HomeMy WebLinkAbout00-00209
',-,
~1iIIAAW
JOHN YURKO
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No.
2000 - eJ-Ot7
ti,J
TRACIL. YURKO
Defendant
CIVIL ACTION - DNORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
yOU HA VB 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 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
Prothonotary Cumberland County Courthouse, Carlisle, P A.
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 HA VB 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
.~~
-~. i
,
.
JOHN YURKO
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
No. 2000 -;2(} 9 ~ ~
v.
TRACIL. YURKO
Defendant
CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 330Hc)
OF THE DIVORCE CODE
TO THE HONORABLE, JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, John Yurko, by Bryan S. Walk Esq., and represents as
follows:
COUNT I
DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiff is John Yurko, who currently resides at 31 Scrafford Street, Shippensburg,
Cumberland County, P A 17257 and has resided there for approximately 6 months.
2. Defendant is Traci 1. Yurko, who currently resides at 31 Scrafford Street, Shippensburg,
Cumberland County, P A 17257 and has resided there for approximately 6 months.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least
six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 27, 1991, in Cumberland County, PA.
-~
.1
" ~
~.
~
5. There have been no prior actions of divorce or annulment between the parties.
6. Plaintiff avers that there are two children under the age of 18.
7. The Plaintiff is a citizen of the United States of America.
8. The Defendant is not a member of the Armed Services of the United States of America or its
Allies.
9. The marriage is irretrievably broken.
10. The Plaintiff has been advised that counseling is available and that Plaintiff may have the
right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to
Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and the
Defendant.
an S. Walk
LD.# 63881
108 - 112 Walnut Street
Harrisburg, PA 17101
(717) 238-5113
ATTORNEY FOR PLAINTIFF
I~
.
~
VERIFICATION
I verify that the statements made in these Pleadings 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: I ~7-cO
, '......_.......,.,.._......u'..................r".',k.".........~......J""'''.b.I~.'",___;'...~'"''"'-...,~''"-'',=~_=~~"'-l/.~"I"-'J-"'I'"'~.M"/'"..:"_;.~,
'"
~p"
E~~S-BEc:: (HL)
~O~H \fd 'fimqS!JJllH
laaJIS II1UlllM in-BO~
M'Il.l'l A3NHOll'l
1I18M 'S u8AJ8
,..
t~
'f\
~
~
~
~ ......
~ ~ v
~ \~ ~
~ \
~ . \
, .
~ ~
o
c
:R~
2?f{
z:::O
C9~
~O
~g
?J
~
~
C'
<-...,
~
o
o
'--
""
z
~
--I
j:,}-i:B-
,
-'Om
-:-.y
,:'50'
-"..{
'TTi
?5:D
~O
am
-'1
~
-0
::J::
~
t1l
(T\
;'-';::f;:.tlf;';~~'Ii""&.
1:"l-.,..~"'ii;\\l::c'",,'-'!5,,~ .'i'c..,y,{(~~,.E1"?,7~'Wd-X'~_i';: ,;;-~-'- ,i',",," <',..-, "',)j""\h"h~"'~~-, ;-_"%"'~-"'~"-_,,t:-",",".,<-....,; , ._,'~'.'h-Y:'-" '"'0''-', "^.1
,,' <',_." ,-_,~~,,"*"'''''''-"''''''"''-=~r.'''.-'','' "''',,'''''''-_-__~c'_'. "~,,"',_<,,,'_'., ,''''''" "-''' ,
JOHN YURKO
Plaintiff
v.
TRACI L. YURKO
Defendant
3. Artfcle Addressed to:
Traci L. Yurko
1750 Orchard Road
Chambersburg, PA 17201
r
z
"... "
..
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
No. 209 2000
CIVIL ACTION - DIVORCE
[J: Certifled
102S95"97"~~179 'Domestic Retum Race t
i .ge~ _ ptate~ 1 and/or 2 for additional services,
fJ . '. plete items 3, 48, and 4b.
CD . P lit your name and addtBss on the reverse of this fenn so that we
! card to yoll. . the b
i -AttaCh this tonn to the front of the mallplece, or on
.=i:rstum Receipt Requested- on the mail~iece
~ _The Return AeceJpt will show to whom the altitJe wa
- delivered.
c
o
~
ii.
~
J
l
g
~
In
a
'8
II
a:
c
~
"
~
Cll
c
II
"
!
i
...
jo
..
r'~.'~ ',,"
tP'livtuEilil.~.~~ ilIlIir""~"""~' ~ ~~ji'i1l~llil.ljbi",J_jl_""'-~--'o ".~=.
-
\..
.
~-
...._"'.'
\1
0 0 0
C 0 "'T"1
s: {-
-aO} 1=i1 :n
mrn z
Z::J.) N ~~i~
zc; 00
~.7
kC~i ~-O
~Q ..$. "Y{)
L' ';')rn
S;;c '- .
""
Z w $.
::< Q:) ""
"
~
I