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HomeMy WebLinkAbout01-6800FALASHIA L. MELIUS, Plaintiff DOUGLAS A. MELIUS, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- b oe/rD 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 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 Prothonotary's Office at the 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 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 FALASHIA L. MELIUS, Plaintiff DOUGLAS A. MELIUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001- (~$i¢9 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Falashia L. Melius, through her attomey, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Faiashia L. Melius, is an adult individual who currently resides at 10805 Carlisle Pike, Gardners, Adams County, Pennsylvania 17324. 2. The Defendant, Douglas A. Melius, is an adult individual who currently resides at Station Road, P.O. Box 227, Twin Rocks, Cambria County, Pennsylvania 15960. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 27, 1996 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for 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, 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' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Falashia L. Melius, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX VERIFICATION 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 unsworn falsification to authorities. FALASHIA L. MELIUS, Plaintiff FALASHIA L. MELIUS, Plaintiff DOUGLAS A. MELIUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6800 CIVIL TERM : CIVIL ACTION - LAW : 1N DIVORCE PRAECIPE TO THE PROTHONOTARY: Please reinstate the above-captioned case for the purpose of securing service upon the defendant. Date: Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - F~X FALASHIA L. MELIUS, Plaintiff DOUGLAS A. MELIUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-6800 CIVIL TERM : : CIVIL ACTION - LAW : 1N DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 11th day of January 2002, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, Falashia L. Melius, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Douglas A. Melius, by certified, restricted delivery, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on January 9, 2002. Respectfully submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ~z.~u t.3.20 $ $7,37 P.O. BOX 227 · Print your IIk'~auind,~rii~lis~o0 ~e reverse · Attach this--cer~t~t~ae'"~l~'~l~o~ t~ mailpiece. oron the hont if space permits. 1. Article Addressed to: DOUGLAS A. MELIUS P.O. BOX 227 TWIN ROCKs, PA ].5960 2. A,'tlcisNumbe~ 7000 1670 0001 8796 3746 (rrar, sfer from sewice label) Ps Form 3811. March 2001 Y address different from Item 1 ? f'lyes If YES, enter delivery address below: [] No Service Type ~[ Certified Mail F'l Express Mail [] Registered [] Return Receipt for [] Ins~rad Mail r-I C.O.D. 4. Restricted Daiive~,? ~ Fee) Domestic Return Receipt FALASHIA MELIUS, Plaintiff Vo DOUGLAS A. MELIUS, Defendant FALASHIA L. MELIUS, Plaintiff DOUGLAS A. MELIUS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5380 CIVIL TERM · CIVIL ACTION - LAW : IN CUSTODY : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-6800 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO WITHDRAW AND ENTER APPEARANCE TO THE PROTHONOTARY: Date: . U6 0 5 2002 Please withdraw the appearance of Thomas S. Diehl, Esquire, on behalf of Falashia L. Melius in the above-captioned cases. Thomas S. Diehl, Esquire One West High Street, Suite 208 Carlisle, Pennsylvania 17013 (717) 240-0833 TO THE PROTHONOTARY: Please enter the appearance of Michael F. Fenton, Esquire, on behalf of Falashia L. Melius in the above-captioned cases. Date: MiChael F. Fenton,'l~sq~re 149 East Market Street. 2nd Floor York, Pennsylvania 17401 (717) 854-1366 FALASHIA L. MELIUS, : IN THE COURT OF COMMON PLEAS OF Plaintiff, Vo DOUGLAS A. MELIUS, Defendant. DEFENDANT : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-6800 CIVIL TERM : IN DIVORCE MARRIAGE COUNSELING AFFIDAVIT The Defendant being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed[ down. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: /to- ~_ ,2003 DOUGI~AS A. MELIUS FALASHIA L. MELIUS, Plaintiff, DOUGLAS A. MELIUS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2001-6800 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry ora final Decree of Divome without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divome is granted. 3. I understand that I will not be divomed until a divome decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are tree and correct. 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. Date: /0-o~ ,2003 DOUGLAS A. MELIUS FALASHIA L. MELIUS, Plaintiff, DOUGLAS A. MELIUS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001-6800 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divome Code was filed on November 29, 2001. 2. The man-iage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry ora final decree in divorce. 4. 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. Date: /0- ~7 ,2003 DOUGLAS A. ME IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FALASHlA L. MELI-US, Plaintiff DOUGLAS A. MELIUS, Defendant CIVIL ACTION ,LAW NO.: 2001-6800 ACTION IN DIVORCE AFFIDAVIT OFCONSENT 1. A Complaint in Divorce Under §3301 (c) of the Divorce Code was filed on November 29, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entD' of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. Section 4904 relating to unsworn falsification to authorities. Date Fal~shia L. Melius IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FALASHIA L. MELIUS, Plaintiff DOUGLAS A. MEL1US, Defendant CIVIL ACTION -LAW NO.: 2001-6800 ACTION 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. Date Falashia L. Melius IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FALASHIA L. MELIUS DOUGLAS A. MELIUS : TO THE PROTHONOTARY: CIVIL ACTION - LAW NO: 2001-6800 ACTION IN DIVORCE P~.ECIPE TO TRA_NSMIT RECORD 1. Ground for divorce: Irretrievable breakdown under §(3301(c)) of the Divorce Code. 2. Date and manner of service of the Complaint: Janua~z~, 2002 Certified Mail Rest ic · 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff~l. Odlg/o':; by Defendant ~c~/c~3/C~3 and, date of filing of the Affidavit ' ' - - , of Consent; by Plaintiff ~ by Defendant j (b) Date of execution of the Plaintiffs Affidavit required by §3301(d) of the Divorce Code N/A __ 5 date of filing of Plaintiffs Affidavit N/A ~ and, service of Plaintiffs Affidavit upon the Defendant ~N/A 4. Related claims pending: . · . . Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record a copy of which is attached, if the decree is to be entered under §3301(d)(i) of the Divorce Code: N/A Date and manner of service of Notice of Intention to File Praecipe to Transmit Record, a copy of which is, if decrce is to be entered under §3301(c of the Di o~r date of execution of Waiver of Notice of In*~-, '- ,-, ! -'~ vorce Code: N/A L, efendant ~1OJO2/03~ and date of~.,:-- -~ .... ~ .. . __0/1~ by 11_~3~/03 _, by Defendant ~ - - ,,,,,,~ m wmver o~ ~ot~ce of Intent: by Plaintiff M__ael F. FentRn, nsquire Sup. Ct. I.D. ~53985 Attorney for Plaintiff INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ¢~~ PENNA. FAnASHIA n. M~.BIU$ N O. ~00!-5800 VERSUS DOUGLAS A. MELIUS DECREE IN AND NOW, DECREED THAT AND DIVORCE , IT IS ORDERED AND _. Falashia L. Melius Douglas A. Melius ArE DIVORCED FROM THE BONDS OF MATRIMONY, , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None ATTEST: ~OTH ONOTARi'