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HomeMy WebLinkAbout10-1469r STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF OF 4we""CHIPM 7010 MaR -2 ph 2% is OJOALACJ ?i SCOTT A. CALAMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MELANIE E. CALAMAN, : NO.2010 - /161 CIVIL TERM Defendant : IN DIVORCE NOTICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 9 3 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 in 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, Carlisle, Pennsylvania 17013. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ti STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF SCOTT A. CALAMAN, Plaintiff V. MELANIE E. CALAMAN, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2010 - yb q CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Scott A. Calaman, an adult individual residing at 6 Mountain View Lane, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Melanie E. Calaman, an adult individual residing at 66 Gobbler Knob Road, Newville, Cumberland County, Pennsylvania 17241. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on February 19, 1993, in Mt. Holly Springs, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said parry has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ?7 -Z -1 [7 , 2010 -z- , 2010 BY: Scott A. Calaman, Plaintiff WOLF & WOLF, Attorneys at Law STACY WOLF, ESRU lli SuprerrV Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff I. .?:-gy , pp STACY B. WOLF, ESQUIRE ?+ 7 qn}A 20 ttU , ii1? AR .. ATTORNEY ID NO. 87380 10 WEST HIGH STREET CARLISLE PA 17013 ` Y (717) 2414436 ATTORNEY FOR PLAINTIFF SCOTT A. CALAMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MELANIE E. CALAMAN, : NO. 2010 - IN &q CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 2010 SCOTT A. CALAMAN, Plaintiff I RLEL-C '''UP STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF 2010 R 16 N, 1 1:37 CUM, 17 'y SCOTT A. CALAMAN, Plaintiff V. MELANIE E. CALAMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2010 -1469 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) NOW, Stacy B. Wolf, Esquire, being duly sworn according to law, does depose and state: 1. That she is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about March 9, 2010, by certified mail "restricted delivery," addressed to the defendant at 66 Gobbler Knob Road, Newville, Pennsylvania 17241 return receipt No.7008 1830 0003 5942 0505. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. March 2010 ' STACY B. OLF Attorney for Plaintiff i ¦ Complete items 1, 2, and 3. Also complete A. Signature ? Agent item 4 if Restricted Delivery is desired. X ¦ Punt your name and address on the reverse so that we can return the card to you. B. R ed y (PH C. pate of Delivery me) a ¦ Attach this card to the back of the maiipiece, l b / or on the front If space permits- i ivery D. Is frO m item 1? 0 Yes . 1. Article Addre ssed to: If Y ? No below: 0 \ n P? - d MaIC? Express Mail Gertm red Return Receipt for Merchandise T Mail C.O.D. Delive ? ra Fee) Yes 4.Restricted ry 2. Article Number % 7008 1830 0003 5942 0505 (rmnsferfrom sembelabel) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 Ln1 CERTIFIED MAIL RECEIPT Q I• Ln Q N u1-i Postage $ °"" '1wd? #1rs M CertHled Fee t A & Q Q Return Receipt Fee Q (Endorsement Required) Mere Reatrsemnt Delivery Fes E3 (Endorsement Required) M CO Total Postage & Fees $ 6@@ru?? o CO o ... _ (? nr IM Rnr u.. I n I .. ?, t 1 ; r-------- ------, ?._i.. STAGY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF FlLCC-~ ~ u~ :FAY ~,F T}-i~ ~,r T ~ h';'~T,' ~~ 2040 J~4_ -1 4'4~ 3~ Ord SCOTT A. CALAMAN, : IN THE COURT OF C ~ ~EAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. MELANIE E. CAI.AMAN, Defendant CIVIL ACTION -LAW N0.2010 -1469 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about March 2, 2010 and served upon defendant on or about March 9, 2010. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. ~~ , 2010 - SC TT A. CALAMAN SCOTT A. CALAMAN, Plaintiff v. MELANIE E. CA~i.AMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2010 -1469 CIVIL TERM IN DIVORCE AIVER OF NOTICE OF INTENTION TO RF()iTF ENTRY OF A DIVORCE ('REF SJ NDER SECTION 3301( 1 F TH nNORCE CODE C"~ N d " p T7 _ ~ -~ ~ ~-~ ` -7~'` c .a F_4 ~ t-r~ . ~, ~ 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. 2010 ~, v SCOTT A. CALAMAN STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEX FOR PLAINTIFF SCOTT A. CALAMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA Y. : CNIL ACTION -LAW ~ ~ ;=, ~- ~ ~y MELANIE E. CAi.AMAN, : NO.2010 -1469 CIVIL TERM ~~,'~ ' ~:^ ~~? _; . r Defendant : IN DIVORCE r.> .' ~ ~.`~ t ~ } DEFENDANT'S AFFIDAVIT OF CONSENT` ~ ~ t,, _~ ~' 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about March 2, 2010 and served upon defendant on or about March 9, 2010. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. ~-~~' ~-~ , 2010 SCOTT A. CALAMAN, Plaintiff v. MELANIE E. CALAMAN, Defendant 1. 2. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2010 -1469 CIVIL TERM IN DIVORCE c~ - c Q „ .-~,~ E.F_ C.. ---1 `-~'`r. ~AIVER OF NOTICE OF INT T i-- nir~T- EN ION TO FO T T =~- - --, ; rn ENTRY OF A DIVOR EC E -' ~-, , ~ ~TNDER SECTION 3301(Cl OF THE DIVORCE CODE ' . ~~~: -° ~. -y .r.._ - Cv; i' ~. f. ; f; ~ ii . ~ ;.~ ~ I consent to the entry of a final decree of divorce without notice. .,,: •< I understand that I may lose rights concerning alimony, division of property, lawye r's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. ~~i ,c r7 Q ~, ~ , 2010 MELANIE E. C Scott A. Cala an Melanie E. C laman IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 2010-1469 DIVORCE DECREE AND NOW, Scott A. Calaman ~(~ 020 CO , it is ordered and decreed that Melanie E. C~alaman bonds of matrimony. plaintiff, and defendant, are divorced from the Any existin~ spousal support order shall hereafter be deemed an order for alimony pendente ~ite if any economic claims remain pending. The court r~tains jurisdiction of any claims raised by the parties to this action for which a final or~er has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, ttest: .1. rothonotary -7•ao-lO `7 .r20 ~ ~O ~'~,c='--. toy ~cL:, l~ /v o~ csL M~`.1es~ -~O -Fo ~Jo1-~