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Home My WebLink About07-1917.~ F:\FILES\DATAFILE\General\Cunent\1251 S 12515.dcoml Created: 6/1/06 S:SOAM Revised: 4/9/07 1 L 32AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SERAPHIM LASKOWSKI, Plaintiff V. SPIlZIDOULA B. LASKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007- D'7- ~~17 ctVl I lerrn 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 L. ' ~i SERAPHIM LASKOWSKI, Plaintiff v. SPIIZIDOULA B. LASKOWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007- ~ ~> / 7 ~ T-~-~"` IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is, Seraphim Laskowski, who currently resides at 307 Glenn Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is, Spiridoula Laskowski, who currently resides at 702 Petersburg Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on November 22,1997, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 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. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(Cl OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. When at the appropriate time, Plaintiff will file an Affidavit of Consent and Waiver of Notice. WHEREFORE, Plaintiffrespectfullyrequests the Court to enter a decree of divorce pursuant ti ~~ to Section 3301 of the Divorce Code. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(A) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. MARTSON LAW OFFICES By ~/~~J Jenni r .Spears, Esquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: ~ ~ ~~ `~~~~ Attorne s for Plaintiff Y .. ~ ti~ VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Divorce Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. F: \FII,ES\DATAFILE\Genoral\Cumnt\1251 S I2515.dwml ~~ ~ ~ ~ ~ ~ 0~ s ~ o° Vi `~' O b _ ca r,., ~ ~ F:\FTLES\General\Current\1251512515.1.pra Creatcd: 6/U06 S:SOAM Revised: 5/30/07 11:22AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SERAPHIM LASKOWSKI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. 2007-1917 -CIVIL ACTION LAW SPIIZIDOULA B. LASKOWSKI, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the Complaint against Defendant in the above-captioned action and return same to the undersigned for. service. MARTSON LAW OFFICES By Jen~ife .uS~pears, Esquire 10 Eas High Street Carlisle, PA 17013 (717) 243-3341 Date: May 30, 3007 Attorneys for Plaintiff n G r • ~j C~l~t~y. ~ ~v _~ -... w ~. ~ W ti :~~, ~_ `~ w -~ N c1't W C7 -ri ~~ ~~ ~_~~, "-~C