HomeMy WebLinkAbout04-6349SARAH M. MAZAN,
PLAINTIFF
V.
MICHAEL MAZAN,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, ,? /PENNSYLVANIA
NO.
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 ground for is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Court Administrator's
Office, Fourth floor, Cumberland County Courthouse, Hanover and
High Streets, 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.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
NOTICE QF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a
divorce proceeding filed in the Court of Common Pleas of Cumberland
County. This notice is to advise you that in accordance with
Section 3302(c) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to
a divorce being handed down by the court. A list of professional
marriage counselors is available at the Domestic Relations Office,
13 North Hanover Street, Carlisle, Pennsylvania. You are advised
that this list is kept as a convenience to you and you are not
bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by
you and your spouse.
If you desire to pursue counseling, you must make your request
for counseling within twenty days of the date on which you receive
this notice. Failure to do so will constitute a waiver of your
right to request counseling.
SARAH M. MAZAN,
PLAINTIFF
V.
MICHAEL MAZAN,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ct
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Sarah M. Mazan who resides at 339
Stonehedge Lane, Mechanicsburg, Cumberland County, Pennsylvania
17055.
2. The Defendant is Michael Mazan who currently resides at
Vigado u. 16. 1.3, 2400 Dunaujvaros, Hungary, Europe.
3. The Plaintiff has been a bonafide resident of the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 8, 2003
in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties in this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
8. The Plaintiff has been advised of the availability of
counseling and that Plaintiff may have the right to request that
the Court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
Thomas D. Gould
Attorney for Plaintiff
I.D. # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
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. 4904, relating to unsworn
falsification to authorities.
Date: Iate?-Ib-0 f ' kYn.
Sarah M. Mazan
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THOMAS, THOMAS & HAFER, LLP
By: Evan Black, Esq.
L D. No. 17884
Stephanie Hersperger, Esq.
I.D. No. 78735
Thomas, Thomas & Hafer, LLP
305 North Front Street
A O. Box 999
Harrisburg, PA 17108
(717) 237-7100
Attorneys for Defendants
KAY BEAMER, In her own right and
as Executrix of the Estate of
DONALD G. BEAMER, Deceased,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA.
Plaintiff
VS.
DAVID CHANG, M.D. and
MOFFITT HEART & VASCULAR GROUP
and
ASSOCIATED CARDIOLOGISTS
and
No. 04-6369
HOLY SPIRIT HOSPITAL A/K/A HOLY SPIRIT
HOSPITAL OF THE SISTERS OF CHRISTIAN
CHARITY,
Defendants JURY TRIAL DEMANDED
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of the Defendants, David Chang and Moffitt Heart
& Vascular Group only, in the above-captioned matter.
THOMAS, THOMAS & HAFER, LLP
Evan Black, Esq.
Attorney for Defendants David Chang, M.D. and
Moffitt Heart & Vascular Group
/'P? Date: ? ? ? ?
CERTIFICATE OF SERVICE
I, Joan Wolfe, an employee of the law firm Thomas, Thomas & Hafer, LLP, hereby state
that a true and correct copy of the foregoing document(s) was served upon all counsel of record
by first class United States mail, postage prepaid, addressed as follows, on the date set forth
below:
Carol Nelson Shepherd, Esquire
Eileen Riley Sutton
Feldman, Shepherd, Wohlgelernter & Tanner
1845 Walnut Street
25th Floor
Philadelphia, PA 19103
Date: P- e;? o
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Curtis R. Long
Prothonotary
office of the i3rotbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
n q - 131/2 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