene C. Nagy -dry f? 1ryLL -C,,.--F rig 2009 MAY 18 Phi 2= t, 5 f"jN wY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA C. WEBER, CIVIL DIVISION Plaintiff, NO. 08-5313 V. PRAECIPE TO WITHDRAW MARY V. BEECROFT, MOTION TO COMPEL Defendant. (Jury Trial Demanded) Filed on Behalf of the Defendant Counsel of Record for This Party: Kevin D. Rauch, Esquire Pa. I.D. #83058 SUMMERS, McDONNELL, HUDOCK, GUTHRIE and SKEEL, L.L.P. Firm #911 100 Sterling Parkway, Suite 306 Mechanicsburg, PA 17050 (717) 901-5916 #16089 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRENDA C. WEBER, Plaintiff, V. MARY V. BEECROFT, Defendant. CIVIL DIVISION NO. 08-5313 (Jury Trial Demanded) PRAECIPE TO WITHDRAW MOTION TO COMPEL TO: The Prothonotary Kindly withdraw Defendant, Mary Beecroft's Motion to Compel discovery of the Plaintiff, Brenda Weber. Respectfully submitted, SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: Ke in D. Rauch, Esquire Counsel for Defendant r CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE TO WITHDRAW MOTION TO COMPEL has been mailed by U.S. Mail to counsel of record via first class mail, postage pre-paid, this 15th day of May, 2009. Philip L. Zulli, Esquire 155 Grandview Road Hummelstown, PA 17036 SUMMERS, McDONNELL, HUDOCK, GUTHRIE & SKEEL, L.L.P. By: Kevin D. Rauch, Esquire Counsel for Defendant OF THE 2gzq Evelyn M. Nagy, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5250 CIVIL TERM V. Eugene C. Nagy, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Sarah Rosko, Certified Legal Intern, Family Law Clinic, hereby certify that I'served a true and correct copy of the Notice of intention to Request Entry of § 3301(d) Divorce Decree and Defendant's Counter-Affidavit under § 3301(d) of the Divorce Code on Eugene C. Nagy, residing at 508 14th Street, Donora, PA 15033 by depositing a copy of the same in the United States mail first class on May 29, 2009. I verify that the statements made in this Affidavit of Service are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: 5J d ?/ J ? Sarah Rosko Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 i n Lju? r- v: I Evelyn M. Nagy, Plaintiff V. Eugene C. Nagy, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-5250 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 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 and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Personal Service to Defendant at 508 14th Street, Donora, PA 15013 on February 13, 2009. 3. Complete either paragraph (a) or (b): (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: March 16,2009; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on March 20, 2009 and served April 9, 2009. 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: Service by first class mail on May 29, 2009. Date Sarah Rosko Certified Legal Intern - ?L A7Anne enald-Fox Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Evelyn M. Nagy, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-5250 CIVIL TERM Eugene C. Nagy, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: EUGENE C. NAGY You have been sued in an action for divorce. You have failed to answer the complaint. You have filed a counter-affidavit to the § 3301(d) affidavit, stating that you do not oppose the entry of a divorce decree, and you do not wish to make any claims for economic relief. Therefore, on or after June 23, 2009 the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. OF THE FF--Jl "IX)TARY L?v7. rIU It`i f i 4-, C;J r Evelyn M. Nagy V. Eugene C. Nagy DIVORCE DECREE AND NOW, 10 %AQ n it is ordered and decreed that Evelyn M. Nagy plaintiff, and Eugene C. Nagy , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-5250 Attest' J. rothonotary . ?, 4- ? ? a*?1 ?? ? Evelyn M. Nagy, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08-5250 CIVIL TERM Eugene C. Nagy, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on June 30, 2009 hereby elects to retake and hereafter use her previous name of Evelyn Marie Strychalski, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As: Evelyn M. N 4y ;Y?! 5t Evelyn M. Stry alski COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the day of G?? , 2009, before me, a Notary Public, personally appeared Evelyn M. Nagy, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal. 1.%L atAL NOT PSI RVER NOTARY PUBLIC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES DEC. 22, 2010 OF TI 2009 JUL 29 Ct,;rtip 7 G?j?