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HomeMy WebLinkAbout09-449614 KAREN M. UPDEGRAFF, Plaintiff vs. MICKEY UPDEGRAFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Oq- 14H9(o Civil Term ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 t KAREN M. UPDEGRAFF, Plaintiff vs. MICKEY UPDEGRAFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 6 9 - yy 1(-, Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Karen M. Updegraff, a competent adult individual, who has resided at 3555 Mulberry Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055 since 1998. 2. Defendant is Mickey Updegraff, a competent adult individual, who resides at 104 Sunset Drive, New Cumberland, York County, Pennsylvania, 17070. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 6, 1993 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together; namely, Tyler J. Updegraff, born 10/22/95 and Luke F. Updegraff, born 4/22/00. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. A' Lid) Karen M. Upde raff, Pin?V? Respectfully subm Date: -I I h q Iar e Ad ams, Esquire No. 79465 West South St. lisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF r.? RL EDl-kD OF THE 2059 JUL --I A 8: 2 4 4 338.50 Pa ATT/ ev v 5306 M4 aahcpgs KAREN M. UPDEGRAFF, Plaintiff vs. MICKEY UPDEGRAFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - 4496 Civil Term ACTION IN DIVORCE ACCEPTANCE OF SERVICE I, Marylou Matas, Esquire, represent Mickey Updegraff, in the above-captioned matter; I hereby accepted service of the Notice to Defend and Complaint in Divorce on or about the date listed below, which was filed by Plaintiff's Attorney under the above- captioned number and I hereby affirm I was authorized to do so. Date: `~ d~ ~- Mary s, Esquire ~- 26 W. Hig Carlisle, Pa. 17013 (717) 243-6222 ATTORNEY FOR DEFENDANT ~(l.E[3~r~~G`~ ZffQ9 JUG. 22 ~'M I ~ 00 VLt~~i~.'a~r~d iL.i l.~"..tV~~l 3 ~''a.,.,i ~I~ YJ~~yri~~~i(r'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KAREN M. UPDEGRAFF V. MICKEY UPDEGRAFF NO 2009 - 4496 Civil Term DIVORCE DECREE AND NOW, ~~•, 2~"'' Qor v , it is ordered and decreed that KAREN M. UPDEGRAFF plaintiff, and MICKEY UPDEGRAFF ,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; all issues have been resolved by the parties marriage settlement agreement. By the Court, 9 Atte J. Prothonotary 3- ~ ~ ~a ~ - ~~ ~~~ ~ ~~~ ~~~