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Home My WebLink About01-1462KELLY A. MELEEN, Plaintiff JAMES G. MELEEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Ot- IqCgz , : : CIVIL ACTION - LAW : IN 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 annulmem 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 that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Associatbn 2 Liberty Avenue Carlis~, PA17013 717-249-3166 KELLY A. MELEEN, Plaintiff JAMES G. MELEEN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : :NO. 01- ~ ,t L, 2- ~ q~g~- : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, KELLY A. MELEEN, by and through her counsel, Kollas and Kennedy, and respectfully represents as follows in support of the within Complaint: 1. Plaintiffis Kelly A. Meleerg an adult individual currently residing at 600 Bridge Street, New Cumberland, Cumberland County, PA 17070. PlaintifFs Social Security Number is 194-60- 6930. 2. Defendant is James G. Meleen, an adult individual currently residing at 8 Umberto Avenue Rear, New Cumberland, Cumberland County, PA 17070. Defendant's Social Security Number is 071-50-2089. 3. Plaintiffand Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 11, !996, in Sugar Grove, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and th. at Plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant are both citizens of the United States. COUNT I - DIVORCE PURSUANT TO §3301¢c~ OR (d) OF THE DIVORCE CODE 8. Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. The marriage of the parties is irretrievably broken. WHEREFORE, the Plaintiffprays that a Judgmem and Decree be entered as follows: (a) As to Count I, that a decree be entered divorcing Plaintifffi'om the bonds of matrimony with the Defendant pursuant to 23 Pa. C.S. Section 3301 (c) or (d). RESPECTFULLY SUBMITTED, I .MD .a~NKo .o l~4~nne dy, Esquire KOLLAS AND KENNEDY 1104 Femwood Avenue, Suite 104 Camp Hill, Pennsylvania 17011 Telephone: (717) 731-1600 ATTORNEY FOR PLAINTIFF 2 KELLY A. MELEEN, Plaintiff JAMES G. MELEEN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, KELLY A. MELEEN, verify that the statements made in the foregoing 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.A. 4904, relating to unswom falsification to authorities. Kelly A. Me(~n DATE: KELLY A. MELEEN, Plaintiff JAMES G. MELEEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYI.VANIA : NO. 01-1462 Civil Term : : CIVIL ACTION - LAW : IN DIVORCE pRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record together with the following infornmttion, to the Court fbr entry ora divorce decree: 1. Ground for a divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and nmm~r of service of the Complaint:03/16/01 Certified mail, restricted delivery 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit ofconsem required by Section 3301(c) of the Divorce Code: by the Plaintiff0?/06/01, by the Defendant 06/30/01. Divorce Code: (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the (2) Date of service of the plaintiWs affidavit upon the Defendant: 4. Related claim pending: Nom. 5. Complete either (a) or (b) (a) Date and nmuner of service of the notice ofintemion to file pmecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301 (d) of the Divorce Code: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary 07/10/01. Date Defendant's Waiver of Notice in Section 3301(c) was fi~ with the Prothonotary 07/10/01. KEIJ.Y A. MELEEN, Plaintiff JAMES G. MEI,EEN. Del~ndant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-1462 Civil Term : : C1VIE ACTION -. LAW : iN DIVORCE PROOF OF SERVICE · Complete items 1, 2, and 3. A~so complete item 4 if Restricted Delivery is desired. · Pdnt 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: A. Received by (Please Pdnt Clearly) [] Agent elivery address different from item 1 ? [] Yes enter delivery address betow: [] No Service Type Certified Mail [] Express Mail [] Registered '~Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delive~? (Extra Fee) ~ Yes 2. Article Number (Copy from service label) PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 BY: 1104 Fernwood Avenue Suite 102 Camp Hill, PA 17011 (717) 731-1600 Attorney for Plaintiff II KELLY A, MEI.EEN, Plaintiff' .lAMES G. MELEEN, Defendant IN '['HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1462 Civil 'Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) or (d) of the Divorce Code was filed on March 13. 2001, and was served upon the Detbndant on or about March 16, 2001. The Proof of Service was tiled on March 21. 200 l. 2. The marriage of the Plainliffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. t 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: "[ J {~ / O I Kelly A. Mele~n KELLY A. MELEEN, Plaintiff .lAMES G. MELEEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1462 CMl Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §330l(c) OR (d} OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's t~es or expenses ifI 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 tree 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. Kelly~. MeLk · r ~ 0 ffi ffi il I I1/[ Illl Ill] [ il Il I I[1 ............................ ~ KELLY A. MEI,EEN, Plaintiff' JAMES G. MELEEN, Defbndant IN 'FILE CO1JRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1462 Citvil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSE1Vr l. A Complaint in D vorce under §330 l(c) or (d) of the Divorce Code was filed on March 13, 2001, and was served upon the Defendant on or about March 16, 2001. The Proof of Service was filed on March 2l, 2001. 2. The marriage of the PLaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, &ws~on ofprope y, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are tree 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: es~. Meleen v v - z~ ~Z o;. ~Zz KELLY A. M[';LEEN, Plaimiff JAMES G. MELEEN, Defendant IN THE COURT OF COMM()N PI,EAS OF CI IMBERLAND COUNTY, PENNSYLVANIA NO. 01-1462 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OR (d} OF THE DIVORCE CODE I. 1 consent to the entry of a final decree of divorce without notice. 2. ! understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is emered by the Court and that a copy of the decree will be sent to me immediately alter it is tiled with the Prothonotary. I verify that the statemems made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn fialsification to authorities. DATED: ((o/,~O/O { fitJmes G. Meleen OF CUMBERLAND IN THE COURT Of COMMON PLEAS COUNTY STATE OF ~ PENNA. ................. ~%ai~&¢~ ................ Versus .... CA~E$ ~..~.~;~E~:~, ................ ............. D~fendant . .. DECREE ltd DIVORCE AND NOW .............. /~-7 .... /'~' .... 1,'~..,~..~!'., it is ordered and decreed that . ?.~.~.~ ..A:..~.e..~.e.e.n. .............................. plaintiff, and ...4 .~.eA .6,..~.~!.e.e.n. ..................................... defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered;