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Home My WebLink About09-6234REBECCA McKINLEY FRY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 09-1.22Y I STEVEN MICHAEL FRY, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend agai*?t the claims set forth in the following pages, you must take prompt action. You are w reed 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 bee tered against you for any other claim or relief requested in these papers by the Pl tiff. You may lose money or property or other rights important to you, including c> ,3tody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown l?f the marriage, you may request marriage counseling. A list of marriage course ors is available in the Office of the Prothonotary, Cumberland County Courthouse; One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISIO OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. I, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT O CE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO ND OUT WHERE YOU CAN GET LEGAL HELP. I. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD CAB-ISLE, PA 1 70 1 3 (717) 249-3166 OR (800)990-9108 I'' ABOM ?' ICuruiaxis Michelle L. Sommer, Esquire Attorney I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717)249-0900 REBECCA MCKINLEY FRY, IN THE COURT OF COMMON 1I,EAS Plaintiff CUMBERLAND COUNTY, PA v. NO. 0 4 - G 2 3Y C'.c?-?-! i? STEVEN MICHAEL FRY, CIVIL ACTION - LAW Defendant IN DIVORCE I'? II COMPLAINT 1 . Pla>ntiff is Rebecca McKinley Fry, who currently resides at 139 So?i?hside Drive, Newville, Cumberland County, Pennsylvania. 2. Defendant is Steven Michael F who currentl incarcera 'I ry, y ted at the; ? State Correctional Institution at Mahanoy, 301 Morea Road, Frackville, Schjylkill I County, Pennsylvania. I'? I 3. The Plaintiff and Defendant have been bona fide residents i? the I, I Commonwealth fo.r at least six (6) months immediately previous to the fig of this Complaint. 4. The Plaintiff and Defendant were married on March 12, 2009, in P atka, I' Putnam County, Florida. I? I 'I'll COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated '!herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce I Code, 3301(a) (5), (a) (G), (c) and (d), in that: a. Expect that the Defendant will be sentenced to imprisonment for 41 term of two or more years upon conviction of having committed a crim¢j I' b. Offered such indignities to the innocent and injured spouse as to tender that spouse's condition intolerable and life burdensome c. The marriage of the parties is irretrievably broken. d. Plaintiff and Defendant have lived separate and apart since after Leven (7) days of marriage the Defendant was arrested in Florida on Mardi 19, 2009, on a parole violation; and as a result, they continue to live separate and apart and will do so while he remains incarcerated. 8. Plaintiff has been advised that counseling is available and that Plaintiffs may have the right to request that the court require the parties to participate in such counseling. I' 9. The Plaintiff nor the Defendant in this action are members of the A1lLmed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Di*orce. I? Respectfully submitted, DATE q'16 "()q ABOM & KUTULAKIs, L.L.P. Michelle L. Somm , Esquire Attorney ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Plaintiff r VERIFICATION I, REBECCA M. FRY, verify that the statements made in this Divorce I'Complaint are true and correct to the best of my knowledge, information, and Ilbchef I understand that false statements herein are made subject to the penalties Of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. Date `1- 1 ?(`6?t CERTIFICATE OF SERVICE AND NOW, this 15`h day of September, 2009, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct cppy of the foregoing Divorce Complaint, upon the deposited, same in the United Sues Mail, prepaid addressed to the f g: Ir".1 e Defendant by depositing, or causin Into be ? Certified mail and First-class mail, pl l stage Steven Michael Fry Inmate #GX 4964 State Correctional Institution at Mahanoy 301 Morea Road Frackville, Pennsylvania 17932 Respectfully submitted, A.Bom drKuTur_4s, LLP. Michelle L. Sommer, Esquire Supreme Court ID 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff FILES. c l OF THE ? ? , ,S??T41?Y ? g. s? _ .ABOM & U ULAKIS Michelle L. Sommer, Esquire Attomey I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 REBECCA McKINLEY FRY, Plaintiff V. STEVEN MICHAEL FRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009-6234 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF ERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve a true and correct copy of the Complaint under Sections 3301 (a)(5), (a)(6), (c) and (d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, postage prepaid, on Steven Michael Fry, at Frackville, Pennsylvania, addressed as follows: Steven Michael Fry Inmate #GX 4964 SCI Mahanoy 301 Morea Road Frackville, PA 17932 Return card acknowledging receipt on September 17, 2009 is attached as Exhibit "A". Date: a V ABom & KUTULAKis, L.L.P. Michelle L. So , Esquire Attorney I.D. No.: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff A. `V.4n O?pw B by (Pdn ) C. a of Delivery (7? D. PWdeW1lhw,.ny address different from Itern 1 ? ? Yes If YES, enter delivery add low: ? No Type 3. Ser?vM ? I 13 Express mail ? Retumm Receipt for Merchendhs ? insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7005 2570 0000 3804 1183 rna?aAerlron ssndoe (abet) _._ - -----------_- ...- _ __ _ PS Form 3811, February 2oo4 Domestic Return Receipt 102595-02-WI540 ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 34eV per, T' W'a?4- 4t-6-1 y9?? 5 ?y Naha n? EXHIBIT `A" OF T} 'r 7*, I ARY 2099 Sir.l 2 1 1=k`i ?4' v r V OM & Nu ULAKIS Michelle L. Sommer, Esquire Attomey I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 REBECCA McKINLEY FRY, Plaintiff V. STEVEN MICHAEL FRY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009-6234 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw the Divorce Complaint in the above-referenced matter. Respectfully submitted, Awm&KUTVL4KvS L.L.P. DAB q nOq ?- Z) Michelle L. So er, Esquire Attorney ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorng for the Plaintif f r AND NOW, this 24th day of September, 2009, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true and correct copy of the foregoing Divorce Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First- class mail, postage prepaid addressed to the following: Steven Michael Fry Inmate #GX 4964 State Correctional Institution at Mahanoy 301 Morea Road Frackville, Pennsylvania 17932 Respectfully submitted, ABOM & KUTULAIGS, LLP. &WUL k th? Michelle L. Sommer, Esquire Supreme Court ID 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff 2009 SEP 24 PH 2. 10 ;:jN? Ili