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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 2C C9 Vi i 03 28 P1, 12: 1 a t ? as ? 3q 0 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 '?? ? pyona i?x? 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 rlid??s 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. q� / /2... 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