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HomeMy WebLinkAbout03-1226IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN M. VOLOVSKI, PLAINTIFF TERRY L. VOLOVSKI, DEFENDANT No. - /2Z 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 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 the Cumberland County Courthouse. 1 Courthouse Square, Carlisle, PA 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 Lawyer Referral Service 2 Liberty Ave. Carlisle, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN M. VOLOVSKI, PLAINTIFF TERRY L. VOLOVSKI, DEFENDANT No. ~ '" 1o2~ CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Kathryn M. Volovski, who currently resides at 1219A Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070, since October 25, 2002. 2. Defendant is Terry L. Volovski, who currently resides at 12 Miramar Street, New Cumberland, Pennsylvania 17070, since late November or early December, 2002. 3. Plaintiff and Defendant have been separated since October 25, 2002. 4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 5. Plaintiff and Defendant were married on July 20, 1984 at District Justice Clement's Office in Camp Hill, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. 9. Plaintiff requests the court to enter a decree of divorce. DATE: John~. Porter, Esquire Attorney for Plaintiff ID No. 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 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 unswom falsification to authorities. DATE: 3 '-/?-0 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN M. VOLOVSKI, PLAINTIFF TERRY L. VOLOVSKI, DEFENDANT No. 03-1226 Civil Term CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, John C. Porter, co-counsel for Kathy Volovski, hereby certify that a copy of the Divorce Complaint in the above captioned case was served upon Defendant, Terry L. Volovski, 12 Miramar Street, New Cumberland, Pennsylvania, 17070, by certified mail on March 20, 2003. Co-Counsel for Plaintiff PA Sup. Ct. ID# 90152 61 W. Louther St. Carlisle, PA 17013 717-249-1177 · Complete items 1, 2, and 3. Also complete item 4 if Restrictecl Delivery is desired, · Pdnt your name and addrees on the reverse so that we can return the .card to you. · Attach this card to the back of the mailpiece, or on the front if space permits, Article Addressed to: 2. Article Number (Transfer from service label) PS Form 3811, August 2001 [] Agent ~' [] Addressee 3. Printed Name) C. Date of Delivery D. Is detiver~/address d~fferent from item 17 [] Yes If YES, enter delivery address below: [] No 3. Service Type "~tified Mail [] Express Mail '[] Registered [] Return Receipt for Memhandiee [] Insured Mail [] C.O.D. []Yes 4. Restricted Delivery? (Extra Fee) 7002 2410 0007 8509 4229 Domestic Return Receipt 102595-02-M-1035 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN M. VOLOVSKI, PLAINTIFF Vo TERRY L. VOLOVSKI, DEFENDANT No. 03-1226 Civil Term CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under § 3310(c) of the Divorce Code was filed on March 19, 2003. 2. The marriage of plaintiff and defendant is irrctrievably broken and ninety 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 without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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 unswom falsification to authorities. Date: ~{S 1 6'~ Kathryn M. Volovski IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHRYN M. VOLOVSKI, PLAINTIFF TERRY L. VOLOVSKI, DEFENDANT No. 03-1226 Civil Term CIVIL ACTION - LAW IN DIVORCEr DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under § 3310(c) of the Divorce Code was filed on March 19, 2003. 2. Defendant was served the Complaint by certified mail on March 20, 2003 and on or about March 21, 2003 Defendant signed for the certified mail. 3. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. I consent to the entry of a final decree in divc,rce without notice. 5. I have been advised that it might be in my be:st interest to retain legal counsel in this matter. 6. 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. 7. 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. 8. I have been advised of the availability of m~fiage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to ~Ihe penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: ~/~//) ~ Kathryn M. Volovski, Plaintiff VS. Terry L. Volovski, Plaintiff IN 'THE COURT OF COMMON PLEAS CUMI3ERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 03-1226 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: Complaint filed 3-[9-03 and served on Terry L. Volovski by certified mail. 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 8-5-03 ; by delendant 8-9-03 (b) (1) Date of execution of the affidavit requ'red 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: 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) Diverce was filed with the Prothonotary: 9- t 0-03 Date defendant's Waiver of Notice in §3301 (c) Diw~rce was filed with the Prothonotary: 9-10-03 Attorney for Plaintiff¥.l~'~."~- IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~. PENNA. KATHRYN M. VOLOVSKI, PLAINTIFF VERSUS TERRY L. VOLOVSKI, -DEFENDANT $0. 03-1226 DECREE IN DIVORCE AND NOW, DECreed THat September / ~ ~ Kathryn M. Volovski 2003 ., IT iS ORDERED AND , PLAINTIFF, AND Terry L. Volovski , DEFENDANT, 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; BY TH E/GOU rT: ATT~T· //~ j.