HomeMy WebLinkAbout00-00281JUDITH ANN YABLINSKY,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2000 - -ZPI CIVIL TERM
JOHN PATRICK YABLINSKY,
Defendant
IN DIVORCE
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 in 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, 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
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduling conference or hearing.
JUDITH ANN YABLINSKY,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2000 - -? 81 CIVIL TERM
JOHN PATRICK YABLINSKY,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT
TO SECTIONS 3301(c) AND 3301(a)(6)
OF THE DIVORCE CODE
NOW comes the plaintiff, Judith Ann Yablinsky, by her attorney, Marcus A. McKnight,
III, Esquire, and files this complaint in divorce against the defendant, John Patrick Yablinsky,
representing as follows:
1. The plaintiff is Judith Ann Yablinsky, an adult individual residing at 236 Senior
Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
2. The defendant is John Patrick Yablinsky, an adult individual residing at 102 Baker-
Russell Drive, Shippensburg, Cumberland County, Pennsylvania 17257.
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on January 27, 1975 in Winchester,
Virginia and separated on or about December 4, 1999.
5. There were no children born to this marriage.
6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken.
7. There have been no prior actions of divorce or for annulment between the parties.
8. Pursuant to the Divorce Code, Section 3301(a)(6), the plaintiff avers as the grounds
upon which this action is based that the plaintiff is the injured spouse and that the defendant has
offered such indignities to her as to render her condition intolerable and life burdensome.
9. The plaintiff avers that she has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment
a. Dissolving the marriage between the two parties;
b. Equitably distributing all property, both personal and real,
owned by the parties; and
c. for such further relief as your Honorable Court may deem
equitable and just.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Attorney forIn
Judith Ann
Esquire
West Pomfret Professional ]Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 25476
Date: January 14 , 2000
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unworn falsification to authorities.
Date: January iNP? , 2000
JUDITH ANN YABLINSKY,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2000- CIVIL TERM
JOHN PATRICK YABLINSKY,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, 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 Prothonotary's
Office, 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: January , 2000
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JUDITH ANN YABLINSKY,
Plaintiff
V.
JOHN PATRICK YABLINSKY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2000-281 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I, John Patrick Yablinsky, the defendant in the above-captioned divorce action, hereby
verify that I accepted service of the Divorce Complaint filed under Sections 3301(c) and
3301(a)(6) of the Divorce Code on January 14, 2000. Said complaint was filed on January 14,
2000.
U JOHN PAT CK YABLINSKY
Date: January 14, 2000
iD
(.1
JUDITH ANN YABLINSKY,
Plaintiff/Petitioner
V.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2000 - 281 CIVIL TERM
JOHN PATRICK YABLINSKY,
Defendant/Respondent IN DIVORCE
PETITION FOR ECONOMIC RELIEF
AND NOW, this 12th day of July 2001, comes the plaintiff/petitioner, Judith Ann
Yablinsky, by her attorneys, IRWIN, McKNIGHT & HUGHES, and makes the following
Petition for Economic Relief against the defendant/respondent, John Patrick Yablinsky, as
follows:
1.
The petitioner is Judith Ann Yablinsky and is the plaintiff in a divorce action filed at
2000-281 in Cumberland County, Pennsylvania. Her address is 236 Senior Drive, Shippensburg,
Cumberland County, Pennsylvania 17257.
2.
The respondent is John Patrick Yablinsky, and is the defendant in this divorce action. His
address is P. O. Box 135, West Campbell Street, c/o Charles Yablinsky, Carrolltown, Cambria
County, Pennsylvania 15722.
3.
The petitioner seeks the following relief from the Court:
a. Alimony Pendente Lite;
C. Costs and expenses; and
d. Counsel fees.
WHEREFORE, the petitioner, Judith Ann Yablinsky, requests the relief set forth above.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
Marcus
Carlisle, PA 17013
717-249-2353
Supreme Court I.D. No: 25476
Attorney for the plaintiff/petitioner,
Judith Ann Yablinsky
Date: July 12, 2001
2
60 West Pomfret Street
VERIFICATION
The foregoing Petition for Economic Relief is based upon information which has been
gathered by counsel and myself in the preparation of this action. I have read the statements made
in this document and they are true and correct to the best of my knowledge, information and
belief. I understand that false statements herein made are subject to the penalties of 18 Pa.
C.S.A. Section 4904, relating to unworn falsification to authorities.
Date: July 12, 2001
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In The Court of Common Pleas of
Cumberland County, Pennsylvania
File No. 2000-00281
YABLINSKY JUDITH ANN
vs
YABLINSKY JOHN PATRICK
STATEMENT OF INTENTION TO PROCEED
To the Court:
JUDITH ANN YABLINSKY
Date: October 25, 2004
intends to proceed with the above captioned matter.
lgr--
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MARCUS A McKNIGHT-Ti-I-' SQ
IRWIN & McKNIGHT
60 WEST POMFRET STREET
CARLISLE PA 17013
i N CD
c 7 -tl
-i rr3
Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
no - 2 8 ( CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573