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HomeMy WebLinkAbout01-5248DOUGLAS A. MELIUS, Plaintiff FALAFHIA E. MELIUS, Defendant IN THE COURT OF COMMON PLEAS OF ._ : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2001- 5~6t '4?CIVIL TERM .. IN DIVORCE NOTICE 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 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 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 our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. DOUGLAS A. MELIUS, Plaintiff FALAFHIA E. MELIUS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2001- K.~'/~CIViL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THI~ D_IVORCE CODE NOW comes the plaimiff, Douglas A. Melius, by his attorney, Mark D. Schwartz, Esquire, and files this complaint in divome against the defendant, Falafhia E. Melius, representing as follows: 1. The plaintiff is Douglas A. Melius, an adult individual residing at 227 Station Road, Twin Rocks, Cambria County, Pennsylvania 14960. 2. The defendant is Falaflfia E. Melius, an adult individual whose last known address is c/o Alberta R. Whitmer, 10805 Carlisle Pike, Gardners, Cumberland County, Pennsylvania 17324. 3. The defendant has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on September 27, 1996 in Newville, Pennsylvania, and separated on August 15, 2001. 5. There have been no prior actions of divorce or for annulment between the parties. 6. There were two (2) children bom to this marriage; namely Brianna H. Melius, bom October 28, 1996, age four (4) years, and Douglas D. Melius, bom May 30, 1998, age three (3) years. 7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHI~;REFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Date: September 5, 2001 By: Respecfft ~y submitted, ~[cK~ & HUGHI~S Mark D. Schwartz, Esquire Attorney for Plaintiff West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I.D. No. 70216 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Complaint and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: August 21, 2001 DOUGLAS A. MELIUS, Plaintiff, FALASHIA E. MELIUS, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 2001-5248 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on lqovember 29, 2001. 2. The marriage of plaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a fmal decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is gran~Ied. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: /g? - c~ 3 ,2003 DOUGLAS ~A. MELIUS