The URL can be used to link to this page

Home My WebLink About02-2786BEVERLY PAULUS, Plaintiff VS. TERRY B. PAULUS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- ~ -1 ~'(-~' CIVIL ACTION - LAW 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 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. 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 (717) 249-3166 1-800-990-9108 BEVERLY PAULUS, Plaintiff VS. TERRY B. PAULUS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002 - CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Beverly Paulus, an adult individual whose mailing address is 4175 Mountainview Road, Apt. 104, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose social security number is 184-38-0478. 2. The Defendant, Terry B. Paulus, is an adult individual, whose current address is R.R. #1, Box 97C, Loysville, Perry County, Pennsylvania 17047, and whose social security number is 206-32-2064. 3. Plaintiff and Defendant were married on June 13, 1981. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children bom of the marriage. 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: VERIFICATION I verify that the statements made in this Complaint in Divorce 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: BEVERLY PAULUS, Plaintiff IN THE COURT ( CUMBERLAND ( PENNSYLVANL6 TERRY B. PAULUS, : NO. 2002-2786 Defendant : : CIVIL ACTION : IN DIVORCE PRAECIPE To the Prothonotary: Please enter my appearance on behalf of the defendant, Terry B. captioned matter. Dated: June 19, 2002 Respectfully Submi Kevin E. Prosser, E Supreme Cou~ ID PO Box 395 New Bloomfield, P ~F COMMON PLEAS ~OUNTY, LAW Paulus, in the above tted, ~quire ~77227 17068 BEVERLY PAULUS, PLAINTIFF VS. TERRY B. PAULUS, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 02-2786 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE CERTIFIED MAIL COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Be it known, that on the IQ'p~ day of SS: ,2003, before me, the subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly sworn according to law, did depose and state as follows: 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania. 2. I represent Beverly Paulus, Plaintiff in the above-captioned matter. 3. On June 11, 2002, a true and correct copy of the Complaint in Divorce Under Section 3301(c) of the Divorce Code was deposited for delivery with the U.S. Postal Service, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7001 1140 0000 9826 9732, and addressed to the Defendant, Terry B. Paulus, at RR #1 Box 98C, Loysville PA 17047. 4. The return receipt card signed by the Defendant, Terry B. Paulus, showing a date of service of June 12, 2002, is attached hereto as Exhibit "A". o Pa.R.C.P. 403. Service by certified mail meets the requirements of Pa.R.C.P. 404(2) and KAY~A~-'DIELLO, Counsel for air, iff SWORN TO AND SUBSCRIBED before me, a Notary Public, this l~4l'x day of ~ ., 2003. Notary Public~ My Commission Expires: O~ .......... Notarial Seal Kimbefly R. Hanford, Notary Public Mechanicsburg Bore, Cumberlan.d ~C..ou?y My Commission Expires Apr. ,~, ~,uuo EXHIBIT "A" · Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · 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 maitpiece, or on the front if space permits. 1. Article Addressed to: / 2. Article Number PS Form 3811, August 2001 A. Signature B. Receiveo~/(Printed Name) C. Daw of pelive~ D. Is deliver3/address different from item 17 [] Yes If YES, enter deliver/address below: [] No 3. Se.rvice Type _,,~Certified Mail [] Mail Express [] Registen~ [] Return Receipt for Merchandise [] Insured IVlail [] C.O.D. 4. Restricted Delivery? (Extra Fee) ,,~Ye$ Domestic Return Receipt 102595-01-M-25(; BEVERLY PAULUS, PLAINTIFF ¥S. TERRY B. PAULUS, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2786 CIVIL TERM CIVIL ACTION' - LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANC..~E Please withdraw my appearance on behalf of the Plaintiff, Beverly Paulus. Respectfully submitted, DILS & DILS Dated: PA I.D.#71873 1017 North Front Street Harrisburg PA 17102 (717) 233-8743 PRAECIPE FOR ENTRY OF APPEARANC..~.E Please enter my appearance on behalf of the Plaintiff, Beverly Paulus. Respectfully subtnitted, LAW FIRM OF :SUSAN KAY CANDIELLO, P.C. Dated: Susan Kay Can~}6~lo) Esquire PA I.D. # 64998.._.~ 5021 East Trindle Road Suite 100 Mechanicsburg PA 17050 (717) 796-1930 BEVERLY J. PAULUS, Plaintiff, V. TERRY B. PAULUS , Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-2786 IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Kindly withdraw the appearance of Kevin E. Prosser, Esquire, on behalf of Defendant, Terry B. Paulus. Dated: PHILPOTT 8,: PROSSER, LLP Kevin~E. P~sser, Esquire Attorney I.D. No. 77227 15 East Main St. PO Box 395 New Bloomfield, PA 17068-0395 (717) 582-4262 PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Brace J. Warshawsky, Esquire, on behalf of Defendant, Terry B. Paulus. Dated: AoCr~J' I/~arshawsky, Esq~it~/ ey I.D. No. 58799 ~'~ P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 287967-1 BEVERLY PAULUS, PLAINTIFF VS. TERRY B. PAULUS, DEFENDANT IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 02-2786 CVv'IL TERM : : CIVIL ACTION - LAW PRAECIPE FOR WITHDRAWAL OF COMPLAINT AND NOW, comes the Plaintiff, BEVERLY pAULUS, by and through her counsel, Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and requests to Withdraw the Complaint for No-Fault Divorce under Section 3301 (c) of the Divorce Code in the above matter Without Prejudice. Dated: November j.~2003 Respectfully submitted, LAW FIKM OF SUSAN KAY CANDIELLO, P.C. Su~n Kay Can& 1~o, ~squ Counsel for Plai li~ PA I.D. # 64998 5021 East Trindle Road, Suite 100 Mechanicsburg PA 17050 (717) 796-1930