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Home My WebLink About00-00002 DOROTHY A. KRYZANAUSKAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. OIOCO -;) ~ STEPHEN M. KRYZANAUSKAS, Defendant : IN DIVORCE NOTICE TO DEFEND 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. 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, I Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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, P A 17013 (717) 249-3166 "''J''""""",,, , , v' _,_ , ,~o~ " >-- DOROTHY A. KRYZANAUSKAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION ; NO. 2M> - <- Cox1 -r~ STEPHEN M. KRYZANAUSKAS, Defendant : IN DIVORCE NOTICE OF RIGHT TO COUNSELING You are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors is available in the Office ofthe Prothonotary at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013-3387. Prothonotary ,- ,'-'--"",,, ~ - "^ > - '" ,--, ~- , h ~_ "'~ DOROTHY A. KRYZANAUSKAS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. CIVIL ACTION STEPHEN M. KRYZANAUSKAS, Defendant n' 'n.....e..- : NO. .2 H-O - 02 LM><-t' 1< : IN DIVORCE ~ CONSOUBkTEB COMPLAINT IN DIVORCE 1. Plaintiff is DOROTHY A. KRYZANAUSKAS, a citizen of Pennsylvania, residing at 910 Herman Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is STEPHEN M, KRYZANAUSKAS, a citizen of Pennsylvania, currently residing at 107 Bamwood Place, West Hanover, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are sui iuris and have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. Jurisdiction of this matter is with the Commonwealth of Pennsylvania. 4. The parties are husband and wife and were lawfully married on May 17, 1997, in Delaware County, Pennsylvania. 5. The marriage is irretrievably broken. 6. Neither Plaintiff nor Defendant is in the military or naval service ofthe United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. The Plaintiff has been advised of the availability of counseling and of the right to 1 " t'~~, ""- ,,~,""~ "',~,, ~ ,," -'. .,^'1'.~ . "' request that the Court require the parties to participate in counseling. COUNT I Request for a Fault Divorce Under 3301(a)(6) ofthe Divorce Code 9. The prior paragraphs ofthis Complaint are incorporated herein by reference thereto. 10. Defendant has offered such indignities to the Plaintiff, who is the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. 11. This action is not collusive. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce, pursuant to 3301(a)(6) of the Divorce Code. COUNT II Request for a Fault Divorce Under 3301(a)(2) of the Divorce Code 13. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 14. Defendant has committed adultery. 15. This action is not collusive. 16. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such 2 "l"',H>'.:poO '." ~~. .~ ~, ,... . . , . counseling. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce, pursuant to 3301(a)(2) of the Divorce Code. COUNT ill Request for Divorce Due to Irretrievable Breakdown Under 3301(c) of the Divorce Code 17. The prior paragraphs ofthis Complaint are incorporated herein by reference thereto. 18. The marriage of the parties is irretrievably broken. 19. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 20. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. COUNT IV Request for Divorce Due to Irretrievable Breakdown Under 3301(d) ofthe Divorce Code 21. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 3 22. The marriage of the parties is irretrievable broken. 23. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. 24. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. Respectfully submitted, LAW OFFICE OF MICHAEL D. RENTSCHLER, P.C. ~~~~~ Michael D. Rentschler, Esquire Attorney for Plaintiff Supreme Court J.D. #45836 1300 Market Street, Suite 200 Lemoyne, Pennsylvania 17043 (717) 975-9129 4 2;:; 'n'~' - VERIFICATION I, DOROTHY A. KRYZANAUSKAS, verify that the statements made in the Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. ~ ~'" " " .', " , ci3 or -;.' FciL::f11~;rtf5tTARY , - . ." n. 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