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Home My WebLink About05-5217MARK D. JONES, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, PENNSYLVANIA VS. PATRICIA L. JONES, Defendant CIVIL ACTION - LAW b S- 5217 ?t v? C ??J2-? 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 foregoing 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 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 Telephone: (717) 249-3166 MARK D. JONES, VS. Plaintiff PATRICIA L. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. OS'- 9917 IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: Cli 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 (d) 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. MARK D. JONES, ) IN THE COURT OF COMMON PLEAS Plaintiff ) OF CUMBERLAND COUNTY, 1 PENNSYLVANIA VS. PATRICIA L. JONES, Defendant CIVIL ACTION - LAW NO. 0,S-- S-.),17 1.1 v t L IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, MARK D. JONES, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is MARK D. JONES, an adult individual who currently resides at 20 Conway Drive in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is PATRICIA L. JONES, an adult individual who currently resides at 34 Pine Hill Avenue in Mechaniccburg, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents 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 10 June 1995 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. Sa l L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date:- MARK D. JONE -TI '-. N ? y CP --? G„ 1 {l j MARK D. JONES, PLAINTIFF vs. PATRICIA L. JONES, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-5217 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, PATRICIA L. JONES, hereby accept service of the original Complaint in Divorce and acknowledge receipt of a copy of the Complaint. Date: /6 (jet aod c f"? PATRICIA L. JONES 34 Pine Hill Avenue Mechanicsburg, PA 17050 . ; ? __i MARK D. JONES, PLAINTIFF vs. PATRICIA L. JONES, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-5217 CIVIL TERM IN DIVORCE If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on or about 15 August 2004 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: 8?a l /o (O AAk MARK D. JONE91 a p d .-n ? .-a °s'.- -e t,.' ?' x1 T'n ?^- G n ` i , , O ? ???Tt ._ 4Y1 ? ? ::? .: ??.; .y ?:i N -t .! W MARK D. JONES, PLAINTIFF vs. PATRICIA L. JONES, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-5217 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on or about 15 August 2004 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 Pa. C.S. 4904 relating to unswom falsification to authorities. Date: 31Q110(,0 7n MARK D. JONE9 II i .1UE (;UPY FROM HEGORO n Testimony wnereof. ! here uFM 90 MY 11W ,)d the Ski of sal, Court ;0 C8(W AL nis??? ,at Drnt'hnnn? MARK D. JONES, Plaintiff VS. PATRICIA L. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005-5217 CIVIL TERM IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(Dl OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because (check (i), (ii) or both): _ (i) The parties to this action have not lived separate and apart for a period of at least 2 years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. ?/ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: o?Z d PAT CIA L. JONES NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. t.'? ?: ?r t; ? C-? _ _ ?::: ''i^? - _ ? ,; ? (? %?... _ ?- G N MARK D. JONES, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff, : NO: 2005-5217 CIVIL TERM PATRICIA L. JONES, : IN DIVORCE Defendant. PETITION TO ADD COUNTS IN RESPONSE TO A COMPLAINT IN DIVORCE AND NOW, comes the Defendant, Patricia L. Jones, by and through her attorneys, Mancke, Wagner & Spreha, and files the following Petition for consideration under the Divorce Code: COUNTI ALIMONY PENDENTE LITE COUNSEL FEES, COSTS AND EXPENSES 1. By reason of this action, Defendant will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 2. The Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 3. The Defendant's income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the cost of this litigation. 4. The Plaintiff has adequate earnings to provide support for the Defendant and to pay her counsel fees and expenses. COUNT U ALIMONY 5. Paragraphs 1 through 4 above are incorporated herein by reference and made a part hereof. 6. Defendant lacks sufficient property to provide for her reasonable needs. 7. Defendant is unable to sufficiently support herself through appropriate employment. 8. Plaintiff has sufficient income and assets to provide continuing support for the Defendant. WHEREFORE, Defendant prays this Honorable Court: (a) Enter a Decree in Divorce; (b) Compel the Defendant to pay alimony pendente lite to the Plaintiff; (c) Compel the Defendant to pay alimony to the Plaintiff; (d) Equitably distribute all property, both real and personal, owned by the parties; -2- (e) Compel the Defendant to pay the Plaintiff's counsel fees, costs and expenses and the costs and expenses of this action; and (f) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, Mancke, Wagner & Spreha Y agner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Defendant Date: M /3L?la -3- VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: OQY /? , xc)(2 CERTIFICATE OF SERVICE I, Debra K. Spinner, secretary in the law firm of Mancke, Wagner & Spreha, do hereby certify that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: Samuel L. Andes, Esquire 525 N. 12'hStreet Lemoyne, PA 17043 By_ Debra K. Spinner, Se retary Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Defendant Date: jo /i3/O? O CAJ ^Q "IV R R? - ra C Q cs, ' ,? . 'mot J7j. ?'! Cis .: • r. `ET ?'T7 J zx :ij T 2 G,7't -rt Commonwealth of Pennsylvania County of Cumberland, ss: MARIE D. JONES, Plaintiff vs. PATRICIA L. JONES, Defendant CIVIL ACTION - LAW NO. 2005-5217 CIVIL TERM IN DIVORCE Motion for Appointment of Master claims: MARK D. JONES, Plaintiff moves the court to appoint a Master with respect to the following (xxx) Divorce (xxx) Distribution of Property ( ) Annulment ( ) Support (xxx) Alimony (xxx) Counsel Fees (xxx) Alimony Pendente Lite (xxx) Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. P. Richard Wagner, Esquire, represents the Defendant. 3. The statutory ground(s) for divorce are: 3301 (d) of the Divorce Code 4. Check the applicable paragraph(s). ( ) The action is not contested. ( ) An agreement has been reached with respect to the following claims: (xxx) The action is contested with respect to the following claims: distribution of property, alimony, alimony pendente lite, counsel fees, costs and expenses. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1day. 7. Additional information, if any, relevant to the motion: _0 C? c X7-6 Date el L. A des Attorney for Plaintiff AND NOW, 2006, Master with respect to the following claims: divorce. Esquire, is appointed BY THE COURT, J. -n ? f Commonwealth of Pennsylvania County of Cumberland, ss: MARK D. JONES, Plaintiff vs. PATRICIA L. JONES, Defendant MARK D. JONES, Plaintiff moves the court to appoint a Master with respect to the following Motion for Appointment of Master claims: (xxx) Divorce ( ) Annulment (xxx) Alimony (xxx) Alimony Pendente Lite and in support of the motion states: OCT a 12oos„1 CIVIL ACTION - LAW NO. 2005-5217 CIVIL TERM IN DIVORCE (xxx) Distribution of Property ( ) Support (xxx) Counsel Fees (xxx) Costs and Expenses 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. P. Richard Wagner, Esquire, represents the Defendant. 3. The statutory ground(s) for divorce are: 3301 (d) of the Divorce Code 4. Check the applicable paragraph(s). ( ) The action is not contested. ( ) An agreement has been reached with respect to the following claims: (xxx) The action is contested with respect to the following claims: distribution of property, alimony, alimony pendente lite, counsel fees, costs and expenses. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1day. 7. Additional information, if any, relevant to the motion: 30 0 Date el L. A des 1 Attorney for Plaint AND NOW, /Ld?l/hc.il. l 2006, ?G a Esquire, is appointed Master with respect to the following claims: divorce. B HE COU , Gv' J. `? C7 } CL. V Curtis R. Long Prothonotary Office of the Protbonotarp CUTt tenant Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Qs - T;Z I 'I CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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 MARK D. JONES, Plaintiff VS. PATRICIA L. JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 - 5217 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this 44 day of A/Z?? , 2010, an order having been entered terminating the above-captioned proceedings for lack of activity, the case having been terminated in accordance with PA.R.C.P 230.2, the appointment of the Master is vacated. BY THE COURT, cc: ? Samuel L. Andes Attorney for Plaintiff ?. Richard Wagner Attorney for Defendant ?? 1 £.S rYt?atll.?rk. P N 7 1 - rn co !l ? 00 r 1.y