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Home My WebLink About05-6530MELANIE B, MATSON Plaintiff V. MICHAEL L. MATSON Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No. OS - C , -' \ 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 Office of the Prothonotary at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013.3387. 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 32 S. Bedford Street Carlisle, PA 17013.3302 (717) 249.3166 MELANIE B. MATSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action - Law No. 09"-LE,36) MICHAEL L. MATSON Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO § 3301 (C) OR §3301(D) OF THE DIVORCE CODE AND NOW COMES, Melanie B. Matson, Plaintiff, who brings this action in divorce against Michael L. Matson, Defendant, upon a cause of action whereof the following is a statement: 1. Plaintiff, Melanie B. Matson, is an adult individual residing at 302 Valley Street, POB 67, Summerdale, Cumberland County, Pennsylvania 17093. 2. Defendant, Michael L. Matson, is an adult individual residing at 302 Valley Street, POB 67, Summerdale, Cumberland County, Pennsylvania 17093. 3. Plaintiff and Defendant are citizens of the Commonwealth of Pennsylvania, having resided here for a period of more than six months immediately preceding the filing of this Complaint. 4. The parties were married on 29 June 2001 in Harrisburg, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies. 6. There has been no prior action for divorce or annulment of this marriage instituted by either party in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling; the parties have attempted marriage counseling without avail. Nevertheless, Plaintiff has signed an affidavit attached hereto averring that she does not request such counseling. 8. The marriage of the parties is irretrievably broken. 9. There is one (1) minor child to this marriage. 10. 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 will also file such affidavit. WHEREFORE, Plaintiff prays this Honorable Court to: a. Enter a Decree of Divorce under § 201(c) of the Divorce Code; and b. Grant such other relief as the Court deems just and reasonable. Respectfully submitted, LAW DJ`/VICES OF LESLw D. JACOBSON P DATED: / 4 /'_r ( t eslie D. Jacobson ttomey for Plaintiff o. 52673 8150 Derry Street Harrisburg, PA 17111.5260 717.909.5858 717.909.7788 [fax] 2 MELANIE B. MATSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action - Law No. MICHAEL L. MATSON Defendant : IN DIVORCE VERIFICATION I, MELANIE B. MATSON, do hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge and belief. I understand that false statements contained herein are subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unsworn falsification to authorities. MELANIE B. MATSON t'1 (oz:) MELANIE B. MATSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action - Law No. MICHAEL L. MATSON Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce and certify that I am authorized to do so. Dated: Z `Z- p pl?jj 7 MICHAEL L. MATSON r a ' „ ?. r; MELANIE B. MATSON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action - Law No. 0,S-. 6 J3 o Ck v; \?r v, MICHAEL L. MATSON Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 3301 (C) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed the A-9-4- day of V e-CGwAe.r 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce without notice. 4. 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. 5. I understand that I will not be divorced until a Decree in Divorce 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. § 4904 relating to unsworn falsification to authorities. Dated: y MELANIE B. MATSON 4- ? rill CO on Leslie D. Jacobson The Law Offices of Leslie D. Jacobson Attorneys for the Plaintiff 8150 Derry Street, Ste. A Harrisburg, PA 17111 - 5260 717.909.5858 717.909.7788 (fax) MELANIE B. MATSON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL L. MATSON Defendant No. 05-6530 Civil Term CIVIL ACTION - 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant Accepted Service of the Complaint in Divorce on December 22, 2005. 3. Complete paragraph (a): (a)(1) Date of execution of Plaintiffs Affidavit of Consent required by § 3301(c) of the Divorce Code: February 13, 2008. (a)(2) Date of execution of Defendant's Affidavit of Consent required by § 3301(c) of the Divorce Code: February 13, 2008. 4. Related claims pending: None. 5. Complete (a) and (b): (a) Date Plaintiff s Waiver of Notice was filed with the Prothonotary: March 18, 2008. (b) Date Defendant's Waiver of Notice was filed with the Prothonotary: March 18, 2008. Respectfully submitted, THE LAW OFFICEPOF LESLIE DAVID JACOBSON Dated: March 18, 2008 L sli D. Jacobson # 2673 8 Derry y Street Harrisburg, PA 17111 717.909.5858 717.909.7788 Fax Attorney for Plaintiff :..) C- Q IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. No. OS-6530 ci yi 1 TPrm VERSUS DECREE IN DIVORCE AND NOW, , `\'I. `,?- \-\\ 'L ? , u)(A' IT IS ORDERED AND DECREED THAT MPlaniP R Matcnn , PLAINTIFF, AND Michael T. Matcnn 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; BY THE COURT- ATT EST: J. PROTHONOTARY W--27? AO-,.5-e- E ,$o-5?f - F