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Home My WebLink About01-4915BROUJOS & GILROY, P. c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET --?._ CARLISLE, PENNSYLVANIA 17013 717-243-4574 766-1690 JOHN D. MAINS, SR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION -LAW LISA M. MAINS, NO.2001- y915' CIVIL TERM Defendant 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 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 JOHN D. MAINS, SR. Plaintiff V. LISA M. MAINS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 2001- IN DIVORCE COMPLAINT CIVIL TERM AND NOW, comes the Plaintiff, by and through his attorney John H. Broujos, of Broujos & Gilroy, P.C., and sets forth the following: Plaintiff is John D. Mains, Sr., who currently resides at 10 Bill Dugan Drive, Etters, Cumberland County, Pennsylvania. 2. Defendant is Lisa M. Mains, who currently resides at the home of her mother, Patrice Saurman, 35 Highland Drive, Camp Hill, PA 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The parties were married on February 25, 1989 in Lisburn, York County, Pennsylvania. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 6. 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. In accordance with Section 3301(c) of the Divorce Code the marriage between the parties is irretrievably broken. WHEREFORE the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. August 20, 2001 John p. Broujos, Esquire44o. 06268 Atto ey for Plaintiff B ujos & Gilroy, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 (717) 243-4574 or (717) 766-1690 Fax: (717) 243-8227 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: P- 20-01 ohn D. Mains, Sr. n c:? V a v1 r LS. H JOHN D. MAINS, SR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION -LAW LISA M. MAINS, NO. 2001-4915 CIVIL TERM Defendant IN DIVORCE ORDER AND NOW, this kV"- day of August, 2001, upon Petition for Exclusive Possession of the Marital ?R?esidence, it is ordered that a hearing be held on the day of A /16, 2001 at?3Qo'clockPm. in Courtroom No. S in the Courthouse, Carlisle, Pennsylvania, on the request by Plaintiff for exclusive possession of marital residence during divorce proceedings. By the Court, cc: John H. Broujos, Esquire Lisa M. Mains AI v. `73 , c> ,._.? ?? c_ --- ,,,, T, rya Izl P? ;. '? _. ji ? N C': f, L, r ( _. ' _`-? _? ^) '_ (^ -? JOHN D. MAINS, SR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW LISA M. MAINS, NO. 2001-4915 CIVIL TERM Defendant IN DIVORCE ORDER AND NOW, this day of 2001 it is hereby ordered that John D. Mains, Sr. is awarded exclusive possession of the marital residence at during the pendency of the divorce proceedings, subject to access by Wife at reasonable times upon reasonable notice to obtain personal clothing and property and personal interim possession of household furnishings as agreed by the parties. Wife will surrender all keys to the premises. Either party can petition at any time for a modification of the order. By the Court, cc: John H. Broujos, Esquire Lisa M. Mains JOHN D. MAINS, SR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW LISA M. MAINS, NO. 20014915 CIVIL TERM Defendant IN DIVORCE PETITION FOR EXCLUSIVE POSSESSION OF MARITAL RESIDENCE Petitioner, through his attorney John H. Broujos of Broujos & Gilroy, P.C., in accordance with Section 3502 (c) of the Divorce Code, sets forth the following: Petitioner and Respondent are Husband and Wife, parties in the above divorce action. The parties own a marital residence at 10 Bill Dugan Drive, Etters, Pennsylvania. On July 24, 2000, Wife left the marital home owned in the name of both parties, leaving three children with Father for care and sustenance: John D. Mains, Jr., born September 5, 1989 (age 11), Steven T. Mains, born July 16, 1991 (age 10); Sarah C. Mains, born April 10, 1993 (age 8). During the ensuing 14 months, to the present time, Mother saw the children only once, during Christmas 2000. Father was sole caregiver and support. 5. Petitioner filed Complaint for Custody on Monday, August 20, 2001 at 4:15 pm, copy of which is attached. Sheriff was asked to serve Respondent Mother at her mother's home in Camp Hill, Pennsylvania. 6. On Monday evening, August 20, 2001, Mother with her own mother came to the house. Father and Mother were attempting to arrange supervised visitation, since Father wants the children to have a relationship with the Mother. However, Mother's mother interjected and made the confrontation acrimonious; whereupon Mother then took physical custody of one of the three children, against the wishes of Father, who acquiesced to avoid a struggle. After Mother had left the marital homestead on July 24, 2000, she stayed with her own mother at Camp Hill and at times out of state with a boyfriend at some location. 8. Mother had not entered the marital residence for a year. Mother threatens to take the children out of state. She has been urged to obtain counsel. 10. There is a clear risk that Mother will take the child John D. Mains, Jr. and may attempt to take the other two children out of state. She has indicated she will leave within a week. 11. Mother entered the marital home with police assistance, who rightfully said she had the right to enter because of joint ownership. 12. Father cannot ensure continuous and uninterrupted care of the children if Wife enters the home and disrupts the family, which has occupied the house as a cohesive family since the Mother's departure on July 24, 2000. She has disregarded the children, Father paying all costs of support and maintenance. 13. Father requests an order awarding him exclusive possession of the marital residence during the pendency of the divorce proceedings, subject to reasonable access by Wife at reasonable times upon reasonable notice TBH. dAu gust 21, 2001 ujos, , Es uire 46268 BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717/243-4574; 717/766-1690 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. Date: n D. Mains, sr. c 17 -711 JOHN D. MAINS, SR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION -LAW LISA M. MAINS, NO. 2001-4915 CIVIL TERM Defendant IN DIVORCE ORDER 4% AND NOW, this ? day of 2001 it is hereby ordered that John D. Mains, #10 to frill Ou'N+ )Alvf'o F H Sr. is awarded exclusive possession of the marital residence at during the pendency of the divorce proceedings, subject to access by Wife at reasonable times upon reasonable notice to obtain personal clothing and property and personal interim possession of household furnishings as agreed by the parties. Wife will surrender all keys to the premises. Either party can petition at any time for a modification of the order. By the cc: John H. Broujos, Esquire 8 a o i Lisa M. Mains° CIL _? ? fV M l7 L" J U.1 G 1 1 I The Court of Common Pleas of Cumberland County, Pennsylvania JOHN D SR VS LISA M Fife No. 2001-049 1 5 STATEMENT OF INTENTION TO PROCEED :ours: (? / t C / A C - ' `-6A M ?l.??Cr? 6 1 [ 7LVS intends to proceed with the above captioned matter. Attorney for 1 vl Y `. Curtis R. Long Prothonotary (Office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ni - g9IS CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 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, CURTIS R. LONG PROTHONOTARY One Courthouse Square - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573