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PAMELA MATTUS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - LAW
PAUL MATTUS, : NO. 09 - X95/0? CIVIL TERM
Defendant : IN DIVORCE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you fail
to do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
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.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORAMTION 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
Phone: (717) 249-3166
(800) 990-9108
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. 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.
PAMELA MATTUS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
: CIVIL ACTION - LAW
PAUL MATTUS, : NO. 09 - ?67.;?,
Defendant : IN DIVORCE
CIVIL TERM
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Pamela Mattus, an adult individual, who resides at 514 Partridge Court,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Paul Mattus, an adult individual, who resides at 3810 Market Street, Camp
Hill, Cumberland County, Pennsylvania 17011.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on August 5, 1996, in Juneau, Alaska.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
COUNT II
ALIMONY. ALIMONY PENDENTE LITE
AND COUNSEL FEES
9. Paragraphs 1 through 8 are incorporated herein by reference as if set forth in their full
text.
10. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during
the pendency of this divorce action, and through its resolution.
11. Plaintiff is without sufficient property and otherwise unable to financially support
herself and children.
12. Defendant is presently employed and receiving substantial income and benefits and is
able to pay for counsel fees, expenses and costs, as well as alimony, and alimony pendente lite for
Plaintiff.
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring
Defendant to pay for Plaintiff's counsel fees, expenses, and costs as well as providing for payment of
an appropriate alimony and alimony pendente lite for Plaintiff.
COUNT III
EQUITABLE DISTRIBUTION
13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their
full text.
14. Plaintiff and Defendant are joint owners of various items of personal property,
furniture and household furnishings acquired during their marriage, which are subject to equitable
distribution.
15. Plaintiff and Defendant have incurred debts and obligations during their marriage,
which are subject to equitable distribution.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing
the parties' property and equitably apportioning the debts incurred by the parties.
Respectfully submitted,
Rominger & Associates
Date:
4 2(zg
Kar1B. Rominger, Esquire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court I.D. # 81924
Attorney for Plaintiff
U
PAMELA MATTUS,
Plaintiff
V. .
PAUL MATTUS, .
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL. ACTION - LAW
NO. 09 - CIVIL TERM
IN DIVORCE
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 unworn
falsification to authorities.
Date:
Pamela Ma laintiff
FILE E
OF ?H
2N9 APR 21 PH 3: 20
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