The URL can be used to link to this page

Home My WebLink About03-0031 MICHAEL ALAN MILAKOVIC, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION - LAW :IN DIVORCE ;NO. 0,- J/ CIV:/ TERRI M. MILAKOVIC, Defendant 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 of divorce or annulment may be entered against you by the court. A judgment may also be entered against 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: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square 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 A venue Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 MICHAEL ALAN MILAKOVIC, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE :NO. 0 :3 - 0 0.3 I TERRI M. MILAKOVIC, Defendant COMPLAINT AND NOW comes the Plaintiff, Michael Alan Milakovic, who, by and through his attorneys, John Q, Milakovic, Esquire, Elizabeth S. Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which he avers that: 1. Plaintiff, Michael Alan Milakovic, is an adult individual residing at 181 "R" Street, Steelton, Dauphin County, Pennsylvania 17113. 2. Defendant, Terri M, Milakovic, is an adult individual residing at 505 East Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both parties were bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of the original Complaint. 4. Plaintiff and Defendant were married on October 5, 1991. 5. There have been no prior actions in divorce or for annulment between the parties in this or any other jurisdiction. 6, The marriage is irretrievably broken. 7, Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs 1 through 7 of this Complaint are incorporated herein by reference as though set forth in full. 9. Plaintiffs marriage to Defendant is irretrievably broken, 10, Plaintiff has been advised that counseling is available and that he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, pursuant to 23 Pa.C.S.A. gg3301(c) or (d), Plaintiff, Michael Alan Milakovic, respectfully requests the Court to enter a Decree of Divorce. 2 DATED: 112../0] Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 Respectfully submitted, E1~t.a1, i'4~ Elizabeth S. Beckley II Attorneys for Plaintiff 3 VERIFICATION I, Michael Alan Milakovic, hereby verify that I am an adult individual and that the facts set forth in the foregoing pleading are true to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. ~4904, relating to unsworn falsification to authorities, Dated: IlLlo-; ~ --- ,10 v0 ~ ------ ~ ~ ~ ---- "---'\) <:::::5J '-"/ ~ -~ ~ ~, r-- --- ""'" "" ~~~-- Q ,- (, C ~'.'; ~, czY C~, C~I .....J ~-~, ,=' :u -< MICHAEL ~LAN MILAKOVIC, Plaintiff v. I I TERRI M. ~ILAKOVIC, , Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LA'W :IN DIVORCE :NO. 03-31 ACCEPTANCE OF SERVICE I, Tclrri M. Milakovic, hereby accept service of the Divorce Complaint filed in the above-captibned action. I DATED: J 1.03 ~G' ~ TerriM.M~ (Defend.ant) CERTIFICATE OF SERVICE i It is here~y certified that a copy of the foregoing document was this day served upon the ! following perso,s in the manner below indicated. FIRST CLASS MAIL Maria P. Cognetti, Esquire Maria P. Cognetti & Associates 210 Grandview Avenue Suite 102 Camp Hill, PA 17011 Dated: 1/2--0/ OJ I ~:I~OViC MICHAEL ALAN MILAKOVIC, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION - LAW :IN DIVORCE TERRI M. MILAKOVIC, Defendant :NO. 03-31 PRAECIPE FOR DISCONTINUANCE TO THE PROTHONOTARY: Please mark the above-captioned matter discontinued. Dated: 7//2..-( U) - Respectfully submitted, Of Counsel ------ Beckley & Madden 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233-7691 ?'~~A "LvJ, j. A~ IrkJ ~ Beckley Attorneys for Plaintiff CERTIFICATE OF SERVICE It is hereby certified that a copy of the foregoing document was this day served upon the following persons in the manner below indicated. FIRST CLASS MAIL Maria P. Cognetti, Esquire Maria P. Cognetti & Associates 210 Grandview Avenue Suite 102 Camp Hill, PA 17011 Dated: 7/11.-(0:'- -""'.:) ~~'-" r,}f~ o c ,...> "'" ~ U' <- C r'-" ~y - c,.,) -0 -- -"-..... t;';? r" !';,,', ' ",,;:\. <p.. (~,:-. :'j ~~ ..-\ ~f9. ,.-n -re: ~'~\~). .,,"' ~\i)~f; ~A ~~ - t.f\ .p -