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Home My WebLink About10-1991 NANCY HAAS Plaintiff V. MICHAEL HAAS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEWYVANIA NO. 16- / / I 0 CIVIL ACTION - LAW N DIVORCE ?. c ? Orr, NOTICE TO DEFEND AND CLAIM RIGHTS ?? 6 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, at the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 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, 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 `7 S .. uv ,Zke?riiwc l y -3 I Q d eo oXh ct14: lO?%? p 1-0(?a -31 46 NANCY HAAS Plaintiff V. MICHAEL HAAS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Nancy Haas, by and through her attorneys, Joseph D. Caraciolo, Esquire and Foreman & Caraciolo, P.C., and makes the following Complaint in Divorce and, in support thereof, avers as follows: 1. The Plaintiff, Nancy Haas, is an adult individual who currently resides at 100 South First Street, Unit C, Lemoyne, Cumberland County, Pennsylvania. 2. The Defendant, Michael Haas, is an adult individual who currently resides at 323 Big Spring Road, Etters, Pennsylvania. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married by formal ceremony on December 31, 2005 in York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. 10. There is one minor child to this marriage, Dominic Haas, born July 15, 2008. WHEREFORE, the Plaintiff, Nancy Haas, respectfully requests that this Honorable Court enter a decree of divorce in this matter. COUNT II - EQUITABLE DISTRIBUTION 23. Paragraphs one (1) through twenty-two (22) are incorporated herein by reference. 24. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, the Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to § 3502(a) of the Divorce Code. COUNT III - REQUEST FOR ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, AND ALIMONY UNDER SECTIONS 3701(A) AND 3702 OF THE DIVORCE CODE 25. The prior paragraphs, one (1) through twenty-four (24) of this Complaint are incorporated herein by reference thereto. 26. Plaintiff is unable to sustain herself during the course of litigation. 27. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 28. Plaintiff requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3701(a) and 3702 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter an award of alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to Sections 3701(a) and 3702 of the Divorce Code. o3 o? lc? Date Respectfully Submitted, FORE)gATCAWIOLO, P Pseph D. Ca6&iolo, Esquire Attorney ID No. 90919 112 Market Street, 6th Floor Harrisburg, PA 17101 (717) 236-9391 - Telephone (717) 236-6602 - Facsimile I • NANCY HAAS Plaintiff V. MICHAEL HAAS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date OF CV David O. Buell- 2 £ Me' Wfnee X Simpson Prothonotary 4 , :� i p 1s` Deputy Prothonota � o , T Z KirkS. Sofionage, ESQ --��' j s- h Irene E. Morrow Solicitor 1750 2ni Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania .0—/99I CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carliis[e, PA 17013 • (717)240-6195 • Fax(717)240-6573