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HomeMy WebLinkAbout09-4228In the Court of Common Pleas of Cumberland County, Pennsylvania BECKY M. PELLMAN, ) Plaintiff, VS. ) No. CA - Naafi Civi I Term SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) 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 Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania BECKY M. PELLMAN, ) Plaintiff, ) VS. ) SCOTT C. PELLMAN, Defendant. ) No. 0 1- ?? ?B' cu%1 f ?M CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in 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 days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Nff2ff5o Michael S. Travis Attorney at Law ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9509 mst@mtravislaw.com In the Court of Common Pleas of Cumberland County, Pennsylvania BECKY M. PELLMAN, ) Plaintiff, ) VS. ) SCOTT C. PELLMAN, Defendant. ) CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by her attorney, Michael S. Travis, respectfully represents: 1. Plaintiff is Becky M. Pellman, who resides at 1721 English Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since March, 2009. 2. Defendant is Scott C. Pellman who resides at 117 West Coover Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since Zi? 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 10, 2006 at a n IQ\ Chi Mechanicsburg, Cumberland County. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. 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. 9. Neither party is in the Military Service in the United States. 10. Plaintiff requests the court to enter a decree of 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 unsworn falsification to authorities. Date: )v dymv? Becky M. P Oman, Plaintiff Michael S. Travis Attorney for Plaintiff I. D. # 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 F1LF_J OF THE' 2H9 JUIN 23 Pill I : I 1 l f, J!-`.. C'L'.?ri .j 338. 50 PO ATM c g-# 15 3y W aaflo(po In the Court of Common Pleas of Cumberland County, Pennsylvania BECKY M. PELLMAN, ) Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, CIVIL TERM Defendant. ) IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT Divorce Agreement The following is an agreement between Scott Pellman and Becky Pellman with regards to financial support and separation of property. Financial Becky Pellman is to receive a lump sum of money in the amount of $10,300 from Scott Pellman. How we arrived at this amount: Becky will be provided $3,300 from our joint income tax return for 2008 tax year. The following $7,000 is $1,000 for each year that we were together. Property With regards to property we have agreed that Becky is to receive the following items of marital property: Big Screen TV and stand Dresser/Mirror, night stand and bed frame All other property that was brought into the marriage by Becky will leave with her, with exception of the buffet that is in the dining room and one plant. Child Support Scott has agreed to pay all of Cole Pellman's (our son) daycare expenses until he has reached kindergarten. He has also agreed to provide $150/monthly towards groceries. Once Cole has reached kindergarten Scott will then start paying a sum $600/monthly in child support, which was figured based on income on the PA Child Support website. However, if there should be a significant change in employment or income status, we have agreed to adjust these figures accordingly, based on ability to pay and will be again figured by the PA Child Support website calculator. By signing this agreement we have both agreed to these terms and conditions and shall not deviate from the aforementioned from this day forward. q / X QL Date ??o U 1 X Z1 WJO?.ate Mffe5o OF THE FP0T-.t:i\.0;Apy 2009 J` L -b PIS 2: ; CUtY!` l1? ,fv ??4?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BECKY M. PELLMAN, Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant on June 26, 2009, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. '4904 relating to unsworn falsification to authorities. yes/o? ichael S. Travis 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 FIL KE N THE PROTHONOTARY CIC 2009 OCT -5 PM 1: 55 CUP,t 3;.. _.- NI Y FE= yi ?SYCVA fir: ¦ corrtpme RM" 1, z, am Z. MMUMMMew ftqM 4 if RestrlaW DOWNY la did. ¦ PLAt your matte and on do MAW" Awd we can mWm the terra to you. ¦ ft this card to the back cif the mololo s, the from! N wave i<+wmft. 1. Artkie-A+ddrosssd to. x 0 Agent SCoA+ C. Pakkrro-n 1`O Vi. (ovje-rS+fo!e t- mec)Qwocsbw f , PA v,o55 Q?Mff!g 0. % > +o 17 U'M ff YES, ~ delvary address beiew: 0 No 3. Sery" Type artemw ma ? Express Mail 0 Registered 0 Return Receipt for Merchandise 0 insured Mali 0 C.O.D. 4. Restricted DeNvery4 (Extra Fee) 2. Article Number 7008 1140 0003 9596 9604 (rransfer from service labs!) PS Fora, 3811, February 2004 oorMFOetle PAW" Pleeei(at 102595-02-M-1540 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BECKY M. PELLMAN, ) Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 23, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unsworn falsification to authorities. DATED: L?& m ?&4 & 64?? Becky M. loran, Plaintiff flLED-Ci- rE OF THC PRDTHONOTARY 2009 OCT -5 PM 1: 55 PENNSYLVANIA ,n ..? V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BECKY M. PELLMAN, ) Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 3301(c) OF THE DIVORCE CODE 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 if I 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. § 4904 relating to unsworn falsification to authorities. Date: ! tjCf ?C C?` Becky ellman, Plaintiff OF TFf FILE 0H:R`E 2009 OCT -5 PM 1: 55 C:I;A??? .?a?r+1f P -NNSYLV Ai%''i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BECKY M. PELLMAN, ) Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on June 23, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unsworn falsification to authorities. DATED: (? ( 10? Scott C. Pellman, Defendant FILED-OFFICE OF THE FROT-!c NaTARY 2009 OCT -5 PM 1: 5 5 rE NNSYL.Vi"VA ?1lffa-;:,LUWAD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BECKY M. PELLMAN, Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) IN 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 if I 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. § 4904 relating to unsworn falsification to authorities. Date: &11)09 e --4ez , ?ja Scott C. Pellman, Defendant FILED-OFFACE OF THE PPknTHr-NOTARY 2009 OCT -5 PM 1: 5 5 PEf\jNSYLVr N A Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BECKY M. PELLMAN, Plaintiff, ) VS. ) No. 09-4228 SCOTT C. PELLMAN, ) CIVIL TERM Defendant. ) 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: mutual consent unde5 3301 (c)(1) of the Divorce Code. 2. Date and manner of service of the complaint : Complaint was mailed June 24, 2009, via United States Certified Mail, restricted delivery, return receipt requested to Defendant, which was received by Defendant on June 26, 2009. Affidavit of Service is attached hereto. 3. Date of execution of the affidavit of consent required by$3301(c) of the Divorce Code: by Plaintiff on 9 30 , 2009; by Defendant 1311 , 2009. 4. Related claims pending: Economic claims resolved by Mariltal Settlement Agreement dated April 6, 2009. 5. Dat Plaintiff's Waiver of Notice in§3301(c) Divorce was filed with the prothonotary: 0 Date Defendant's Waiver of Notice in33301(c) Divorce was filed with the prothonotary: 1t5I ?g5 -'Michael S. Travis Attorney for Plaintiff HLED-O?FQ OF THE PF iT' 0NflTARY 2009OCT -5 PM 1: 55 PENNSYLVANIA BECKY M. PELLMAN V. SCOTT C. PELLMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-4228 DIVORCE DECREE AND NOW, it is ordered and decreed that BECKY M. PELLMAN , plaintiff, and SCOTT C. PELLMAN 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.") The Marital Settlement Agreement dated April 6, 2009 is incorporated but not merged in i Decree, By the Court, r thonotary d .Of 1® ,12 a