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Home My WebLink About09-7896• • .L Patricia Matson, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Glenn Matson, Defendant : NO. 09- 7?16 CIVIL TERM 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, 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, 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 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. . . 146 PATRICIA MATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE GLENN MATSON, Defendant :NO. 09- -7 ?lG CIVIL TERM DIVORCE COMPLAINT The plaintiff, Patricia Matson, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. § 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Patricia Matson, who currently resides at 10 East Main Street 1st Floor, Camp Hill, Cumberland County, PA 17011, since March 2005. 2. Defendant is Glenn Matson, who currently resides above the Colony House Restaurant, at 125 West Main Street, Mechanicsburg, Cumberland County, PA 17055, since approximately May 1999. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on December 20, 1958 at Harrisburg, Dauphin County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since Summer 2004. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. .,4. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Edward W. Chase Certified Legal Intern ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date ///,/10 le9 Plaintiff Patricia Matson 2?Q9 NOV 1 3 ANN, ?. ? __r r -P PATRICIA MATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE GLENN MATSON, Defendant NO. 09- 7016 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Patricia Matson, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date /D, 1v07 __4f Z-,-/ -2?_ Edward W. Chase Certified Legal Intern ROBEPVT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 -TPE tIK 2009 NOV 13 AY, G Patricia Matson, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Glenn Matson, Defendant NO. 09 - 7896 CIVIL TERM CERTIFICATE OF SERVICE I, Edward W. Chase, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Glenn Matson, residing at Colony House Restaurant (room above), 125 West Main Street, Mechanicsburg, PA 17055, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Glenn Matson, on the the 16th day of November, 2009 as evidenced by the attached green card. Edward W. Chase Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ¦ Complete items 1, 2, and 3. Also complete Itern 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 H space permits. 1. Article Addressed to: Ienn 129a-15r C'D/pm[// /?pLlSC ?tS?nura/! C r49'M a free) .Sfi'Pef- I*,-1b'71C5buff, P'Q i gass- A. X Agent B. Received by (Printed Name) C. Date of Delivery D. Is delive om it 0 Yes eprom If YE ` delivery adder 0 No s g wOV 16 20U? `? . 3. Service 1j _r r U S P Express Mali Registered ),petum Receipt for Merchandise 0 insured Mau 0 C.O.D. 4. Restricted Delivery? (Fria Fee) 19-yes 2'' 7008 1140 0001 6165 0675 Ps Form 3811, February 2W4 Donr¦Mr flelrsn I9soelpt 102595-02•M-1540 t OF THE ?M.y 2099 NOV 20 PM 3: 52 'UNTY Patricia Matson Plaintiff v. Glenn Matson Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 09-7896 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in Summer 2004, and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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/~ ~ ~ ~%~. £~~ ~ ~~ ~ ~ Plaintiff „ ;-_ _ . ,,; .,~; r ~ 7~~~~,,C~~ Patricia Matson , 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION-LAW DIVORCE Glenn Matson, . Defendant NO. 09-7896 CIVIL TERM CERTIFICATE OF SERVICE I, Edward W. Chase, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Plaintiffls Affidavit Under Section 3301 (d) of the Divorce Code, on Glenn Matson, residing at Colony House Restaurant (room above), 125 West Main Street, Mechanicsburg, PA 17055, by depositing a copy of the same in the first class, United States mail, postage prepaid on the 1St of December 2009. ~~. Edward .Chase Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ,- ~" t'i is t ` ~ __ ~ _, '~°, - _. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Patricia Matson V. Glenn Matson NO. 09-7896 Civil Term DIVORCE DECREE AND NOW, F e ~~,,~,~T 2 ~.~t~ , it is ordered and decreed that Patricia Matson plaintiff, and Glenn Matson ,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,