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HomeMy WebLinkAbout03-1743TRISHA J. BORSUK, RONALD A. BORSUK, JR., Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O.~ - 17~ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Ronald A. Borsuk, Jr. 501 Steelstown Road Newville, PA 17241 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. When the ground for 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 Cumberland County Courthouse, One Courthouse Square, Carlisle, 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #: 266256.1 TRISHA J. BORSUK, RONALD A. BORSUK, JR., Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW - 17q.3 IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff, Trisha J. Borsuk, is an adult individual currently residing at 501 Steelstown Road, Newville, Cumberland County, Pennsylvania, 17241. 2. The Defendant, Ronald A. Borsuk, Jr., is an adult individual currently residing at 501 Steelstown Road, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on August ! 9, 2000, in Monroe County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security Number is 177-60-9496 and Defendant's Social Security Number is 176-62-3436. 7. There have been no prior actions of divorce or for annulment between the parties. 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. Document It.. 266256.1 VERIFICATION I, Trisha J. Borsuk, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Trisha J. Borsu~: Document #: 266256.1 TRISHA J. BORSUK, Plaintiff · RONALD A. BORSUK, JR., · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff, Trisha J. Borsuk, in the above captioned action, hereby certify that a tree and correct copy of the Complaint in Divorce was served upon Defendant, Ronald A. Borsuk, Jr., in person on April 21, 2003. Attached hereto, marked as Exhibit "A", and incorporated herein by reference is the Acceptance of Service signed by Ronald A. Borsuk, Jr. for said service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: ~'.... ~.~-x~ By. An~re~C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for PlaimSff 280428-1 TRISHA J. BORSUK, Vo RONALD A. BORSUK, JR., Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE ACCEPTANCE OF SERVICE i, Ronald A. Borsuk, Jr., Defendant, hereby certify that 1 accept service of the Complaint in Divorce this ~. I day of ~C) r- ~ 2003. Ronald A. Bor~'uk, Jr. ~ -" Document #.. 267354.1 TRISHA J. BORSUK, Plaintiff V. RONALD A. BORSUK, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-- 7S'3 1N DIVORCE AFFIDAVIT OF CONSENT 1. An Amended Complaint in Divorce under §§ 3301(c) and (d) of the Divorce Code was filed on April 6, 2003 and served upon Defendant on April 14, 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 of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are tree and correct. I understand that any false statemems herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unswom falsification to authorities. Dated: Trisha J. Borha~tk 285550-1 TRISHA J. BORSUK, Plaintiff V. RONALD A. BORSUK, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ,, IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce xvithout notice. 2. I understand that I may lose fights conceming alimony, division of property, lawyer's fees or expenses ill 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: Trisha J. Borsuk C) 285550-1 TRISHA J. BORSUK, : Plaintiff : RONALD A. BORSUK, JR., : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~0~- Iqt~ IN DIVORCE AFFIDAVIT OF CONSENT 1. An Amended Complaim in Divorce under §§ 3301(c) and (d) of the Divorce Code was filed on April 6, 2003 and served upon Defendant on April 1.4, 2003. 2. The marriage of Plaintiffand 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 any false statements herein are made subject to the penalties of 18 Pa.C.S., § 4904, relating to unsworn falsification to authorities. Dated: ~/Iq/ O~, Ronald A. Borsuk, irt. / ' 285550-1 TRISHA J. BORSUK, Plaintiff V. RONALD A. BORSUK, JR., Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW NO. os- IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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 divoree 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Dated: Ronald A. Borsuk, Jr. 285550-1 TRISHA J. BORSUK, : Plaintiff : : V. : RONALD A. BORSUK, JR., : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-1743 CWIL TERM 1N DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry ora Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and manner of service of Complaint: A Complaint in Divorce was filed on April 16, 2003, and served on Defendant on April 21, 2003, in person. An Affidavit of Service and Acceptance of Service was filed on May 7, 2003. Complete either paragraph (a) or (b): (a) Date of execution of PlaintiWs and Defendant's Affidavits of Consent required by Section 3301 (c) of the Divorce Code: Plaintiff: September 13, 2003, filed September 16, 2003 Defendant: September 19, 2003, filed September 24, 2003 (b)(1) Date of execution of PlaintiWs Affidavit required by Section 3301(d) of the Divorce Code: NA (2) Date of filing and service of the Plaintiff's Affidavit upon the respondent: Filing: NA Service: NA 4. Complete the appropriate paragraphs: 289821 5. (a) (b) Related claims pending: None Claims withdrawn: None Claims settled by agreement of the parties: All State whether any written agreement is to be incorporated into the Divorce Decree: N/A Date and manner of service of the Notice of Intention to File Pmecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301(d)(1)(i) of the Divorce Code: Service: NA Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 16, 2003 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 24, 2003 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By_ Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 289821 TRISHA J. BORSUK, : Plaintiff : : V. : : RONALD A. BORSUK, JR., : Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-1743 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this3,a~ay of~ C~t.k~,.~ , 2003 I, Andrew C. Spears, Esquire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, Tfisha J. Borsuk, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Ronald A. Borsuk, Jr. 501 Steelstown Road Newville, PA 17241 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By:_ ~ Andrew C. Spears 289821 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY TRISHA J. BORSUK ,STATE OF ~,~~ PENNA. Plaintiff VERSUS RONALD A. BORSUK, JR., Defendant 03-1743 DECREE IN DIVORCE AND NOW, 2003 , IT IS ORDERED AND DECREED THAT TRISHA J. BORSUK AND RONALD A. BORSUK~ JR.~ ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, 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; BY THE COURT: . / ATTE/~/ · 7~~PROTHONOTA~'