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PO. Box 5320. HARRISBURG. PtNNSYLV..N1A 17110,532.0
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CERTIFIED TRUE
AND CORoRECT COpy
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
JOHN F. GARANCHESKI,
v.
NO. (17 - 5 q L{3 t.i,...:fT.//l-lV-
VOLQUITA NOVAS,
Defendant.
CIVIL ACTION--LAW IN DIVORCE
NOTICE TO 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 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 County Courthouse, ,
Pennsylvania.
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 REFERRAL SERVICE
Court Administrator's Office
Cumberland County Courthouse, 4th Floor
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
(717) 240-6200
JOHN F. GARANCHESKI,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
NO. 91- 5"'/'13 Ct;..J (.J1..I"'--
VOLQUITA NOVAS,
Defendant.
CIVIL ACTION--LAW IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I
DIVORCE UNDER SECTION 330l/CI OF THE DIVORCE CODE
I. Plaintiff is John F. Garancheski, who currently resides at
768 Burnt House Road, Carlisle, Cumberland County, pennsylvania.
2. Defendant is Volquita Novas, who currently resides at 3502
Vermeer Drive, Virginia Beach, Virginia.
3. Plaintiff has been a bona fide resident in the Commonwealth
for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on September 21,
1996 in Virginia Beach, Virginia.
5. There have been no prior actions of divorce or for annulment
between the Parties.
6. The marriage is irretrievably broken.
7. Neither Party is a member of the Armed Forces of the United
States or any of its allies.
8. The Plaintiff has been advised of the availability of
counseling and that either party may compel the other by Order of
Court to attend counseling sessions.
9. Plaintiff avers that there are no children to the Parties
under the age of 18.
WHEREFORE, Plaintiff respectfully requests that your Honorable
Court enter a Decree in Divorce under Section 3301(c) of the Divorce
Code.
Respectfully submitted,
B ~~A1L~ O'
G~rald S. R~bi~n~re
Attorney 1.0. No. 27423
ROBINSON AND GERALDO
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney for Plaintiff.
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