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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 0 m c c? 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 ? O ? ' ?r ' ? Qy ? r '' ? ? ? ? ( "G f:.7 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-- A 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