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HomeMy WebLinkAbout02-3641IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant NO. (~'~ ,~ ,~ ~"q/ CIVIL ACTION- LAW 1N 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 relief requested in these papers by the Plaintiff You may lose money or property or other rights important to you. 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 Court House, 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 ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant NO. ~. ~ CIVIL ACTION - LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe romar accion con prontitud. Se le avisa que si not se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien set emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades y otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALLMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USED PUEDE PERI)ER EL DER.ECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE 1-NMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAIO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telefano: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE Defendant :NO. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Sueann Matrese, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant NO. d>:2- .76 CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this ,~gt~t. day of July, 2002, comes the Plaintiff, Suearm Matrese, by her attorney, G. Patrick O'Connor, Esquire, Office of G. Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: 1. The Plaintiff, Sueann Matrese, is an adult individual who currently resides at 6223 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, Stephen H. Matrese, is an adult individual who currently resides at 2166 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant were married on or about October 19, 1985, and separated on or about June 15, 2002. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaimiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely. Respectfully submitted, /G. Patrick O C0nnor, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 ID No. 64720 Attorney for the Plaintiff VERIFICATION I, SUEANN MATRESE, state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are tree and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unswom falsification to authorities under 18 Pa.C.S. Sec. 4904. Date: ~Cd~ann IVl~ese IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant NO. 02-3641 Civil Term CIVIL ACTION - LAW · IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA. R. CIV. E 1920.4 G. Patrick O'Connor, Esquire, being duly sworn according to law, deposes and says that he mailed a copy of the Complaint in Divorce filed in this matter by certified mail, return receipt requested, addressee only, to the Defendant at 2166 Yale Avenue, Camp Hill, Pennsylvania 17011. The remm receipt signed by the Defendant is evidence of delivery to him and is attached as Exhibit "A". I verify that the facts contained above are true and correct to the best of my knowledge, information and belief. I understand that the facts herein are verified subject to the penalties for unsworn falsification to authorities under Crimes Code, Section 4904 (18 Pa.C.S. {}4904). ,X~. Patrick O'Connor, Esquire I.D. No. 64720 3105 Old Gettysburg Road Camp, Hill, PA 17011 Phone 717-737-7760 Atto~aey for Plaintiff II Print ~~ on the reverse ~o th~i~c~d to you. · Attach this card to the back of the mailpiece, X ~1~/,~ ..~ o~ on the front ff space permits. 1. ~tlcle Addressed to: [] Agen~ ~ Isj~tve~addressdlffemnt fmmitem 17 [] Ye~ If YES, ent~' delivery address below: [] No [] Registered [] Insured Mail [] Express Mail [] Return Receipt for Mercham~ll~e [] C,O.D. 2. A~ticle Number (Copy from service labet) ~ ~) /~'~ C'~ 00~ ~-~ ,~7~-~-~ PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant NO. 02-3641 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 30, 2002 and service made on the Defendant on August 5, 2002. 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. CS. Section 4904 relating to unsworn falsification to authorities. ~ Ma~se, Plaintjtt~' t/ -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant : NO. 02-3641 Civil Term CIVlL ACTION - LAW 1N DIVORCE AFFIDAVIT OF CONSEiNT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 30, 2002 and service made on the Defendant on Augast 5, 2002. 2. The marriage of Plaintiff and Defendant is irretrievabJLy 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. Section 4904 relating to unsworn falsification to authorities. DATE: Stephe~ H. Matrese, Defendant MyC, ommissJon Expires Dec 19, 2~05 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant NO. 02-3641 Civil Term : CIVIL ACTION - LAW : 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 ifI 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 inunediately after it is filed with the Prothonotary. I verify that the statements made in the foregoing 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:/~9 ~3/- 02, Stephen H. Matrese, Defendant Frtrl~ln A. T~h'~est, No~y ~ 01y Ci~ Hamsburg, Daupt~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANLk SUEANN MATRESE, Plaintiff VS. STEPHEN H. MATRESE, Defendant : NO. 02-3641 Civil Term (a) Date of execution: plaintiff: November4 2003 defendant: Date of filing: plaintiff.' contemporaneously herewith defendant: contemporaneously herewJtth CIVIL ACTION - LAW IN DIVORCE PRAEClPE TO TRANSMIT THE RECORD Grounds for divorce: ,/'Section 3301(c) of the Divorce Code Section 3301(d) of the Divorce Code (a) Date complaint filed: ~ (b) Date of service of the complaint: ~ 2002 (c) If service 30 days after date of filing, date complaint reinstated: (d) Manner of service of the complaint: ,/ Certified mail, restricted delivery to and return receipt signed by defendant __First-class mail-not returned, certified mail refused, 15 days have elapsed ~_Date of mailing: Date certified mail refused: __Personal service by Shefiffand/or Deputy Sheriff __Personal service by competent adult other than Sheriff (Affidavit attached) __ Acceptance of service (Copy attached) By publication pursuant to Order of Court (Copy of Order attached) Affidavit of consent required by Section 3301[(c) of the Divorce Code: _October 31, 2003 (b) Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: Date of execution: Date of filing: Date of service upon defendant: Manner of service: Related claims pending: None. All economic clalm~ have been settled. (a) Date of service of the notice of intention to file praecipe to transmit, a copy of which is attached: Manner of service: (b) Date waiver of notice to file praecipe to tr~asmit was filed with the Prothonotary: By plaintiff: contemporaneously herewith By defendant: contemporaneously herewith VERIFICATION I verify that the statements made in this praecipe are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Date j~ttorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUN1BERLAND COUNTY STATE Of PENNA. SUEANN MATRESE Plaintiff VERSUS STEPHEN H. MATRESE Defendant NO. 02-3641 Civil AND NOW, DECREE IN DIVORCE DECREED THAT AND SUEANN MATRESE STEPHEN H. MATRESE , PLAINTIFF, , 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 ~AIHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. All economl, / BY THE fURT: ATTEST: PROTHONOTARY + ++ + + ++++ ++++++++++ ++++~.+++++++++++++++++++++++++++++