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HomeMy WebLinkAbout01-5224IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF CIVIL ACTION-LAW -vs- MICHAEL L. MCBRIDE, DEFENDANT NO. O~ IN DIVORCE a v.m. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Michael L. McBride, Defendant 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 Court House, One Courthouse Square, 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. Pennsylvania Bar Association-Lawyer Referral Service Telephone 1-800-692-7375 (PA only) or 717-238-6715 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Prothonotary's Office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend any scheduled conference or hearing. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF : -VS - : MICHAEL L. MCBRIDE, DEFENDANT : CIVIL ACTION-LAW IN DIVORCE a v.m. COMPLAINT UNDER SECTION 3301(C) or (D) OF THE DIVORCE CODE NOW comes the plaintiff and for cause of action against the Defendant says: 1. Megan R. McBride is the Plaintiff, who currently resides at 18 Valley Street, Carlisle, Cumberland County, Pennsylvania, since approximately 1998. 2. Michael L. McBride is the Defendant, who currently resides at Barricl<'s Camp Ground, Center Road, Newville, Cumberland County, Pennsylvania who has a mailing address of 27 South Spring Garden Street, Carlisle, Pennsylvania since approximately May 2000. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 17, 1997, in Carlisle, Pennsylvania, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, REICHARD LAW OFFICES, LLC. Carrie M. Bowmaster, Esquire Attorney I.D. No. 70226 ReJchard Law Offices, LLC 70 West King St. Chambersburg, PA 17201 (717) 267-2288 I verify tl~at tl~e statements macte in tl~e attacl~ect Divorce Complaint are true ancl correct. I unc~erstancJ tt~at false statements macle Inerein are mac~e subject to tl~e penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to autl~orities. Datei.~,~ .~ ,2001 Mega,/q McBride~Plaintiff 202~5 F.~Main Street Post Office Box 8 Waynesboro, PA 17268 717-762-1131 717-267-3006 FAX 717-762-8800 REICHARD LAW OFFICES, LLC. The Fort Chambers Bldg. 70'~Z~ng Street Suite B Chambersburg, PA 17201 717-267-2288 FAX 717-267-1151 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF MICHAEL L. MCBRIDE, DEFENDANT CIVIL ACTION-LAW NO. 01 - 5224 Civil Term IN DIVORCE a v.m. Affidavit of Service I, Carrie M. Bowmaster, hereby certify that I served Michael L. McBride, by handing him a tree and attested copy of the Divorce Complaint on the 84 day of September, 2001 at 11:00 o'clock a.m. while he was at Barrick's Camp Ground, Center Road, Newville, Pennsylvania. I verify that the statements made in this document are tree 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. Section 4904, relating to unswom falsification to authorities. Date: Carrie M. Bowmaster Attorney I.D. No. 70226 Reichard Law Offices, LLC. 70 West King Street Chambersburg, PA 17201 (717) 267-2288 Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA) (ss COUNTY OF FRANKLIN) Onthis //7//~ dayof ~r~tC~ } , A.D., 2001, before me, the undersigned officer, personally appeared ((~lln ~t ~'T)./4..~, ~.a x~.fC.~ ). known to me (or satisfactmy proven) to be the \ person whose name sub'scribed to thee within document, and acknowledged that they execute the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. lic / ~ My commission expires ~ ~ ~THYA. B~ NolapJ Pub~% ~ ~i Chambersburg Berm Frmfldin,~Cou~n?~, i BEACON-MORRIS, DIVISION OF MASTEK, INC., Plaintiff NOVCO SUPPLY, INC., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5204 CIVIL CIVIL DIVISION - LAW ANSWER AND NOW, comes Novco Supply, Inc., named Defendant herein, by and through its attorneys, Cunningham & Chernicoff, P.C., and files its Answer to the Complaint filed by Beacon-Morris, Division of Mastek, Inc., and in support thereof answers as follows: 1. Admitted. 2. Admitted. 3. The averments contained within paragraph 3 represent conclusions of law to which no response is required and the averments are therefore denied. If and to the extent it is later judicially determined that an answer is so required, Defendant specifically denies that Exhibit "A" to Plaintiff's Complaint represents an "insistence" or "request" by the Defendant to the Plaintiffto sell and deliver goods, wares, and memhandise on the dates, in the amounts, and for the prices set forth in Exhibit "A" to Plaintiffs Complaint. Defendant specifically denies that it agreed to pay the sum of $8,530.19 to Plaintiff and strict proof thereof is demanded, if relevant, at time of trial. As further answer, Defendant specifically denies that the invoices attached as Exhibit "A" to Plaintiffs Complaint represent Defendant's request or acceptance of goods or supplies as alleged in paragraph 3 of Plaintiff s Complaint because such invoices are not signed or acknowledged by Defendant, or any agent of Defendant. A strict accounting of all past payments made by Defendant to Plaintiff, including the dates and amounts of such payment, as well as how such payments were applied, is demanded, if relevant, at time of trial. 4. The averment contained within paragraph 4 represents a conclusion of law to which no response is required and the averment is therefore denied. As further answer, Defendant incorporates its answer to paragraph 3 of Plaintiffs Complaint herein as if more fully set forth. 5. The averment contained within paragraph 4 represents a conclusion of law to which no response is required and the averment is therefore denied. As further answer, Defendant specifically denies owing Plaintiffthe sum of $8,530.19 as set forth in paragraph 5 and Exhibit "B" to Plaintiffs Complaint for the reasons more fully set forth in Defendant's answer to paragraph 3 of Plaintiffs Complaint herein incorporated by reference as if more fully set forth. 6. Denied as stated. Defendant specifically denies owing the sums alleged to be due and owing in Plaintiff's Complaint for the reasons more fully set forth in paragraph 3 of Defendant's Answer herein incorporated by reference as if more fully set forth. WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order dismissing Plaintiff's Complaint and further awarding Defendant all such other relief as is proper and just. Respectfully submitted, CUNNINGHAM & CHERNICOFF, P.C. Date:_ I0-?- 0 / ~e Eck, Esquire Pa. Attorney Id. #83087 2320 North Second Street P. O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 (Attorneys for Defendant) 3 1, Kcvin D. Novingcr, Trcasurer of Novco Supply, Inc., verify that the statements made in the foregoing Answe~ are true and corrcct to the bes, of my knowledge, information and belief. I understand that falsc statements herein arc made subject to thc penalties of 18 Pa. C.$.A. Section 4904, relating to unswom falsffication to au,horitics. cvin'D. Novinger Treasurer .CERTIFICATE OF SERVICE I, Beth A. Kunlde, a legal secretary for the law firm of Cunningharn & Chemicoff, P.C., hereby certify that on this date, a true and correct copy &the foregoing ANSWER was served by first-class mail, postage prepaid, to the person named below: Robert D. Kodak, Esquire 407 North Front Street P.O. Box 11848 Harrisburg, PA 17108-1848 Date: Io-7'- 1 Beth A. Kunkle 4 o 2025 E. Main Street Post Office Box 8 Waynesboro, PA 17268 717-762-1131 --------~AX 717-762-8800 REICHARD LAW OFHCES, LLC. The Fort Chambers Bldg. 70 W. King Street, Suite B Chambersbutg, PA 17201 717-267-2288 FAX 717-267-1151 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF : MICHAEL L. MCBRIDE, DEFENDANT : CML ACTION-LAW NO. ox-sag4 CIVIL TERM IN DIVORCE a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 33o1(C) was filed on September 5, 2ooz. 2. The marriage of the Plaintiffand Defendant is irretrievablybroken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce as I have waived notice of intention to request entry of a divorce decree under Section 33o1(C) of the Divorce Code. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 Pa. C.S. f49o4 relating to unsworn falsification to authorities. Date: ~ ~ ,2OO1 ~~~ MeganIR. McBride, Plaintiff 2025 E. Main Street Post Office Box 8 Waynesboro, PA 17268 -- 717-762-1131 FAX 717-76243800 REICHARD LAW OFHCES, LLC. The Fort Chambers Bldg. 70 W. King Street, Suite B Chambersburg, PA 17201 717-267-2288 -- FAX 717-267-1151 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MACBRIDE, PLAINTIFF MICHAEL L. MACBRIDE, DEFENDANT CIVIL ACTION-LAW NO. 01-5224 CIVIL TERM IN DIVORCE a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SEC. 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I 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. Sec. 4904 relating to unsworn falsification to authorities. Date:~P..). [~ 2001 ~ d~ &~k.~ Megan ]~. MacBride, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF CML ACTION-LAW -V$- : MICHAEL L. MCBRIDE, DEFENDANT : NO. 01-5224 CML TERM IN DIVORCE a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 33o1(C) was filed on September 5, 2om. 2. The marriage of the Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce as I have waived notice of intention to request entry of a divorce decree under Section 33o1(C) of the Divorce Code. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties o;f ~8 Pa. C.S. f49o4 relating to unsworn falsification to authorities. Date: ~-, ~ Michael L. McBride, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF : MICHAEL L. MCBRIDE, DEFENDANT : CIVIL ACTION-LAW NO. 01-5224 CIVIL TERM IN DIVORCE a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SEC. 3301 C OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. ! understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P~C.S. Sec. 4904 reloting to unsworn falsification to authorities. ~~ Date: ~/ 7 2002 Michael L. McBride, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MEGAN R. MCBRIDE, PLAINTIFF -V$- MICHAEL L. MCBRIDE, DEFENDANT CIVIL ACTION-LAW NO. 01-5224-CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. Grounds fordivorce: Irretrievable Breakdown under Section 3301 (c) ofthe Divorce 2. Date and manner of service of the Complaint: September 5, 2001, Affidavit of service dated September 8, 2001 and filed on September 13, 2001. (copy attached hereto). 3. (a) Date of execution of the Affidavit of Consent and Waiver required by Section 3301 (c) of the Divome Code: by the Plaintiff.' December 12, 2001 and filed on December 26, 2001; by the Defendant: January 7, 2002 and filed on January jj~, 2002. 4. Related claims pending: No claims are pending. Carrie M. Bowmaster, Esquire Reichard Law Offices, LLC Attorney for Plaintiff INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. MEGAN R. MCBRIDE PLAINTIFF VERSUS MICHAEL L. MCBRIDE NO. 01-5224 civil DECREE IN DIVORCE AND NOW, DECREED THAT Meqan R. Mcbride AND Michael L. Mcbride ARE DIVORCED FROM THE BONDS Of MATRIMONY. 2002 __, IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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; BY THE COURT: / / PROTHONOTARY ZN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANZA MEGAN R. MCBRt'DE, PLAZNTt'FF : -V$- : MI'CHAEL L. MCBRTDE~ DEFENDANT : CTVTL ACTTON-LAW NO. 0].-5224-CZVTL TERM I'N DZVORCE NOTTCE OF ELECTTON TO RETAKE MATDEN NAME Notice is hereby given that the Plaintiff in the above-captioned matter, having been granted a Final Decree in Divorce from the bonds of matrimony on the 30th day of January, 2002, by the Court of Common Pleas of Cumberland County, Pennsylvania, a copy of which is attached hereto, made part hereof, and marked Exhibit"A', hereby elects to retake and hereafter use her maiden name of Megan R. Lebo. Mega~ R. McBride, Petitioner To be known as: Megan~R. Lebo Commonwealth of Pennsylvania County of ~[~,~-t/.-,~f :SS On this ~ day of ~-~ , 2002, before me, a Notary Public, personally appeared Megan R. Lebo, formerly known as Megan R. McBride, known to me, or satisfactorily proven to be, the person whose name is subscribed to the within instrument and acknowledged that she executed the foregoing for the purpose herein contained. I~N WITNESS WHEREOF, T have hereunto set my hand and official seal. Notary Public Notarial Seal Scott A. Rickenbach, Notary Public North Middleton Tw~., Ct~mberland Counly My Commission Expires Apr. 7, 2003 Member, pennsy~vsni~ Associatio~ ol Notaries