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HomeMy WebLinkAbout02-0218KRIEMHILDE C. MANGAN Plaintiff MATTHIAS H. HELLELBARTH Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO.C).g..- ~.2.J~ (~,o',(._ ~'~ · CIVIL ACTION - DIVORCE NOTICE TO DEFEND 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 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 grounds for the divorce are indignities or irretrievably breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013, (717)240-6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERYT, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLIAM 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. Cumberland County Lawyer Referral Service 4 Liberty Avenue Carlisle, PA 17013 717-249-3166 KRIEMHILDE C. MANGAN Plaintiff MATTHIAS H. HELLELBARTH Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA 'NO. · CIVIL ACTION - DIVORCE COMPLAINT IN DIVORCF AND NOW HERECOMES, the Plaintiff, by and through her attorney, Lisa M. Greason, Esquire and respectfully represents: 1. Plaintiff is Kriemhilde C. Mangan, an adult individual who currently resides at 49 Cardinal Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Matthias H. Hellelbarth, an adult individual who currently resides at 49 Cardinal Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on the December 26, 1999, in Carlisle, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or navel service of the United States or its allies within the 9rovisions of the Soldiers' and Sailors' Civil Relief Act of 1940 and its amendments. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. COUNTI-DIVORCF 8. The causes of action and sections of the Domestic Relations Code under which Plaintiff is proceeding are Section 3301(c). 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant will also file such an Affidavit. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT II - EQUITABLE DISTRIBUTION 11. The prior paragraphs of this Complaint are incorporated by reference. 12. The public policy of the Commonwealth of Pennsylvania encourages parties to a martial dispute to negotiate a settlement of their difference. 13. While no settlement has been reached as of the date of the filing of the Complaint, Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant. 14. The parties may enter into a written agreement with regard to real and personal property and debt division. In the event that the parties execute such an agreement, Plaintiff desires that such written agreement be approved by the Court and ~ncorporated, but not merged, in any divorce decree dissolving the marriage between the parties. WHEREFORE, if a written settlement agreement is reached between the parties to the time of the hearing on this Complaint, Plaintiff respectfully requests 3ursuant to the Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code, the Court approve and incorporate, but not merge, such agreement in the final divorce decree. Respectfully Submitted, GREASON LAW OFFICE Date Li~sa M~Gr , Esquire (7'17) 24~-3030 ID #78269 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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~ KRIEMHILDE C. MANGAN KRIEMHILDE C. MANGAN Plaintiff · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02/~' -- 2002 MATTHIAS H. HELLELBARTH Defendant : CIVIL ACTION - DIVORCE AFFIDAVIT OF SERVICE BY MAIL I, Lisa M. Greason, Esquire, being duly sworn according to law, deposes and says that I mailed a copy of the Complaint in Divorce filed in this matter b y certified registered mail, return receipt requested, addressee only, to the Defendant at 49 Cardinal Drive, Carlisle, Pennsylvania, on the .~ day of January, 2002. The return receipt signed by the Defendant is evidence of delivery to her and is attached hereto as Exhibit "A". Date ~..~'sa M.' Gre, a'~0n~,~squire 50 East Hi(~h Stile'et Carlisle, PA 17013 (717) 241-3030 ID #78269 · Compile Items 1, 2, and 3. AJao ~omple{e Itlm 4 If Reetrlcted D~ivef,/La deeired. · Pdnt your name and addme8 on the reveme ·/etach th~ card to the beck of the m~rx'ece, D. I~d~v~yaddm~dllt~entf*~nl~ml? f=lYee KRIEMHILDE C. MANGAN Plaintiff MATTHIAS H. HESSELBARTH Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 218 2002 : CIVIL ACTION - DIVORCE PRAECIPE TO WITHDRAW To the Prothonotary: Kindly withdrawal and discontinue the above caption action on behalf of the Plaintiff, without prejudice. Respectfully Submitted, GREASON LAW OFFICE Date Lisa M. Greason, F_~qui)re P.O. Box 385 Carlisle, PA 17013 (717) 241-3030 ID #78269