HomeMy WebLinkAbout09-59140
Law Office of Theresa Barrett Male
Theresa Barrett Male, Esquire, ID # 46439
Andrea Hudak Duffy, Esquire, ID # 60910
513 North Second Street
Harrisburg, PA 17101-1058
(717) 233-3220
tbm tbmesquire.com
Attorneys for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MARK W. NELSON
Plaintiff
V. NO. 09- Civil Term
KIMBERLY A. NELSON
Defendant CIVIL ACTION - 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, Cumberland County Courthouse, High and Hanover
Streets, 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. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ANOUT 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
2 Liberty Avenue, Carlisle, PA 17013
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. You must attend the scheduled
conference or hearing.
BY THE COURT:
J.
2
Law Office of Theresa Barrett Male
Theresa Barrett Male, Esquire, ID # 46439
Andrea Hudak Duffy, Esquire, ID # 60910
513 North Second Street
Harrisburg, PA 17101-1058
(717) 233-3220
tbrn cD.tbrnesguire.corn
Attorneys for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MARK W. NELSON
Plaintiff
V. : NO. 09- Civil Term
KIMBERLY A. NELSON
Defendant CIVIL ACTION - DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is MARK W. NELSON who currently resides at 1385 Armitage Way,
Mechanicsburg, Cumberland County, Pennsylvania since in or around July 2008.
2. Defendant is KIMBERLY A. NELSON who currently resides at 1016
Wansford Road, Mechanicsburg, Cumberland County, Pennsylvania since in or around
March 1995.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The parties were married on October 13, 1989 in Lincoln, Nebraska.
5. There have been no prior actions for divorce or annulment between the
parties.
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.
Wherefore, Plaintiff requests the Court to enter a divorce decree.
Law Office of Theresa Barrett Male
Theresa BarretrMale, Esquire, ID # 46439
Andrea Hudak Duffy, Esquire, ID # 60910
513 North Second Street
Harrisburg, Pennsylvania 17101
(717) 233-3220
Attorneys for Plaintiff
Date: August 24, 2009
2
s
VERIFICATION
I verify that the statements made in the foregoing document 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: August dA , 2009
ALE! €i xARY
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Law Office of Theresa Barrett Male
Theresa Barrett Male, Esquire, ID # 46439
Andrea Hudak Duffy, Esquire, ID # 60910
513 North Second Street
Harrisburg, PA 17101-1058
(717) 233-3220
tbma-tbmesquire.com
Attorneys for Plaintiff
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MARK W. NELSON
Plaintiff
V. NO. 09-5914 Civil Term
KIMBERLY A. NELSON
Defendant CIVIL ACTION - DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint in Divorce. I certify that I am authorized to accept
service on behalf of defendant.
Smigel, Anderson & Sacks, LLP
V
,,L Ann V. Levin, Esquire
Date: -e5/ - / D '51- , 2009
OF TFE PRO-t unw)TAnY
2009 SEP -4 FM 310 4
PENMYLMAW
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MARK W. NELSON
Plaintiff
V.
KIMBERLY A. NELSON
Defendant
TO THE PROTHONOTARY:
NO. 09-5914 Civil Term
CIVIL ACTION - DIVORCE
PRAECIPE
Please withdraw the appearance of Theresa Barrett Male, Esquire and enter the
appearance of J. Paul Helvy, Esquire as counsel for Plaintiff in this proceeding.
Date: November 5, 2009
Date: November J , 2009
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T esa Barrett Male, Esquire
01- T L
2009 NOY 10 Aft 10.0 5
4't LL7, ! M t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MARK W. NELSON
V.
KIMBERLY A. NELSON NO. 09-5914
DIVORCE DECREE
AND NOW, 1) LL 'It s? 9: ?1 AM+ 1011 , it is ordered and decreed that
MARK W. NELSON , plaintiff, and
KIMBERLY A. NELSON , 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
By the Court,
?Wt. ?A
Attest: J.
Prothonotary
'I I
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FILED-OFFICE:'
BLANK ROME LLP OF THE PROTHON.OTARf
BY: MARY T. VIDAS, ESQUIRE Attorneys for Defendant
Attorney I.D.No. 41546 2013 SEP 13 AM I t: 4 5,
BY: MICHELLE PISCOPO, ESQ'Ld-'k COUNTY
Attorney I.D.No. 87891 PENNSYLVANIA
One Logan Square
Philadelphia, PA 19103
215-569-5500
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION—LAW
MARK W. NELSON,
NO. 09-5914
Plaintiff,
V.
KIMBERLY A. NELSON,
IN DIVORCE
Defendant.
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Defendant in the above matter, after the entry of a Final
Decree in Divorce dated December 21, 2011,hereby elects to resume the prior surname of
GREENWALD, and gives this written notice avowing her intention pursuant to the provisions of
54 P.S. § 704.
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Dated:
K "BERLYA.4'jREENWALyfT
COMMONWEALTH OF PENNSYLVANIA:
ss.
COUNTY OF /7
On the -3 day of 2013, before me,the Prothonotary or a Notary
Public,personally appeared the above affiant known to me to be the person whose name is
subscribed to the within document and acknowledged that she executed the foregoing for the
purpose therein contained.
IN Witness Whereof, I have hereunto set my hand and official sea].
7MCt k-S Ict
P *Aqs
Prothonotary
or tary Public
COMMONWEALTH IDP PENNSYLVANIA
Notarial Seal
Bryce Cree,Notary public
133501.00601/12340320v.I Hampden Twp.,Cumberland County
My commission Expires Feb.16,2016
MEMBER,PENNSYLVANIA 05tiOCAA 110-4 OF NOTARIES