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Home My WebLink About96-00182 " . , ! " ! i , I ( t' I , i .I ; I" i i " ' . ' i j , I ' ; I' I - _I' i .' f i ' ,.1 : :1 ' ! ! ! / , 1 r i n Co - I .3 0- ~i I I I I \ i ~ a. . -7 , , ! i I , I , I . , I ! i \ , \ , kl ] ~ d.. i -/ /~~," l"- SI JI I I I ;. i }.. . " -t -" , ", -----~.------------_._---.----~ ~ ,---------.------ -----,-~--,--~------,--'---'. . ~ 1[1 ~ . ~ IN THE COURT OF COMMON PLEAS : ~ 8 ~ 8 ~ 1[1 ~ ~ 8 OF CUMBERLAND COUNTY STATE OF *, PENNA. BRIAN EDWARD ALEXANDER, Plaintif f N I). 9.~~H2,q. qC:,+.v.:r.~. 19 Vl'l'.-;Wi oj ~ . ,MELANIE LOU ALEXANDER, 1[1 ~ 8 1[1 8 . ~ " 1[1 ~ . ~ . . 1[1 ~ 1[1 1[1 1[1 8 . : lIy The Cjjj~~ ~r- ),. I ^"..~~'''<~, F' ;~iZR~!I 8 '!--;;(:j/",/ /" ~~ ? 2.:4 ~ (/ 77PrnllwnOlillY -- ----.---.-- . ._-,,,-, ..,.." "" . , ~-~~~~--~~~~~~*****~. Defendant DECREE IN DIVORCE AND NOW, . . ,U..\l.1 ~f.t r. ,.~,~..... 19, .9.~. . 0 it is ordRrfld and dflcrflfld that... !l!l.I,1'~~. !>PI'!~!lP. .~~~.x,l\~9!l.R. . . . . . . ... . . " .. . .,.. pllllntiff, nnd . , . . . !'I.~~f,I~.I.~ . ~~.u, .~L!'l?'.~~~~.~ . . , . . , . , . . , . . . . . , . . . . , . . . " dRfflndnnt, nre nlvorcen from thfl honns of matrimony. The court retains lurisnictlon of the following c1nlms whlr.h havR been raised of rfleorn in this nction for which a finnl ordRr hns not yet been entered; ..........,...,. .tiC/I)!'!",.,.......,.,.......,...,..""..,.......,..."..,.. ........... .....,.......,.....................,.,.... ,.. '~ i ! .~ !'.' I ~ .:.:. .:.:- .:.:- .:.:. .:.:. .:.;. .:.:. -:.:. .:+:. .:.:.' ~ 8 w ... .. " .. " oj ~ ~ " ~ .... 1[1 1[1 8 ~ f~ ~ ~ ~ 1[1 1[1 1[1 .. ~ ~ ~ .~ .', ~ w .~ I: ,~ I.~ * ~ ~ I: ';~ ~ ;,: '.' .... VI ,. ~\; c: ,.- 1;~ & ).f.: III ~~} )... (.)(~ ... [':, .'.... . ;;;~ ejl: 1)... . ~) ;::i c' . ,- )':1 :n .:.J! "I C ' u' ..:~ G:I.' ...~' , Ii' r-~ t, .~~(~ :..r..: l', ~,~ :5 0 c' L) . . If,W...."1 M^Hlttllt MIl ,\1111 BRIAN EDWARD ALEXANDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. MELANIE LOU ALEXANDER, Defendant NO. 96- IS;). CIVIL TERM CIVIL ACTION - IN DIVORCE NOTICE TO DEPEND 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. If the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. Ir YOU DO NOT rILE A CLAIM rOR ALIMONY, DIVISION or PlOPERTY, LAWYER'S rEES 01 EXPZNSZS BErORS A DIVOlCE OR ANJIULMENT IS GRANTED, YOU MAY LOSZ THE RIGHT TO CLAIM ANY or THEM. YOU SHOULD TAKE THIS PAPEl TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 01 CANNOT APFORD ONE, GO TO 01 TELEPHONE THE OFFICE SET FOlTH BELOW WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Court One Court House Square Carlisle, Pennsylvania (717) 240-6200 House 17013-3387 itw~q;ik Marlin R. McCaleb Attorney for Plaintiff I^W till" I '. M^,H IN II 11.1\( ^IIII BRIAN EDWARD ALEXANDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. MELANIE LOU ALEXANDER, Defendant NO. 96- CIVIL TERM CIVIL ACTION - IN DIVORCE COMPLAINT UNDBR SBCTIONS 3301 lallll and 330110101 33011dl or TNZ DIVOlCI CODI 1. Plaintiff is BRIAN EDWARD ALEXANDER, who currently resides at 5308 Oxford CirCle, Apartment 85, Mechanicsburg (Lower Allen Township), Cumberland County, Pennsylvania 17055, since January 6, 1996. 2. Defendant is MELANIE LOU ALEXANDER, who currently resides at 53 West Keller street, Borough of Mechanicsburg, Cumberland County, Pennsylvania 17055, since June 2, 1987. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 2, 1978, in the Borough of Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The grounds upon which this action is based are: (a) The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to -2- l' I ,\ d 'I' ii' 1:\ i: " Ii , i.' I '. ~. -'" .... .1C N [; t:::: .. ~'i .II~"'" C1 '.. .~.. 1"'2(:; ;: :~' ~": 1.-"'- .. -- ... I'~~ ....c , "' ': . c.) ,"l.d .' .. ,-. _ r... \J) ...' ,",' u. - .J,'; L. t'l ~': fi~tJ rL _L 1'-' ... _) .,.JIL. II. \.n r.j o 0' II ~ . ~~ 3~ .C: \j ~ ~~ ~M ~t ~ ~i II ! I " ow ~ ~ ow .. ';I I~ 'f ~"'ti ~ i'!5= I E ~ ~ ~ ~ . I! ~ - ., ~z~~ ~ II I ~ ~ 'in ~ ffi:dl:' i l:I :\ ffi ~ 0 d Ii! ~ r ., · 01 .. I' /i~ ~ - 11 I N - z I . , ~ ~i g ~ 2 .. . BRIAN ImWARII AI.g)<ANIIER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. :\0 , %- I 82 C I V 11. TEIIM MEI.AN I E J.OU AI.EXANIIEII Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAI~ RIGHTS You have been sued In court, If you wish to defend against the claims set forth in the following paves, you must take prompt action. You are warned that If you fall 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 clnim or rollef roquested in these papers by the Plaintiff, You may lose money or proporty 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 Court Administrator atl Cumberland County Courthouse 4th Floor carlisle, PA 17013 (717) 240-6200 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. Court Administrator Cumberland County Courthousu 4th Floor Carlisle, PA 17013 (717) 240-6200 BRIAN EDWARD ALEXANDER PI ainti ft IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-182 CIVIL TERM vs MELANIE LOU ALEXANDER Defendant IN DIVORCE ANSWER 1. Admitted. 2. Admit t ed, 3. Admitted, 4. Admit t ed, 5, Admit t ed, 6. (a) Denied - It is specifically denied that Defendant offered indignities to the Plaintiff and/or that Plaintiff is the innocent and injured SPOUse: rather Defendant avers she is the innocent and injured SPOuse and that Plaintiff's abusive conduct toward Defendant during the marriage constitutes indignities from Plaintiff to Defendant which have rendered her condition intolerable and her life burdensome; and (b) Admitted, 7, Admitted, 8, Admitted in part - Denied in part, Defendant admits the marriage is irretrievably broken and consents to a Decree in Divorce on that ground only. Averments of indignities by Defendant are denied and Defendant objects to the entry of ~ Decree in Divorce on those grounds. QOVNTERC~^IH EQUITABLE DISTRIBUTION 9, The averments in paragraphs 1 through 8 above are incorporated herein by reference thereto. 10, Plaintiff and Defendant have acquired property, both real and personal during their marriage from December 2, 1978 until September 22, 1995, the date of their separation, II. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. A~IHON~ 12, Paragraphs 1 through II above are incorporated herein by reference as though set forth in full. 13, Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 14, Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony in her favor, -2- I\t.HIONY ,PENDENTE I. ITE I COUNSEl. fEES, . c::.o 13 TJl I\NP EXPENSES 15, Paragraphs I through 14 above are incorporated herein by reference as though set forth in full. 16, Plaintiff has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, 17, Plaintiff is unable to sustain herself during the course of this litigation, WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony Pendente t.ite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate, ~\l,s'I'OI,)YJ.l',I\J{YJ~" _S'JUJ'fPD)' , _ANP!PJLV ~ ~J 'I'1\'!'],Qli 18, Paragraphs 1 through 17 above are incorporated herein by reference as though set forth in full. 19, Plaintiff and Defendant are parents of the follOWing unemancipated children: Names Age Sex Date of Bi rth Brian Keith Alexander 16 Male 6-16-79 Hegan Hae Alexander 10 female 1-26-85 Both children currently reside with their mother at 53 West Keller Street, Mechanicsburg, Pennsylvania 17055, -3- ..: H ~ ~ Ul ~~ ~~ ~~ liS ~~ !~ ,." .' rn .":: ,uf!i ,'-J C") , ; (]', . ,,' Ff' , , J... " .. r, I.~ . 10- , , rl' , ) III ("'I , I;, ( " i ~ , .' "h" ( I r~ I U ffi f-< ..l H ~ U Nt>.! <DU ....,.: 10 ~~ I'l . :Hi !:l ~ :;;J ~ ~ :;;j '" "" "" '''; .... .~ '" ... Po< . III :> !:l ~ S :;;J .... ~ '1:l 11 Q) "" Q) r:> ~ :J U el ~ o U o ... ... g ~ ~ 8 ~ .. o ~ '" c' ~ ID ~ (ii ;z ~ N~~~~ ...~ Hi;: a: g ~ ID ;; LIl .. _ ::I ~ C .. f:l 0( ~ z ::> o ..l t>.! H ~ F.! ~ ~ Ul ~ . . BRIAN EDWARD ALEXANDER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NO. 96 - If.2.. CIVIL TERM MELANIE LOU ALEXANDER, Defendant CIVIL ACTION - IN DIVORCE ,aaZCIPZ rOR ENTRY or APPzaRAHCE AND ACCEPTANCE or SERVICE TO THE PROTHONOTARY: Please enter my appearance for and on behalf of Melanie Lou Alexander, the Defendant in the above-captioned action. I hereby accept service of the complaint of Divorce on behalf of Melanie Lou Alexander, Defendant herein (and certify that I am authorized to do so) and I acknowledge receipt of a true copy of said Complaint. /' Date:~;?~ ~() , 1996 ~' Albert Z.Boge t, Esquire Attorney for Defendant BRIAN EDWARD ALEXANDER Plainti ff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 96-182 CIVIL TERM vs MELANIE LOU ALEXANDER Defendant IN DIVORCE ~RMg,I PJ;:__hN.!LR.l!J,lLi:QIL..!H,1, f,.~J".. J' ARTLGQLJ'lR Ii TO THE PROTHONOTARY: please enter a rule on Plaintiff to file a Bill of Particulars within twenty days after service of the Rule, or non pros against the defaulting party. Date: ..---: ;/art cA{ /77& /' RULE AND NOW, this .JI. g: day 0; Y"".Ll' , 1996, a Rule is issued as above, () 'J" a )Hdc..~ ~<t. Prothd'notary BRIAN EDWARD ALEXANDER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NO. 96 - 182 CIVIL TERM MELANIE LOU ALEXANDER, Defendant CIVIL ACTION - IN DIVORCE BILL 01' PARTICULARS BRIAN EDWARD ALEXANDER, Plaintiff herein, by and through his attorney, Marlin R. Mccaleb, Esquire, sets forth the following Bill of Particulars in support of his allegation that the Defendant has offered such indignities to him, the innocent and injured spouse, as to render his condition intolerable and life burdensome: 1. During the last three years that the parties lived together, Defendant embarrassed plaintiff, by sitting with other men instead of Plaintiff and by dancing with other men instead of Plaintiff. i '1 i , 2. During the last six months that the parties lived together, Defendant hurt Plaintiff's feelings and destroyed his feelings of love and affection for her by telling him that she wanted to be independent, that she wanted to be free to come and go as she pleased, that she wanted to be free to go out with whomever she pleased, that she didn't love him anymore, that she didn't want to be married to him anymore, and by removing her wedding ring from her finger and not wearing it I^W 1111111', anymore. M^,IIlN II Mil AI 1.1\ 3. During the last six months that the parties lived lAW IJIIl! I', MAUI.IN II "'11 C MTH ,~,,,--,,,,,,,,_,.I_,_';in : together, Defendant hurt and humiliated Plaintiff by calling him a "fucking asshole," by telling him that he had been an "asshole" for sixteen years, by accusing him of "underhanded shit" and by calling him "worthless", "infantile" and "juvenile", and by telling him "fuck you". 4. During the last six months that the parties lived together, Defendant worried Plaintiff by going out in the evening with her girlfriends and not coming home until the early morning hours or by not coming home at all. Her actions upset Plaintiff when he thought about what she might be doing. 5. At first, the conduct described in Paragraph 4, above, occurred on a weekly basis, but then it increased to two evenings per week, and then to three and even four evenings per week. 6. Defendant hurt and embarrassed Plaintiff when she went out in the evening with her girlfriends by meeting, drinking and dancing with other men in pUblic where Plaintiff's friends and acquaintances could see her. 7. When she went out in the evening, Defendant taunted Plaintiff by dressing provocatively and then asking him how she looked, and by asking him if she looked "slutty." She also told Plaintiff that having an affair would be a natural thing to do. 8. During the last two months that the parties lived together, Defendant hurt and embarrassed Plaintiff by going out -2- , " . with other men and by being seen in public with other men by Plaintiff's friends and acquaintances. During this time, Defendant would not tell Plaintiff where she was going and she did not return home until the early morning hours and occasionally she did not come home at all. 9. During the last two months that the parties lived together, Defendant dated one man in particular and spent time with him at his home during the afternoon hours, during the evening hours, and sometimes she stayed until the early morning hours. I verify that the statements made in this Bill of Particulars 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. 1'/;" ,.('6-- C~M'/.( /lh,.;;w-J:, Brian Edward Alexande , Plaintiff Date: February 16 , 1996 I^W ll'IItI., M^ItUN II ",,, I^I III ~t!d~d&- Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiff -3- '- N ;-:: Cr; -- N t.. ~'J " 1I~C) .,) S ( .- 1"1 r"'t I ... i.~J . l. _.. ."... (~i:' c.. :"J E:~ ) C:1 ,. , !l ,J.... ...." ,. , , f.'.'1! (:.1 ' , :) t!...J 'I' f"- ~ I..' .. '. L.. tI. \..Q ::i l) Ul (J ~~ ~I u ~i~ ~~ ; o I I ~ !:;:! B ~7 ~ a ~:l: ~ e;.S ~ ulil u .... ~ .... ~ -I:: I~ ! ~ . ~ ~ ~ 'tl -I:: I~ S r.l ; , " I ~ I-l E1 re r.. o ~ III l I' : 9 ~ .~~~ ~ · ~ ~ d ~ ~ ffid~ ~ ~~ ~a~~ ~ ~ tJ N Z . : Ii! 2 I I I . " ,- C) ';- l,- r,:: i~ - 6\ :,i...;_ 11I..',~ '~.,) ~~.l fEl'; ..-....~ ~jr',: ":':: ~:3 t,J : : ':~j a': . f,. C\J . J :~.: ..Jr-;- " ~'. C' ; "Ira u:: .." lL. r..: t ~ lJ. lL. . It_ '.rJ :.:J t) ~J\ (,) .,.. , r.!"; In -= '" i'. " .. (' ~ )~(. UI,.. C.J.i .-;\::-.~ [... . !~ I. ~'. .'- 1:') ~" ,I .- f_ r '1'> u) U-'" ,-7 [,!I' ' ::~ l:; 'j,1J r' ;..;: .:] u.. ", U) :i c' 0\ U , , , , , ~. 1.:1 (~ r'~ ~.. ..:; .. I' ('1 '.,- III .~,. C1if- _l~) 1'-" ~~: "c L-( "i~ A' , .1;_ ! . ~n Ul" \.~ , ,ra '..1 II':, r c' lU... _.; t '5 .j ..:. , ' ,') I.- . () . . . . . ">- \11 i'-:' t:,~ c. ~~ t~! ~I~~ c'\ ',,\:' " ::=:r:. c,.( .~.. \i:', \,.}.. '.7J q\ '0 ifl (;I' !('"; ltl'-. ,-\r~ .-!t,' :-., 1..1"", .. " u.. ( ., .~ I'. ,n i:) 1".1 '-i' '. . . . . . . . . . .. .. BRIAN EDWARD ALEXANDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. MELANIE LOU ALEXANDER, Defendant NO. 96 - 182 CIVIL TERM CIVIL ACTION - IN DIVORCE WAIVBR OP NOTICB OP INTBNTION TO ~BOUl:ST BNTRY OP A DIVORCB DBCRBJ: UNO R 13301 (01 OP THB DIVORCB CODB 1. I consent to the entry of a final decree cf 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. 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: lu;'i.:'ht- , 1996 Ul:Y1 ;::'<,ktl1!L Brian Edward Alexande , Plaintiff ~-^_..... .._. ~- UI :,'..- tr, c.: -c ~.-\ ~ 1\18 ~~ :..J;~: c.~i- ,". ';:~ I'.,' \~.. ,..~::.J ~l~ '- In . ill ,- II " , ~'- '-' -~. ICl' t ,:'IiLJ >"!o.. r': ;.... ~ i 1.',. V') (,) C) {i', . ... . ,~ .,) , U'''I' -.... f' ell j. r: .. f:!: .- . "5- '" .. , .~ .. .". , !:':! ). ':,) ft! ' .... , '::: '1 Lori Ll_ ~,.' ':'.j IT " (D '" LJ l.~ ,',') I j ~,~ . ',; u:t:1 .' "I III f'. f: ~ !l.l.. -. Il. ..., .' ~ u , en ,) I~ P ~i !~ ~ ~~ ~ ~; ~ ~ ~ ~ ~ I~ Ii !~ ~ s~ ~ I ~ Vl II ~Fl t:J~ ~~ o ~ .. ,.. m 0 ~ ~ gdn N ~ q E t::PmC UJ j: ~ J !: ~ 0( M G .; ~ Z .~, . ~ . . . ~ ,. . ,- . ND\' 1 'j i'j;~,'tY" . ,