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Home My WebLink About00-01731 ._ ,,f CORINE C. NICEWICZ Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- /13 J CIVIL I~ CHRISTOPHER NICEWICZ: Defendant : IN DIVORCE NO'T'TI'.R 'T'() nl<'.l<'RND AND CT.A TM lHG-H'T'8 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 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 the Prothonotary, Cumberlan.d County Courthouse, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAlM 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, PA 17013 TELEPHONE: 717-249-3166 .~ .. '- CORINE C. NICEWICZ Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- J731 CIVIL I.t..-.- CHRISTOPHER NICEWICZ: Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE Count I - Divorce 1. Plaintiff is CORINE C. NICEWICZ, who resides at 1421 Pheasant Drive S., Carlisle, Cumberland Coun.ty, Pennsylvania 17013. 2. Defendant is CHRISTOPHER NICEWICZ, who resides at 1421 Pheasant Drive S., Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the fuing of this Complaint. 4. The Plaintiff and Defendant were married on August 29, 1989. 5. There haye been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 6. Neither party to this action in divorce is currently a member of the Armed Forces ofthe United States of America. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage between the parties hereto is irretrievably broken. ~ 9. Plaintiff requests the Court to enter a decree of divorce. Count II - Custody 10. The averments set forth above are hereby incorporated by reference. 11. Plaintiff seeks primary physical custody ofthe children ofthe parties: A. SEBASTIAN NICEWICZ, age 6, Date of Birth: 3/29/93. B. THOMAS NICEWICZ, age 2, Date of Birth: 9/18/97. The children were not born out of wedlock. The children are presently in the physical custody of plaintiff and defendant. During the past five years, the children have resided with the plaintiff and defendant at 1421 Pheasant Drive S., Carlisle, Cumberland County, Pennsylvania. The mother ofthe children is Corine C. Nicewicz, the plaintiff herein. The father of the children is Christopher Nicewicz, the defendant herein. 12. The relationship of plaintiff to the children is that of biological mother. 13. The relationship of defendant to the children is that of biological father. 14. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of any custody proceeding concerning the children pending in any other court. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to either of the children. 15. The best interests and permanent welfare of the children will be served by granting the plaintiff custody of the children because she is best able to care for them and to provide them with a loving environment. WHEREFORE, Plaintiff requests ofthis Honorable Court that it: a. Grant her a decree of divorce, divorcing the parties; . b. Grant her custody ofthe two minor children; and c. Grant such other relief as may be just and proper under the circumstances. Respectfully submitted, .~ BY: Samuel W. Milkes JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 (717) 249-8427 - Fax Attorney No. 30130 VERIFICATION I hereby verify that the statements made in the foregoing 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. Dated0 f( l'D::> ~-L?IU~ ~ ORIN~b. NICEWIC~ ~. (") c s: -oe- m,.,": ~?J c:);,;; ;::;;-- . -,..-, .,...~- ::P z:0 pO c z: -< -< . " o o o -.., -~ ;:,. = "" N -0 :::E: ~ :,J :.,,:0 .- -"m ....,6 86 :r.:=i-t o-~ --,e"') om s;! :::0 -< ~ c" ~ ~ ~ \l.,' ....... "<J ~\ " d c ~ v- . ~ ~ c-- (j r~ ~ t:.~ ~ f't --t>ll\ t "" -J :k' Lt f. tr \ , t - ~ r v. IN THE COURT OFCOMlVION PLEAS CUMBERLAND COUNTY,PENNSYLV ANIA NO. 2000- /731 CIVIL CORINE C. NICEWICZ Plaintiff CHRISTOPHER NICEWICZ: Defendant : IN DIVORCE r,RRTTFU,AT"R OF RRRVTr,R I, Shelley Eichelberger, hereby certify that a true and correct copy of a Notice To Defend Rights and Claim Rights and a true and correct copy of a Complaint In Divorce Under Section 3301(c), was duly served for the Defendant, Christopher Nicewicz, by a registered letter deposited in the U.S. Mail on March 22, 2000, addressed as follows: Christopher Nicewicz 1421 Pheasant Drive South Carlisle, P A 17013 And further that this attached card demonstrates that on March 23, 2000, the Defendant was served I hereby verify that the statements made in the foregoing 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: 3(Jg!DO ~~ f(~j~<< SHELLEY CHELBERGE ",-.--. 80 -65 Z 452.}1 .!:, us Postal SelVice Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse Sentto Christo her Ni it4~i NP~asant Dri ~S:s"l'&;&'WACotle17013 postage $ GertffiedFea Spedal Delivery Fee Restricted Delive", Fee- "' '" '" .0.. Relum:R "'" Dala,&A g TOTAL <X> M Postm, E .l: CO Cl. ... SENDER: ~ . Complete Items 1 and/or 2 for additions.! services. Ii . Complete Itams 3, 4a, and 4b. CIIl . Print your name and address on the reverse of this fooo so that we can retUrn this "" card to you. :"a . Attach this fOml to the front of the mallp\Qce, or on tt\0 back {f space does not - pe",," . . Write "Return Receipt Requested" on 1/19 maUplece below the artIde number. ~ . The Return Rooelpt will show to whom the article was delivered and the deW .. delivered. S 3. Article Addressed to: ] Christopher Nicewicz ]! 1421 Pheasant Drive South f Crlis1e, PA 17013 I also wish to receive the following services (for an extra fee): . 1.0 A.ddressee's Address 2.~ Restricted Delivery Consult postmaster for fee. 4a. Article Number Z 452 480 265 4b. Service Type o Registered o Express Mall o Retum ReceIpt for Merchandise 7. Date of Delivery :<.: 5. R~peived By: (Print Name) ;. CII-Rf."SrDp#.E.R !ACLwr-C"( 6. Sign~urel(Addressee or Agent) . ! X ~ Lh A--t~_........ .!! PS Form 3811. December 1994 ,Gertlfled D ~Insured o coo 8. ressee's Address (Only if requested and fee is paid) ,... !il ~' " '" a J c .a " a: '" c 0; " ~ oS " l!. ... c .. t= 102S......B-<l229 Domestic Return Receipt " ~ . (") c:> 0 C c::> -,., g: - .~ ~ -00: :;:- .- fTlrt: :;0 R:..,..:..: Z:D N _,..i\1 :Z:C " CJ 0') .;;~ CJJ ~~ ~Z. ~CJ ;po ::C41 5-:8 :;!: 0- ~o S' Ben )>2 "" w 55 =< c::> '< Co r/n e.. C -N/CEW/CZ. /]Ja~L/rff In the Court of Common Pleas of Cumberland County, Pennsylvania vs. No. Rooo - 1731 Civil. 19 CA nSfOt?hn- /VI Ce:(JJ( C2.. ~~~ /? ~a..de dr/;--f AfTn/t/;'u to dp ~ - .. eaAt? " " To ProthonOlary , . 7Je~ 13 j20,? I 19 ::2 S O~'l 6J.3 Cc.ul<..:.&. C?, A-..)1'cE:tAJ'C.:t. - pt +:.r a~ ~~~l~- PLED-OfF1CE . O~ t:~~r::- 7:;~(J:~~:ONOTARY No. ;<000 - (73 (. . Term, 19 ~ CO'{'I1e.. C. Nlcew/cz. o I DEe 13 PH [,: 02 CUb',SEriLAND COUNTY PENNSYLVANIA Vs. Clir/s!-ojPA..u- NtceiA/1C2... PRAECIPE Filed 19 , Atty. . .' .", ,. >:...... . ,~, .~<!- ,'"":