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Home My WebLink About09-4616TOD H. MUTHIG, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - V G/ b CIVIL TERM HEATHER M. MUTHIG, Defendant CIVIL ACTION-LAW 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. 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 TOD H. MUTHIG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - 441-14, CIVIL TERM HEATHER M. MUTHIG, CIVIL ACTION-LAW Defendant DIVORCE COMPLAINT 1. Plaintiff is Tod H. Muthig, an adult individual who currently resides at 318 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Heather M. Muthig, an adult individual who currently resides at 318 Stumpstown Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff has been bona fide resident in 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 October 17, 1998 in Grahamsville, New York. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Date: 1-1 Respectfully submitted, O'BRIEN, BARIC & SCHERER ichael A. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: Tod H. uthig OF FrLfiL RV C?.tAy?;rv ,,4 F`? PLL; Cr,? (. ?/SAG TOD H. -MUTHIG, Plaintiff V. HEATHER M. MUTHIG, Defendant IN THE, COURT OF COMMON PLEAS OF CUMB RLAND COUNTY, PENNSYLVANIA NO. 2009-4616 CIVIL TERM CIVIL CTION-LAW IN DIV RCE AND NOW, this I C' _ day of ' Esquire, Attorney for Defendant, Heather M. M Divorce Complaint. , 2009, I, John F. King, ig, hereby accept service of the John F. King, Esquire"/" Ft L L'. 21C H J', - 17 t t ;~ JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 19 S. Hanover Street Attorney for Defendant Suite 103 Carlisle, PA 17013 Tel.: (717) 258-4343/Fax: (717) 422-5526 TOD H. MUTHIG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. HEATHER M. MUTHIG, Defendant NO. 2009-4616 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 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, 1 Courthouse Square, Carlisle, PA. 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, PA 17013 1-800-990-9108 717-249-3166 Respectfully submitted, JOHN F. KING LAW, P.C. By: F. King, Esquit Hanover Street 103 Carlisle, PA 17013 (717) 258-4343 TOD H. MUTHIG, Plaintiff V. HEATHER M. MUTHIG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-4616 CIVIL ACTION -LAW IN DIVORCE ANSWER WITH COUNTERCLAIM AND NOW comes the Defendant, by and through her attorneys, John F. King Law, P.C., and answers the Complaint and brings this Counterclaim, averring as follows: ANSWER 1-7. Pursuant to Pa.R.C.P. 1920.14, no answer is required. COUNTERCLAIM COUNTI ALIMONY AND ALIMONY PENDENTE LITE 8. The prior paragraphs of this Complaint are incorporated by reference. 9. Defendant is unable to sustain herself during the course of this litigation. 10. Defendant lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 11. Defendant requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Defendant requests the Court to enter an award of Alimony Pendente Lite until final hearing and thereupon to enter an award of Alimony in her favor. Respectfully submitted, JOHN F. KING LAW, P.C Date: /I O ? By: John F. King, Esquire 19 S. Hanover Street Suite 103 Carlisle, PA 17013 (717) 2584343 VERIFICATION I, John F. King, Esq., hereby acknowledge that I am the attorney for the Defendant in the foregoing action; that I have read the foregoing Answer with Counterclaim; and the facts stated therein are true and correct to the best of my knowledge„ information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. This verification will be Dated: 10 /1 6? lo l TOD H. MUTHIG, Plaintiff V. HEATHER M. MUTHIG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-4616 : CIVIL ACTION -LAW : IN DIVORCE CERTIFICATE OF SERVICI3 I, John F. King, Esquire, hereby certify that on October 19, 2009, I served a copy of the within Answer with Counterclaim, by hand delivery as follows: Michael A. Scherer, Esquire 19 West South Street Carlisle, PA 17013 JOHN F. KING LAW, P.C. Suite 103 Carlisle, PA 17013 (717) 258-4343 iF c)d P 4 Q#7 e?sk- Z# ?)-3a i33 e o? ll!U D2 6