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Home My WebLink About03-2407CECILIA B. JANKURA, Plaintiff · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA v · NO. ~3-,~O~z CIVIL TERM KENNETH U. JANKURA, Defendant · 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 CECILIA B. JANKURA, Plaintiff V KENNETH M. JANKURA, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. ~_~ ,~ ~/o'7 CIVIL TERM · IN DIVORCE COMPLAINT UNDER SECTION 3301(C ) OR (D) OF THE DIVORCE CODE Plaintiff, Cecilia B. Jankura, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Cecilia B· Jankura, is an adult individual residing at 72 Covered Bridge Road, Newburg, Cumberland County, Pennsylvania 17240. 2 Defendant, Kenneth M. Jankura, is an adult individual residing at 617 Brookens Road, Fayetteville, Franklin County, PA 17222. 3 The parties were married on December 15, 1984, in Cumberland County, Pennsylvania. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c ) of the Divorce Code, the marriage between the parties 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. ! / Lindsa~_. Baird, Esquire ~.~ Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities. Cecilia B. Jankura, PlaitS' CECILIA B. JANKURA, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-2407 CIVIL TERM KENNETH M. JANKURA, Defendant :IN DIVORCE AFFIDAVIT OF SERVICE I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, May 22, 2003, by Certified Mail - Return Receipt Requested, restricted delivery, a copy of said return receipt evidencing delivery being attached hereto. Said service on May 22, 2003. Sworn and Subscribed to before me this 22nd day of August, 2003. L~dsay D. Bair~, Esquire ~.4~ttorney for Plaintiff 37 South Hanover Street Carlisle, PA 17013 717 - 243-5732 N~ary Public ~.~ · Complete items 1,2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpieca, or on the front if space permits. 1. Article Addre~ed to: 2. Article Number (Transfer from service label) n Agent [] Yes Service Type [] Express Mall [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. Dellver~? ~ra Fee) ~Yes Restricted 7001 2510 0006 5891 6078 102595-01 oM-7424 PS Form 3811, March 2001 * ;~ ' Domestic Return Receipt CECILIA B. JANKURA, Plaintiff KENNETH M, JANKURA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2407 CIVIL TERM :IN DIVORCE 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 Section 3301 (C) of the Divorce Code was filed on May 21, 2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on May 22, 2003. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. t 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. 6. t 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 Et is filed with the Prothonotary. 7. 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. Section 4904 relating to unsworn falsification to authorities. Date: Cecilia El. Jankura,¢,c~ndant CECILIA B. JANKURA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-2407 CIVIL TERM KENNETH M. JANKURA, Defendant : IN DIVORCE 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 Section 3301(C) ot the Divorce Code was filed on May 21, 2003. 2. Defendant acknowledged receipt and accepted service of the Complaint on May 22, 2003. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose dghts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divome is granted. 6. I understand that I will not be divorced until a divome 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. 7. 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. Section 4904 relating to unsworn falsification to authorities. Date: Kenneth M. Jankur~ Defendant CECILIA B. JANKURA, Plaintiff V KENNETH M. JANKURA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2407 CIVIL TERM :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: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: May 22. 2003, certified mail, restricted delivery, return receipt. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: August 22, 2003; by Defendant: August 22, 2003. 4. Related claims pending: None. 5. Date Plainti~sWaiverof Noticein §3301(c)Divorce wasfile¢lwiththe Prothonotary: August22,2003 Date De~ndant'sWaiverof Noticein §3301(c)Divorce wasfiled withthe Prethonotary: August22,2003 ~,,L'~n d say Dare Esquire Attorney for the Plaintiff c2c c~ o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CECILIA B. JANKURA, Plaintiff VERSUS K~N~,~ M. JANKURA~ NO. 03-2407 AND NOW,__ DECREED THAT DECREE IN DIVORCE Cecilia B. Jankura IT IS ORDERED AND , PLAINTIFF, AND Kenneth M. Jankura , 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;