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Home My WebLink About07-0751Francis A. Zulli, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 Phone: (717) 232-1488 Email: wzs@mindspring.com ELIZABETH ANN BILOUS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA vs. NO. JEFFREY ROBERT BILOUS, Defendant CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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 Lawyer's Referral Service 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 4. Francis A. Zulli, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 Phone: 717-232-1488 Email: wzs@mindspring.com ELIZABETH ANN BILOUS, Plaintiff vs. JEFFREY ROBERT BILOUS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 0'7- YS'l CIVIL ACTION - IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) 1. The Plaintiff is Elizabeth Ann Bilous, an adult individual, who currently resides at 612 S. York Road, Dillsburg, York County, Pennsylvania 17019. 2. The Defendant is Jeffrey Robert Bilous, an adult individual, who currently resides at 212 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant were married on April 1, 2006, in Mechanicsburg, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. Plaintiff and Defendant have no minor children of this marriage. I 4k 6. There has been no prior actions of divorce or for annulment between the parties. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Plaintiff is not a member of the Armed Services of the United States or any of its allies. 10. The Defendant is a member of the Armed Services of the United States being in the United States Air Force. 11. 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; however, the Plaintiff waives her right to counseling. 12. Plaintiff avers that the grounds on which the action is based are: (A) That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce. Respectfully submitted, WION, ZULLI & SEIBERT: BY: v is A. Zulli, Esq 016 me Court No. 109 ocust Street . Box 1121 Harrisburg, PA 17108 (717) 232-1488 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce Under Section 3301(c) 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: February 0- , 2007 . Elizabeth Ann ous O c ? CID 9 -1 Francis A. Zulli, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 Phone: 717-232-1488 Email: wzs@mindspring.com ELIZABETH ANN BILOUS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA vs. : NO. 07-751 CIVIL TERM JEFFREY ROBERT BILOUS, Defendant CIVIL ACTION -IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, Francis A. Zulli, Esquire, being duly sworn according to law, depose and say that on February 12, 2007, I personally handed a certified copy of the Complaint in Divorce filed in the above-captioned action to Jeffrey Robert Bilous at 109 Locust Street, Harrisburg, Pennsylvania. The said Jeffrey Robert Bilous, Defendant, signed an Acceptance of Service, which is attached Sworn and subscribed to before me this 13t' day of Februa , 2007. ,4M WEAt_ ,'H 03, 11 AN NSYCJA NOTARIAL SEAL. ANN J. LONG Notary Public City of Harrisburg, Dauphin County Commission ExPir s 7rtnt?r'r 31, .2 Francis A. Zulli, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 Phone: 717-232-1488 Email: wzs@mindspring.com ELIZABETH ANN BILOUS, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. JEFFREY ROBERT BILOUS, Defendant : CIVIL ACTION -IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce under Section 3301(c) of the Divorce Code this J_T?ay of February, 2007. Date: cb a CQ7 ey Robert Bilous, Defendant 212 Deerfield Road Camp Hill, PA 17011 C} o O 0 -rr rri IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. 2001-7151 _ IN DIVORCE I2, ? + ?crUS Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] X prior to the entry of a Final Decree in Divorce, .. or _ after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of Cu&J,7 tih ,4nvq aftd gives this written notice avowing his / her intention p 7?z of 4 Date: 511te 101 uov, Signature i e of name being s d COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF Cumbparbnot ) On the IV day of Ma.v , 200, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Q Prothonotary or Not 9y Public Pun [c): IWSL "BOUNb ? j ry MAL ? w o"S" E ,WNMpYa Inuuat p Ur, - AM zz- Francis A. Znlll, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 (717) 232-1488 fazalH.wzs@mindspring.com Attorney for Plaintiff ELIZABETH ANN BILOUS, Plaintiff VS. JEFFREY ROBERT BILUUS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2007-00751 CIVIL ACTION -IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 8, 2007. 2.. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. 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. 4 :. r .i ? ^.,,,r,_.r,a904 gwa:.iu ieflating t:, unswot' r? ?alsifcat'un to auurorities. Dated: December _;?6, 2007 Je ' ilous i,...' 'f ?? ?' ,._1 <. ...t ?w`i .i .. •tih _r?-t ^ ?„ Francis A. Zuni, Esquire W10N, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 (717)232-1488 fazullLwzs®mindspring.com Attorney for Plaintiff ELIZABETH ANN BILOUS, Plaintiff VS. JEFFREY I OBERi B iLDUS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNT', PA NO. 2007-00751 CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) & 3301(d) 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 I 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. 1 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: December al, 2007 J rt I ous, efendant ??, .. ?? =; {? ? .? ??. ?.?? ` =i ?,?_ :. ?.n Francis A. Zulli, Esquire WION, ZULLI & SEIBERT 109 Locust Street Harrisburg, PA 17101 (717) 232-1488 fazulli.wzs@mindspring.com Attorney for Plaintiff ELIZABETH ANN BILOUS, Plaintiff VS. JEFFREY ROBERT BILOUS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 2007-00751 : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was fl 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. 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: Jamiary-949 20078 6EfJi1;e'th Ann B1 ouS .. ?a ., E? 'J'4 S ?:: ?? ?': ? .? v°? tom. t... {r:: ..- __?.n { i ti.? ? C?'? Francis A. Zulli, Esquire WION, ZULLI & SEBERT 109 Locust Street Harrisburg, PA 17101 (717) 232-1488 fazulli.wzs@mindspring.com Attorney for Plaintiff ELIZABETH ANN BILOUS, Plaintiff VS. JEFFREY ROBERT BILOUS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 2007-00751 : CIVIL ACTION -IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) & 3301(d) 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 I 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. 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: January 24 , 20018 Zbe Ann &Mis"., alntiff s? ?? P ?'? ;3?_ ,.?? 6?T?. ? ^- I i ? ? _... , j'I ELIZABETH ANN' BILOUS, Plaintiff vs. JEFFREY ROBERT BILOUS, IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 2007-00751 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 3301 (c) (Strike out inapplicable section) 2. Date and manner of service of the complaint: Personal Service. See Affidavit of SPrviCe dated February 13, 2007 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiff January 24, 200 by defendant December 28, 2007 b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: January 25, 2008 Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. No. 20o?7 -- 007S- VERSUS DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT PLAINTIFF, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; 4/0-