Loading...
HomeMy WebLinkAbout01-04224CHARLOTTE A. JAKOMAS, Plaintiff v. JOHN H. JAKOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. - CIVIL TERM D/-<l1z~ IN DIVORCE NOTICE 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 maybe 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 Plaintif£ 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 Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 CHARLOTTE A. JAKOMAS, Plaintiff V. JOHN H. JAKOMAS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. o I - 4 CNIL TERM - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Chazlotte A. Jakomas, who currently resides at 226 South Hanover Street, Cumberland County, Pennsylvania, since January, 2001. 2. Defendant is John H. Jakomas, who currently resides at 336 North Bedford Street, Cumberland County, Pennsylvania, since September, 1999. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 3, 1975, in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. COUNT II: REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 L) OF THE DOMESTIC RELATIONS CODE 1. The prior paragraphs of this Complaint are incorporated by reference. 2. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. Plaintiff and Defendant have been unable to agree to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order equitably distributing the parties marital property pursuant to Section 3502 (d) of the Divorce Code. 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. § 4904, relating to unsworn falsification to authorities. Date: ~ ^ ~ 3 - ~' D d~ ~/~~2~G~ ~4~~ Charlotte A. Jakomas, Pl ' iff ~- By:_ Kazl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070