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Home My WebLink About05-5233 Cara A. Boyanowski, Esquire Supreme Court 1.0. No. 68736 2080 LingIestown Road Suite 20 I Harrisburg, PAl 7110 (717) 540-9170 NATHAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO.OS' - ..5'..233 CIVIL TERM AMY L. MORNEAU, 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 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 ofthe Prothonotary, Front and Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 , NOTICIA Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. U sted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion do demanda. U sted puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted. LLEVE EST A DEMANDA A UN ABODAGO INMEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, V A Y A EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRIT A ABAJO PARA A VERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 Cara A. Boyanowski, Esquire Supreme Court LD. No. 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (717) 540-9] 70 NATHAN V. MORNEAU, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. os- S.213 CIVIL TERM AMY L. MORNEAU, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Nathan V. Morneau, by his attorney, Cara A. Boyanowski, Esquire, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Nathan V. Morneau, is an adult individual who resides at 1273 Timberview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, Amy L. Morneau, is an adult individual who resides at 520 E. Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 21, 2001, in Mechanicsburg, Cumberland County, Pennsylvania. 5. The Defendant is a citizen of the United States of America. The Plaintiff is a Resident Alien from Canada. 6. There have been no prior actions in divorce between the parties. 7. Plaintiff avers that there are no children born of this marriage. 8. The Plaintiff and the Defendant are not members of the Armed Services ofthe United States or any of its allies. 9. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. He has declined counseling. 10. The causes of action and sections of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. 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 may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on September 15, 2005. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. 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.A. 94904 relating to unsworn falsification to authorities. /1!Ji:--1I ~ By: Nathan V. Morneau, Plaintiff Date: tt') ~ 3 ~O~ By:O~MPJJ11lowsfu Cara A. Boyanowski, Esquire Attorney No. 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff 0 r-' SA C-~ c: c::~"} ~ G-J"\ -4 (J : c:> ~ -r - (""'J .,_ -n ~ ..0 _1 r1~C ~~ Q 1 ~~ j 1'_- (.Ji ~~) , ~ V\ -0 _,"1 - ' ' (\ \) ~ :;l'n ...0 lrt <....:> r-..l ~ 'tJ ~ :;:- ~S -l (..f! .-<, -t::. - !2 r NATHAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, : No. 05-5233 AMY L. MORNEAU, Defendant CIVIL ACTION - LAW : DIVORCE PETITION FOR RFLATEO CLAIMS PIJRSTJANT TO PA.R.CP. 1920.1'i{h) AND NOW, comes the Defendant, Amy L. Morneau and respectfully represents as follows in support of this Petition: 1. The Petitioner is the Defendant above-named, 2. The Respondent is the Plaintiff above-named. 3. The Respondent filed a Complaint for Divorce to the above caption and number on or about October 5, 2005. COTJNT I - A I .TMONV PENOFNTF, I.TTF 4. The prior paragraphs of this Petition are incorporated herein by reference thereto. 5. The Petitioner is the dependent spouse and lacks sufficient property and income to adequately defend herself in the divorce action filed against her, 6. Petitioner may be in need of hiring an attorney, an accountant, or other expert and does not have the funds necessary to pay said fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final resolution of divorce and equitable distribution, BY: DATE: i.fltq/O& I I RESPECTFULLY SUBMITTED: b" cfY/,o1lJ1litu Amy . Morneau, pro se- 520 E. Winding Hill Road Mechanicsburg, P A 17055 Telephone: (717) 766-6834 NATHAN V. MORNEAU, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 05-5233 AMY 1. MORNEAU, Defendant : CIVIL ACTION - LAW : DIVORCE VF,RTFTCATTON I, Amy 1. Morneau, Defendant in the above referenced divorce action, hereby verifY that the statements made in the foregoing Petition for Related Claims are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: L/lvt! D[, , ' Signature: a.-':j.l ~jVN!/U{ Amy 1. orneau NATHAN V. MORNEAU, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 05-5233 AMY L. MORNEAU, Defendant CIVIL ACTION - LAW DIVORCE CEFTTFTrATF OF SFRVTrF I, Amy L. Morneau, hereby certifY that I am this day serving a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure by depositing a copy of the same with the United States Post Office in Pennsylvania, through first class mail, prepaid, and addressed as follows: Cara Boyanowski, Esquire 2080 Linglestown Road Harrisburg, PA 17110-9670 BY: "'" DATE: l.f/1110~ Amy U Morneau, pro se 520 E. Winding Hill Road Mechanicsburg,PA 17055 Telephone: (717) 766-6834 ~~ ""-r' t" ~ C) ._~ \ ?'~ : - \...~~j (,"1 ~'I "'~;J :< ~ V. :'s '). NATHAN V. MORNEAU, Plaintiff/Respondent THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE AMY L. MO~l\TEAU, Defendant/Petitioner NO. 05-5233 CIVIL TERM IN DIVORCE PACSES CASE NO: 373108210 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 20th day of April, 2006. upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before RJ, Shaddavon Wednesdav. Avril 26,2006 at 9:00 A.M. for a conference, at 13 N, Hanover St" Carlisle, PA 17013. after which the conference omcer may recommend that an Order for Alimony Pendente Lite be entered. YOU arc further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return. including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order. completed as required by Rule 1910,ll<1J (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B, Bayley, President Judge Copies mailed on April 20. 2006 to: Petitioner Respondent Cara Bayanowski, Esquire Date of Order: April 20, 2006 ~ 1__;1lJ(1~ R, ~adday, Conference OHicer (/ '",J." YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOG. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND Ol'T WHERE YOU VIA Y GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2L1BERTY AVE. CARLISLE. PENNSYLVANIA 17013 (717) 249-3166 co361 ::1 .;) (".' In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION AMY L. MORNEAU ) Docket Number 05~5233 CIVIL Plaintiff ) Ys. ) PACSES Case Number 373108210 NATHAN V. MORNEAU ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 26TH DAY OF APRIL, 2006 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or @ Other PETITION FOR APL filed on APRIL 19, 2006 in the above captioned matter is dismissed without prejudice due to: A SPOUSAL SUPPORT ORDER BEING ISSUED UNDER DOCKET NOS. 273 S 2006 AND PACSES #232108162. o , The Complaint or Petition may be reinstated upon written application of the plaintiff pettttoner. BY THE COURT: JUDGE DRO: R.J. Shadday Service Type M Form OE-506 Worker ID 21005 c.,." Cara A, Boyanowski, Esquire Supreme Court I,D, No, 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (717) 540-9170 Attorney for Plaintiff NATHAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 05-5233 CIVIL TERM AMY L. MORNEAU, Defendant IN DIVORCE AFFIDA VIT OF CONSENT l. A Complaint in Divorce under 93301 (c) ofthe Di vorce Code was filed on October 15, 2006, 2, The marriage of Plaintiff and 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 after service of notice of intention to request entry of the decree, 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.A. 94904 relating to unsworn falsification to authorities, Date: June 16, 2006 BY:~ /Nathan V. Morneau, Plaintiff Social Security No. '2-oZ-{)b -'"(bZ I <:~..." '''', Cara A, Boyanowski. Esquire Supreme Court LD, No, 68736 2080 Linglestown Road Suite 20 I Harrisburg, P A 1711 0 (717) 540-9170 Attorney for Plaintiff NA THAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 05-5233 CIVIL TERM AMY L. MORNEAU, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 113301(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 di vorced unti I a di vorce 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 Pa,C,S,A, 114904 relating to unsworn falsification to authorities, Date: June 16, 2006 BY:~ Nathan V. Morneau, Plamtlff --} "" Cara A, Boyanowski, Esquire Supreme Court I.D, No, 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff NA THAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 05-5233 CIVIL TERM AMY L. MORNEAU, Defendant IN DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under 93301(c) of the Divorce Code was filed on October 15, 2005, 2, The marriage of Plaintiff and 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 after service of notice of intention to request entry of the decree, 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.A. 94904 relating to unsworn falsification to authorities, Date: June 16, 2006 By: i~ ~ {'fI~ Amy L o~eau, Defendant Social Security No. tlo~ 6Ie 4aib ) -,1 -::1 ii' t',' , V Cara A. Boyanowski, Esquire Supreme Court LD, No, 68736 2080 Linglestown Road Suite 201 Harrisburg. P A 17110 (717) 540-9170 Attorney for Plaintiff NATHAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW v. NO. 05-5233 CIVIL TERM AMY L. MORNEAU, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S.A, 94904 relating to unsworn falsification to authorities, Date: June 16, 2006 By: ..~-> :..:::J :i Cara A, Boyanowski, Esquire Supreme Court 1.0, No, 68736 2080 Linglestown Road Suite 201 Harrisburg, P A 17110 (717) 540-9170 telephone (717) 540-5481 Attorney for Plaintiff NATHAN V. MORNEAU, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. NO. 05-5233 CIVIL TERM AMY L. MORNEAU, Defendant IN DIVORCE AFFIDAVIT OF SERVICE Cara A, Boyanowski, Esquire, being duly sworn according to law, deposes and says that she is an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on the 12th day of October, 2005, she did serve upon Amy L. Morneau, the Defendant in the foregoing case, a true and correct copy of the Complaint in Divorce by sending same to her, by certified mail, restricted delivery, addressed to 520 E, Winding Hill Road, Mechanicsburg, Pennsylvania, 17055, The receipt for said Complaint is attached hereto as Exhibit" A." Said copy of the Complaint was duly endorsed with notice to Defendant to appear and answer or the matter would proceed without her. · (\'ld~ \./ R, Ql~~~pur1 Attorney No, 68736 2080 Linglestown Road Suite 20 I Harrisburg, P A 17110 (717) 540-9170 Attorney for Plaintiff Sworn to an~.:J0:ribed before me this ddayof < IU....- ,2006, NOTARIAL SEAL LISA A, CONWAY, NOTARY PUBLIC SUSQUEHANNA TWP., DAUPHIN COUNTY MY COMMISSION'r'YPIRES MARCH 24 2007 . Complete items 1, 2, and 3: Also complete Item 4 if Restricted ~Ii~esired. . Print your name and addresS on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: l. o Agent D Addressee Name) C. Date f Delivery 011'." I D /z- D. Is d Ivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No Am'f L. ~OYn<.Qu. 5~ E. W\(\CHr\5 \-1111 Rd ~{.~n\c..'Sburg. flA. l:rosa 3.~lce Type A.."Certified Mail D Express Mail o Registered 0 Return Receipt for Merchandise CJ Insured Mall CI C.O.D. 4, Restricted Delivery? {ExtnlFeeJ Yes 2. Article Number .,.c:. (transfer from SON/co /ab<>O =lee \ - 1 \ 4 O. 0000 -CO\ q - 3()~ PS Form 3811 , February 2004 Domestic Return Receipt 102595-02-M-1540 (') c: <:- ""t1{';] .~.., ,';; :';.1 --< ..,. Cara A. Boyanowski, Esquire Supreme Court I.O, No, 68736 SERRATELLI SCHIFFMAN BROWN & CALHOON 2080 LingIestown Road Suite 201 Harrisburg, PA 17110 Telephone: (717) 540-9170 Facsimile: (717) 540-5481 Attorney for Plaintiff, Nathan V, Morneau IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NATHAN V. MORNEAU, Plaintiff v. NO. 05-5233 CIVIL TERM AMY L. MORNEAU, Defendant 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: 1. Ground for divorce: irretrievable breakdown under 93301(c) of the Divorce Code, 2. Date and manner of service of the complaint: A copy of the Divorce Complaint was served upon Defendant, Amy 1. Morneau, by certified mail, restricted delivery, on October 12,2005, A copy ofthe Affidavit of Service and the Domestic Return Receipt card, signed by Defendant, have been filed of record with this Honorable Court, 3. (Complete either paragraph (a) or (b),) (a). Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by Plaintiff: June 15,2006; by Defendant: June 15,2006. '" (b) (1), Date of execution of the affidavit required by ~330l(d) of the Divorce Code: NI A; (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: N/A. 4, Related claims pending: None, 5. (Complete either (a) or (b),) (a) Date and manner of service of the notice of intention to file praecipe to transmit record; a copy of which is attached: N/A. (b) Date Plaintiffs Waiver of Notice in 9330l(c) Divorce was filed with the Prothonotary: June 21, 2006 (anticipated) Date Defendant's Waiver of Notice in ~330l(c) Divorce was filed with the Prothonotary: June 21, 2006 (anticipated), Respectfully submitted, SERRA TELLI SCHIFFMAN BROWN & CALHOON OWh~CUlowsL Cara A, Boyanowski, Esquire Supreme Court l.D, No, 68736 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 Attorney for Plaintiff " ( . ,( -' ~-,- "'~- - ~ -- - . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS . . OFCUMBERLANDCOUNTY . . . . . . STATE OF PENNA. . NATHAN V. MORNEAU, . . 05-5233 CIVIL TERM No. . PLAINTIFF . . . . . VERSUS . . . AMY L. MORNEAU, . . . . DEFENDANT . . . DECREE IN DIVORCE . . . . . . . . . . . . . . AND NOW, .T..t!, 2.'1 . . 200,", IT IS ORDERED AND . NATHAN V. MORNEAU . DECREED THAT , PLAINTIFF, . . AMY L. MORNEAU . . . . . . AND , DEFENDANT, . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, . . . . . . 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; None. . . . . . , . . ATT T:~ J. . . . ~~JN1 . ,k'. ~ Vi . . ROTHONOTARY . . . . .. .~ _~ ?/()'1mI' ~ ~ ~ li'o :,,,.4r/6>;--rJ "'J<J. E'-L 'J? E L