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Home My WebLink About99-03340 ;W E Ih _.w Andrew C. Shealy, Esquire 127 S. Market Street P.O. Box 9$ Mechanicsburg, PA 17055 PAID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LINDA K. FERKO, Plaintiff VS. ANDREW J. FERKO, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 32'/0 CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT 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 against you and a decree in 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 with your children. When the grounds 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 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ail ', ?w drew C. Sheely, Es re PA. I.D. No. 62969 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LINDA K. FERKO, Plaintiff VS. ANDREW J. FERKO, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 3 3 yd CIVIL TERM IN DIVORCE COMPLAINT 1. Plaintiff is Linda K. Ferko, an adult individual who currently resides at 1104 (B 1), Yverdon Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Andrew J. Ferko, III; an adult individual who resides at 267 Wagon Road, Millersburg, Dauphin County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 6, 1990 in Millersburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. Plaintiff avers that she is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render her condition intolerable and life burdensome. 10. This action is not collusive. 11. The parties separated on March 5, 1999. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. COUNT II---QLAI4 FOR EQUITABLE DISTRIBUTION OF MARITAL pRQU UNDER SECTION 35n2 OF THE DIVORCE COPE 12. The allegations in Paragraphs 1 through and 11 are incorporated herein and made a part hereof. 13. Plaintiff and Defendant are the owners of various personal property, motor vehicles, bank accounts, retirement accounts and insurance policies acquired during their marriage. 14. Plaintiff and Defendant are the owners of real property acquired during their marriage. 15. Plaintiff and Defendant have acquired various marital debt during the period of their marriage. 2 - WHEREFORE, Plaintiff requests your Honorable Court equitably distribute the parties marital property, including marital debt and including any such further relief as the Court may determine equitable and just. Date: June /, 1999 Res ectfull s tte A, . Andrew C. Sheely, Es ire Attorney for Plaintiff PA ID No. 62469 P.O. Pox 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 3 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: June 1999 44'L J x 4, inda K. Ferko Andrew C. Shealy, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 Ph ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LINDA K. FERKO, Plaintiff Vs. ANDREW J. FERKO, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - CIVIL TERM IN DIVORCE AFFIDAVIT Linda K. Ferko, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request.. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed doom by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. /ml 4z z.J) , iLinda K. Ferko a w4 ,(:tj r' c? A Y,LONOHIOtld Q31b1SNMJ 1NWIcitb'J In the Court or Common Pleas or Cumberland County, Pennsylvania vs, 3310 Civil. 19 ZX, b ve_ - co?io?ed' i i t To / `rJ?fiS R. 4y/Ic; _ ----.?; Pmdronomry ?L/le_ Z9 V 19 Alto rncy for Plaintiff -Ally 61 POPA ddI33VNd '$A 61 'iway 'nN Andrew C. Sheely, Esquire 127 S+ Yarkot Street P.O. BOx.95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) LINDA K. FERKO, Plaintiff vs. ANDREW J. FERKO, III Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW e 99 - 3340 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that he caused a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon Andrew J. Ferko, III, by Certified Mail, Restricted Delivery, Return Receipt Requested, as indicated by the attached receipt cards, on July 2, 1999. l-s ANDREW C. SHEELY SWORN to and subscribed before me this t7)Ylt day of July, 1999. Notary Public tEWANALWA My Commission Expires: CAreff I&W", No" PyAk MrdWAW Mp seed CW*04sad Ce., fA MI CvwWa en Evbw Mom% 1& 2002 oY " SENDER: •Dompae hems 1 and/or 2 rot additional services. - I also wish to receive the • aCanplae Items 3.4s, and 4b. - following services (for an • Pdm your name and address on the ravree of this form so that we can Mum this extra fee)):: card lo yyoou. W w as does not a Attach this form to the from of the mall ea, or on the back If i : /??a 1' RESTR IOTs o j Un ppaete t •w Return ew Requested'delthsamdd number d •TN Return Rxahpat t will show to o whom wtam the arild article was was deavarsd and the ties ? ? ? 2,'Xr71C, delivered. Consult 3. Article Addressed to: 4a. Article Number ANDREW J. FERKO III Z 399 976 945 E E , RESTRICTED DELIVERY 4b. Service Type d $ ? Registered XXCertlBed c ADDRESSEE ONLY ? Express Mall ? Insured n WAGON ROAD ZQ/ ? Return Receipt forMomhendse ? COD MILLERSBURG, PA 17061 7. Date of Delivery 5. Received By: (Print Name) 8. Addressee's Address (Only Nrequested c and foe Is paid) A F 9 8. S(g ah ?fressee o e f) ? PS Form 30-1, Decem 1994 102595-97."179 Domest c Return Rece pt MNMNG OFF hum Receipt CUSTOMER: Complete unshaded area Items 4) and color your name and address on Me reverse, was paid for rr G ? R 4ryA^D`?d Atladr toe as shown in DMM If return recelpt was not will for at time of mallin4.. 4. Aside Number ? 1. Return receipt WAS NOT paid for at time of mailing. ? 2a. Return receipt WAS paid for at time d mailing. R2b. Return receipt showing addressee's address WAS paid for at tme of mailing. 3. Aside Addressed To: A,d,ew T FP,- -is•.l aG7 w???N Rd( 170(a/ Z. 2,;_ 9 A E] 000 ® Caged ? Nunbemd lmured ? Mo dandPse ? FxP ass Ma l ? flag s e ed Show: Dom 10. A.ddr December 1994 W a _ a ul ? fa v S _ 2' M1 ? w ?' 6l rn 'o tr ?Uqt S 2w81 m c n ?m 0 N a U c 712ze Domestic Return Receipt 11 H x t v fa o ? AE C ,Y q W a n 1 rJ O O m ? rn ? o ? R.? r 1 •0 _J Z g LL > O IN a N 7d ?e` ' o u a t? j ? iA a a ? a d 500 i•" y o4'"' -- Ujo CV ?.r cc 7 ?- M LL U t