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Home My WebLink About00-02462 ." ,,' '.', - .-, '" -,~' ''-'" ,. ", -,' '. + -,-~,' ." . .. . . :l; :l; ;f.:l;:l;;f :l;:l;~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . PENNA. STATE OF . Raymond A. Dettinger . . Plaintifli NO. 00-2462 VERSUS . . . . Helen Petrovna Dettinger Defendant . . . . DECREE IN DIVORCE . ~ (?J- eo::t , I: 3 a A.,+1. dvtn , IT IS ORDERED AND . . . AND NOW, DECREED THAT Raymond A. Dettinger , PLAINTIFF, . . . Helen Petrovna Dettinger , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . ATTEST: . eYT~ ~~~OTHONOTA'~ . . . . . . . . .. .. .. ,''''':I'; ~if. if. if. if. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . ..~ RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL TERM 00-2462 HELEN PETROVNA DETTINGER fIkIa Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly Transmit the Record, together with the following information, to the court for entry of a divorce decree: I. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: April 20, 2000 by certified mail. 3. Date of execution of the Affidavit of Consent: by Plaintiff (7/27/00) ; by Defendant (7/21/2000). 4. Date of execution of the Consent Waiver: By Plaintiff (11/20/00); by Defendant (11/20/00) 5. Related claims pending: None ~ 12 W-- Craig R. Shagin, Esq. PA ill # 32956 Shagin & Anstine LLC 100 Pine Street, Suite 510 Harrisburg, Pennsylvania 17101 Telephone: (717) 221-1111 Facsimile: (717) 221-1110 Attorney for Plaintiff -',^,-""-'-"'--,- "-~t'lIj~l"~l.iilll'hlilil_iIlllill!llH:im~~~!/JlI~.....'i\l!;~"""".L:i~ lV"" '""~"""- , .. ," ,~, ~ " "-,- -,' -"- . ~, '"-il,llli"~~_ ~= . ~ ". , ~~=,,~~ i?'" I ,! i: !'j I! l I, I ", 1,: I I 'i :1 I "I ,. ;1 i,1 fi Fi Ii i (") Cl ~ C c:> s: 0 .-~ 2~ r"'I ~~~\ F! n I ~'QP4 ZC "','-J" ",1 < 'r Q:l""~ :=';-0 =<..c" "::ijjj (;20 "'U -;Jl: 6:11 ~o '---.0 -0 N ~rn )>c .. ~ ~ ;.n ?is c.n '< .. ~ -, '" ~ .- . RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL TERM 00 - ,;J.4t..;2.., Ciu~lT~ HELEN PETROVNA DETTINGER f/k/a Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DNORCE NOTICE 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 at the Cumberland County Court House, High and Hanover Street, Carlisle. 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. Court Administrator Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 \ -"?~ ~Dory L. ater Attorney for Plaintiff #~- , RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL TERM HELEN PETROVNA DETTINGER t7k!a fLo. ()O ~ .Nt..2- Cwu. ILtAf- Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301( d) OF THE DIVORCE CODE 1. Plaintiff is Raymond A. Dettinger, who currently resides at 7073 Carlisle Pike #210, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Olena Petrovna Dettinger, who currently resides at 10101 N ortheast Ave, Apt H-8 Philadelphia, P A 19116 Philadelphia County, Pennsylvania since March 12, 2000. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 17, 1998, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests This Honorable Court to enter a decree in divorce. _w , , 1-., COUNT IT 8. The allegations in paragraphs one through seven, inclusive, are made a part hereof and incorporated herein by reference. 9. The Plaintiff alleges that in violation of her marriage vows, the Defendant has over a period, in Cumberland County, and other places offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. 10. This action in divorce is not collusive. 11. Neither party to this action is a member of the armed forces of the United States of America. WHEREFORE, Plaintiff prays This Honorable Court to enter a decree of divorce, Respectfully submitted, SHAGIN & ANSTINE LLC '-l-~ ~~~ Dory L. sa~q, PA ID# 83783 100 Pine Street, Suite 510 Harrisburg, PA 17101 717-221-1111 Date: Lj//v/oo I / Attorney for Plaintiff "" VERIFICATION I verify that the statements made in this Complaint 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. DATED: t ~ Itfn' 1 ~o ""0 ~oJk~ Raymond A. Dettinger, Plamt Mff{;J/ j, . 1 ~ """"'u RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. /? . .1 -; ~ CIVIL TERM tv - J. r;~;;L ~ HELEN PETROVNA DETTINGER f/kla Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE AFFIDAVIT I, Ravmond A. Dettinger, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors III 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 counselling prior toa divorce decree being handed down by the court. 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. Dated: l~ At',..;, :lODO ~ {).tW( ~ Raymond A. Dettinger ~~'iItilG!Ild~HN~~W'~'~""; z:JJ.i'i/ll;iliWj~""'- .- ~ ~-.~- " ~- "Q. -.. ..,( Crth & 8 C1) ,C)., ;rh ("'~ J u~~ PJ D -..J --,,,> " o/>'"-="_~~" w__, ,_ ,_" ,.. ,~'"' , . " ~ '" . o c <" ~~- ~ .' !~ -< - ,-"- ~..__~~'J' ._ ~, , . .. 'II 'I !I I i -l':;:;; C) 'J ~Tl ......'..;-(8..~.'.' .,..,. '.~c'} ol...J ~~~;.~ _ -;-n :)0 ,-',-", .~"'--' ::-;.::,; :0 -< """ -v :;::,J ,.0 -'"'0 -~ r;} ~J'I (~ ., - - "'^"" " RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL TERM 00-2462 HELEN PETROVNA DETTINGER t7kJa Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE AI<'FIDA VI'f OF CONSENT (1) A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 19,2000. (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (3) I consent to the entry of a final decree of divorce. (4) I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted, I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subjectto the penalties of 18 Pa, C.S. Section 4904, relating to unsworn falsification to authorities. DATED: :;; 7 JoLt (looo ~4~~ Ra ond A. Dettmger, Plamtlff fliiii~_~ij~~~lIl1I~~~<>M*AJ,~"';811~~ ~-~" , ,^ , -~ ~, ~'. .~ ,~ . ."- ~._~~- '. - 0 0 0 c 0 -1'1 ~ :<>0 ::::! -ot,t:I c: ':~;@ rnm G) Z::n ZC 0' (j) .,}..~" ,<"". .:jo~) ~C:, --0 )~~ +\ "J>C :3: Z'" '4 C) 0 ry ~~ln >c ~ 'J'l 55 N -< -~^" "...." 11 ['I II ,I H II - ~. "","- .., .._~,~o~-_'_ - ", RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL TERM 00-2462 HELEN PETROVNA DETTINGER fIkIa Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SECTION 330HC) OF THE DIVORCE CODE I. I consent to the entry 9f a [mal decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DATE R D-N 0<1 ,do'''' ~cJA~ Raymond A. Dettinger, Plaintiff ~~~iliIi~im!lfil.""i:ilili,",,,"iS~-'o,,,,,,,,,,,'id"ljW.PJIWi!i0M$li;~tilli~""'_.i',~''d&'''' ~-~ .- ~'~'~~_3iiii!l~~- "".:~ai ~ " o c: :5;: ;:gO;; ..,.Dc ~~.., Zf!:/ CD::!:. ::<: '. ,-,<- ~-CJ' ~Q >'-' f =< - ""' <.:> ::;r ~ '-'1 .;:- -1-' f '! Cl Cl o '-" C") I <J? o -'0 ~j i';'~-=D r-' ;gE9 ~~~! i~ Ci :rJ $,0 <sm s;! :0 ""'" .~ ""' " ~ ~~ ' -- \~ RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL TERM 00-2462 HELEN PETROVNA DETTINGER f7k/a Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE AFF'IDAVI'l' OI<' CONSEN'i' TO DIVORCE (1) A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 19,2000. (2) Defendant acknowledges that service of the Complaint was made by certified mail on April 20, 2000. (3) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date offiling the Complaint. (4) I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (5) I consent to the entry of a final decree of divorce. (6) I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. (7) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. Being so advised, I do not request that the Court require that my spouse and I participate in counselling .- .. - .---" """ prior to a divorce decree being handed down by the Court. I verifY that the statements made in this affidavit 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. DATED: 7~ 2/~2()rflO ~{l dJitthJ0-- Helen Petrovna Dettinger, Defendant ~~J.""""'~~~lM1l@jifillUl~" ~" t.lSi!iliIt:l;;i;~~'Ml~&'il~ ,,~.: -.;,.~",,",," "-'~>'~~IU .-- - -L (") 0 0 c: c::> ., < J:>o ""I -0 OJ 111rn ".- ~_C 7.-~' G") !Tj~ """'- _'.J Z\, :g2j (J)...,-' 0'> -<:;:"- ~j(-:) kCJ ::t:l r"' -rl 'J> ._ ,";:"-:U Z).--: --3... ..-}~") )>;::: r:-;> ;5S1il 2'~ ~'-t ~ ':.n )> N ::rJ -< 1 ~" ~ Ii f ~ i I. o ~".c~~"'" __ . ~ . ~ ~ -'\~- RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. CIVIL TERM 00-2462 HELEN PETROVNA DETTINGER f/k/a Helen Petrovna Kuzinets and Olena Petrovna Kuzinets, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary . I verify that the statements made in this affidavit 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. DATE 1/ /2~ /flO L l1Jlt.~ Helen Petrovna Dettinger, Defendant 1.Jj!!llll9i~l~~jj~~~'I~I.~~.d1_",",~jiJtJi""~~H"'''~--,,'lJ~~.~-W".;~'--n~~~lifML_~iir-'~~- ~-^" --^ , ,,-, '~_~~iil.' ~='-iIIIr.lllliill"~ ~,,--....., 2 <::) 0 0 -n s: 0 ~=-.!- "'Ow ,.,., -~-~,-\ ~f 52m " ze' I -ot121 '..I. ~_;:-:it,._) ~:2: -~~~i kO -0 ~g 3: ~~;-~ r-:: (51'n --i Z Ul "r-? =< ::0 .r:- -< 'h s;;: I I . "~ - ~., -- -', , ''''OJ''!; . RAYMOND A. DETTINGER, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL TERM 00-2462 HELEN PETROVNA DETTINGER flk/a Helen Petrovna Kuzinets and 01ena Petrovna Kuzinets, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL AND NOW, this 17th day of November, 2000, I Craig Shagin, attorney for Plaintiff, hereby certify that a true. and correct copy of the Notice to Defend and Claim Rights and Complaint for Divorce was served upon the Defendant, Helen Petrovna Dettinger by certified mail to following address: 10101 Northeast Ave. Apt H-8 Philadelphia, PA 19116 ~ Y2/~ Craig R. Shagin, Esq. PA ill # 32956 Shagin & Anstine LLC 100 Pine Street, Suite 510 Harrisburg, Pennsylvania 17101 Telephone: (717) 221-1111 Facsimile: (717) 221-1110 Attorney for Plaintiff ~~~"~~'l~ ~"~=, .__ ".~<~,o _". " ,^'- ~ ~. Iaf !u..Illlil~!l'll~~~~ ~ - ."'~. ..........;,..~",. . ~ '-", " ~~ ., " Iti:'ii \1 .1 I, II i! I: , , II Ii Ii l I I I I J I Ii Ii " () Cl ~ c: 0 "'U~ g "7' !pm ::n " r'~i~ z~ f./),," C.11 --om O<.c. ~C)O ~o f~J.. -0 "'>>1(.) j8 :x :]:~ Qo ~ +.. ~ om ,en ?& ..,.. -<