HomeMy WebLinkAbout06-5451
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Pamela L. Purdy
Attorney 10 No. 85783
100 Pine Street
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
plpurdy@verizon.com
Attorney for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01.. - Si-lS{ (l~ OL( T€IL."'l
PAULA J. MANN,
v.
MARK K. MELUSKEY,
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 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 at the Cumberland
County Courthouse, Carlisle, PA.
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
(717) 249-3166
cti-.
PAMELA L. PURDY
(,.......
ATTORNEY FOR PLAINTIFF
..
Pamela L. Purdy
Attorney ID No. 85783
100 Pine Street
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
plpurdy@verizon.com
Attorney for Plaintiff
PAULAJ. MANN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. OL - SLI S I CIO~ L '-r 'CI2....'l
v.
MARK K. M ELUSKEY,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I
Divorce Under 3301(c) of the Divorce Code
1. Plaintiff is Paula J. Mann who currently resides at 317 N.
Front Street, Harrisburg, Dauphin County, Pennsylvania.
2. Defendant is Mark K. Meluskey who currently resides at 125
E. Springville Road, Boiling Springs, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months previous to the
filing of this Complaint.
. , , ,
4. Plaintiff and Defendant were married on October 14, 1995, at
State College, PA.
5. There have been no prior actions of divorce or for annulment
between the parties.
6. The marriage is irretrievably broken.
7. The grounds on which the action for divorce is based are:
Section 3301 (c): The marriage of the parties is irretrievably broken.
After 90 days have elapsed from the filing of this Complaint, it is believed
the parties will file Affidavits of Consent to a divorce.
8. Plaintiff has been advised of the availability of counseling
and that she may have the right to request that the Court require the
parties to participate in counseling. Plaintiff hereby waives her right to
such counseling.
WHEREFORE the Plaintiff requests this Court to enter a decree of
divorce under Section 3301 (c) of the Divorce Code.
COUNT II
Equitable Distribution
10. Plaintiff incorporates by reference paragraphs I through 9 of
this Complaint.
11. Plaintiff and Defendant have acquired various items of
marital property which are subject to equitable distribution by this Court
under Sections 3501 and 3502 of the Divorce Code.
. . .-.
12. Plaintiff and Defendant have not agreed on an equitable
distribution of this property.
WHEREFORE, Plaintiff requests the Court to enter an order equitably
dividing all of the property.
Respectfully submitted,
L+2~
Pamela L. Purdy
Attorney for Plaintiff
Dated: &r+e~ J~/ 2DO"
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VERIFICATION
I verify that the statements made in the foregoing document are true and
correct to the best of my knowledge, information and belief. I understand that
false statements are made subject to the penalties of 18 Pa. c.s. 94904,
relating to unsworn falsification to authorities.
Dated: ~t.en* /'5,loOfo
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Pamela L. Purdy
Attorney ID No. 85783
100 Pine Street
Harrisburg, PA 17108-1166
(717) 232-8000
(717) 237-5300 facsimile
plpurdy@verizon.com
Attorney for Plaintiff
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PAULAj. MANN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND=OUNTY, PENNSYLVANIA
. NO. Ob - 5L{~-1 C; ud Term
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I hereby accept service of the Complaint in Divorce under Section 3301(c) of the
Divorce Code in the above-captioned matter.
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Date
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125. E. Springville Road
Boiling Springs, PA 17007
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Pamela L. Purdy
Attorney ID No. 8S 783
100 Pine Street
Harrisburg, PA 17"108-1166
(717) 232-8000
(717) 237-5300 facsimile
plpurdy@verizon.com
Attorney for Plaintiff
PAULAj. MANN,
Plaintiff
v.
MARK K. MELUSKEY.
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 01.. - $4 ~ l ~...~L ~
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IN DIVORCE
NOTICE TO RESUME PRIOR NAME
NOTICE is hereby given that the Plaintiff in the above-captioned
matter is in the process of a divorce, the Complaint in Divorce having
been filed by Plaintiff on September 18, 2006. Plaintiff hereby elects to
resume the prior surname of Paula j. Mann, and gives written notice
pursuant to the provisions of 54 P.S. 704.
Date: ~ 't/zotk>
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ulaJ. Mann-Meluskey ..,..
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CERTIFICATE OF ACNKOWLEDGEMENT OF NOTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
On this, the -.!itvt day of December, 2006, before me, Pamela L.
Purdy, a notary public, the undersigned officer, personally appeared Paula
j. Mann-Maluskey, 317 N. Front Street, Harrisburg, Dauphin County,
Pennsylvania 17101, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purposes therein
contained.
In witness whereof, I hereunto set my hand and official seal.
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Pamela L. Purdy
Attorney ID No. 85783
115 Pine Street, Ste. 100
PO Box 11 544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Defendant
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
PAULAJ. MANN,
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code
was filed on July 17, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the 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. 9 4904 relating to unsworn falsification to authorities.
Dated: ~{Y>f 07
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Pamela L. Purdy
Attorney 10 No. 85783
11 5 Pine Street, Ste. 100
PO Box 11 544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Defendant
PAULA J. MANN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER Ei3301 Cd 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. 1 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.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. ~4904 relating to unsworn falsification
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Pamela L. Purdy
Attorney 10 No. 85783
11 5 Pine Street, Ste. 100
PO Box 1 1 544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Defendant
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
PAULAJ. MANN,
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code
was filed on July 17, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the 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. 9 4904 relating to unsworn falsification to authorities.
Dated: 6g J/\ ~ ~I
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MARK K. M U~Y
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Pamela L. Purdy
Attorney ID No. 85783
11 5 Pine Street, Ste. 100
PO Box 11544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Defendant
PAULA J. MANN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
v.
MARK K. MELUSKEY,
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.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. 94904 relating to unsworn falsification to authorities.
INti- ~/
Mark K. Me u ey
Dated: 09 -:)II\..A kiJ,
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Pamela L. Purdy
Attorney 10 No. 85783
11 5 Pine Street, Ste. 100
PO Box 11544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
PAULA J. MANN,
Plaintiff
v.
MARK K. MELUSKEY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
IN DIVORCE
PRAECIPE TO WITHDRAW ECONOMIC CLAIM
TO THE COURT:
Please withdraw Count II for equitable distribution in the divorce complaint in the
above-captioned matter.
Dated: ~"^-~ l J 'lret-
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Pamela l. Purdy
Attorney ID No. 85783
11 5 Pine Street, Ste. 100
PO Box 11544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
PAULAJ. MANN,
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please 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: September 25,
2006, U.S. Mail, First Class, postage prepaid; Acceptance of Service signed by
Defendant on September 28, 2006, returned to the office of the undersigned,
and filed with the Court on October 18, 2007.
3. Date of execution of the Affidavit of Consent required by 3301 (c)
of the Divorce Code:
By Plaintiff: 1/25/07
By Defendant: 1/8/07
4. Related claims pending: Plaintiff filed a Praecipe to withdraw her
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economic claims simultaneously with this Praecipe to Transmit Record.
S. Date Plaintiffs Waiver of Notice was filed with the Prothonotary:
contemporaneously with this Praecipe. Date Defendanfs Waiver of Notice was
filed with the Prothonotary: contemporaneously with this Praecipe.
Respectfully submitted,
Date: ~ lfj lov:r
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PAULA J. MANN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
MARK K. MELUSKEY,
Defendant
NO. 06-5451 CIVIL TERM
ORDER OF COURT
AND NOW, this 23rd day of February, 2006, upon consideration of Plaintiffs
praecipe to transmit the record in the above-captioned matter, and it appearing that
Defendant's affidavit of consent was not filed within the 30-day time period as required,
a divorce decree will not be entered at this time, without prejudice to the parties' rights to
correct the deficiency and file a new praecipe to transmit the record.
BY THE COURT,
Pamela L. Purdy, Esq.
100 Pine Street
Harrisburg, P A 17108-1166
Attorney for Plaintiff
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Pamela L. Purdy
Attorney 10 No. 85783
115 Pine Street, Ste. 100
PO Box 11544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
PAULAJ. MANN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code
was filed on July 17, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the filing and service of the
Complaint.
3. 1 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. 9 4904 relating to unsworn falsification to authorities.
Dated: 3(Z2( 2-co7
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PA LA J. MANN .
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Pamela L. Purdy
Attorney ID No. 85783
11 5 Pine Street, Ste. 100
PO Box 11 544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
PAULAj. MANN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER fi3301 Cd 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.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. ~4904 relating to unsworn falsification to..JMghorities.
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Dated: 3/22-( 2.w7
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Pamela L. Purdy
Attorney ID No. 85783
115 Pine Street, Ste. 100
PO Box 11 544
Harrisburg, PA 1 7108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
PAULA J. MANN,
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code
was filed on July 17, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the 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. 9 4904 relating to unsworn falsification to authorities.
~l[ u~~
MARK K. M EY
Dated: i <;' 0Vl~ J-eJI
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Pamela L. Purdy
Attorney 10 No. 85783
11 5 Pine Street, Ste. 100
PO Box 11 544
Harrisburg, PA 17108
(717) 221.8303
(717) 221.8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
PAULAj. MANN,
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER Ei3301 (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.
understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. S4904 relating to unsworn falsification to authorities.
~L~/
Mark K. M luJ<ey
Dated: 1<' tM.A<Ut.l ~i'
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Pamela L. Purdy
Attorney ID No. 85783
115 Pine Street, Ste. 100
PO Box 11544
Harrisburg, PA 17108
(717) 221-8303
(717) 221-8403 facsimile
plpurdy@verizon.net
Attorney for Plaintiff
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 06-5451 CIVIL TERM
PAULAJ. MANN,
v.
MARK K. MELUSKEY,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please 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: September 25,
2006, U.S. Mail, First Class, postage prepaid; Acceptance of Service signed by
Defendant on September 28, 2006, returned to the office of the undersigned,
and filed with the Court on October 18, 2007.
3. Date of execution of the Affidavit of Consent required by 3301 (c)
of the Divorce Code:
By Plaintiff: 3/22/07
By Defendant: 3/1 5/07
.. ..
4. Related claims pending: Plaintiff filed a Praecipe to withdraw her
economic claims on February 13, 2007.
5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary:
contemporaneously with this Praecipe. Date Defendant's Waiver of Notice was
filed with the Prothonotary: contemporaneously with this Praecipe.
Respectfully submitted,
Date: vY1CN1A t:;. Zlf07
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
PAULA J. MANN
PLAINTIFF
No. 06-5451
VERSUS
MARK K. MELUSKEY
DEFENDANT
DECREE IN
DIVORCE
AND NOW,
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, 20D7, IT IS ORDERED AN D
DECREED THAT
PAULA J. MANN
, PLAI NTI FF,
AND
MARK K. MELUSKEY
, DEFE:NDANT,
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;
N/A
J.
PROTHONOTARY
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