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HomeMy WebLinkAbout03-0997GARY GEORGE VASSIL, Plaintiff VS. DENISE ELAINE VASSIL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003- ctq'7' CIVIL ACTION - LAW 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 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 GARY GEORGE VASSIL, Plaintiff VS. DENISE ELAINE VASSIL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003- q~ CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Gary George Vassil, an adult individual whose mailing address is 506 Boston Court, Mechanicsburg, Cumberland County, Pennsylvania 17050, and whose social security number is 384-50-9926. The Defendant, Denise Elaine Vassil, is an adult individual, whose current address is 439 North Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043, and whose social security number is unknown. 3. Plaintiff and Defendant were married on May 18, 1994, in Baltimore, Maryland. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. o Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children bom of the marriage. 10. Plaintiff avers that the grounds on which (a) That the marriage is irretrievably broken. this action is based are: WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: March 4, 2003 VERIFICATION I verify that the statements made in this Complaint in Divorce are tree 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: March 4, 2003 GARY GEORGE VASSIL, Plaintiff VS. DENISE ELAINE VASSIL, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003 - 00997 CIVIL ACTION - LAW IN DIVORCE AI~'FIDA¥1T OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 6, 2003. 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 in Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final Decree in Divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 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 Waiver are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Denise Elaine Vassil, De?e~dant GARY GEORGE VASSIL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 2003 - 00997 DENISE ELAINE VASSIL, Defendant CIVIL ACTION - LAW iN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 6, 2003. 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 in Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A 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 ifi do not claim them before a divorce is g,~anted. 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 Waiver are true mid correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. {}4904 relating to unswom falsification to authorities. G~t~ Geor~t~ Qhlil, Pl~tiff GARY GEORGE VASSIL, Plaintiff VS. DENISE ELAINE VASSIL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003 - 00997 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 6, 2003. 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 in Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry ora final 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 clai~n them before a divorce ia 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 Waiver 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.~/'/~ / ~/~ .v~ Geort& 'thrill, Pl tiff GARY GEORGE VASSIL, Plaintiff VS. DENISE ELAINE VASSIL, Defendant IN THE COURT ,OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2003 - 00997 CIVIL ACTION -LAW IN DIVORCE 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: Irretrievably broken under Section (X) 3301(c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By certified mail on March 28, 2003. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of ,Consent required by Section 3301(c) of the Divorce Code by Plaintiff, August 20, 2003; by Defendant, July 18, 2003. (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A; Date of service of Plaintiff's affidavit upon Defendant: N/A. 4. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: N/A; 5. Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff.' Simultaneously herewith; by Defendant: Copy enclosed, filed on August 14, 2003. 6. Related Claims Pending: None 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 Attorney for (x) Plaintiff ( ) Defendant IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF PlaSntiff Versus DENIg~ ~T,AT~E vaggtT,: Defendant PeN NA. NO. 2003-00997 DECREE IN DIVORCE ANd NOW, DECREED THAT CARY CR~RC~ VARRTT. ~= , IT IS ORDERED AND , PLAINtiff, AND DENISE ELAINE VASSIL , DEFENDANt, ARE DIVORCEd FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JUR}SD[CTION OF THE FOL. LOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD iN ThiS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURT: PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : Vs : File No. : Defendant : IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/defendant in [he above matter, [select one l~y marking '~"] prior to the entry of a Final Decree in Divorce, or .~f after the entry of a Final Decree in Divorce dated ~-,~ z_ 0 3' , hereby elects to resume the prior surname of //2ti× ~ ,~ , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Signature 'gn e~-n~resumed COMMONWE,~LTH OF PENNSYLVANIA ) COUNTY OF On the ~4~ day of ~) (~ ;[Oka,~ ~ ,20(~z, 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 Wimess Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary Public NOTARIAL SEAL CLAUDIA A. BREWBAKER, NOTARY PUBLIC Carlisle Bore. Cumberland County My Commission Expires April 4, 2005