HomeMy WebLinkAbout99-03987
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF +Fd. , PENNA.
.....KAREN . E....M.IHALIK
Versus
.. VALERIY V. SELLECK
I
N0....... 3,987....... ...
i
DECREE IN
DIVORCE
..... 1999
AND NOW, ...........a.n%.. it is ordered and
decreed that ........... KARENMIHALIK ................... Plaintiff,
and .................... VALERZx .V.. SELI:E.CK ................ 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;
NONE
.........................................................................
•:•
........................................................
•A
By Th Cou t.
7
Attest- J. A
Prothonotary ?'O•'
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KAREN E. MIIIALIK
Vs.
VALERIY V. SELLECK
To the Prothonotary:
Plaintiff IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 1999-3987
CIVIL ACTION- LAW
Defendant IN DIVORCE
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( )3301C (x) 3301 D of the
Divorce Code. ( Check applicable code )
2. Date and manner of service of the complaint 7/1/99 - certified mail
restricted delivery
3. ( Complete either paragraph (A) or (B) .)
(A) Date of execution of the affidavit of consent required by Section 3301 (C) of the divorce code:
By plaintiff ; by defendant
(B) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (D) of the
DivorceCode:_ 2/26/01
3/1/01-filed
(2) Date of filing and service of the plaintiffs affidavit upon the respondent 3/2/01-personal
4. Related claims pending: NONE service
5. (Complete either (a) or (b).)
(A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy
of which is attached: 3/23/01 - personal service
(B) Date plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary:
Date defendant's Wavier of Notice in § 3301 (c) Divorce was filed with the Prothonotary:
N/A
Attorney for ((X ) Pla tiff t
Francis M. Soch(a,) 2sfqudianre
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KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. 1999- 3987 CL? Tern,
VALERIY V. SELLECK, CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM OF RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the COMPLAINT herein, 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 may be
entered against you for any other claim of 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, CARLISLE,
PENNSYLVANIA.
If you do not file a claim for alimony, division of marital
property, lawyers fees or expenses before the final decree 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 COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717)-240-6200
. .
KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. 1999-
VALERIY V. SELLECK, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION
3301(cl OF THE PENNSYLVANIA DIVORCE CODE
AND NOW, this 28th day of June, 1999, comes the Plaintiff,
Karen E. Mihalik, by and through her attorney, Clayton W.
Davidson, Esquire, and hereby avers the following in support of
her divorce complaint:
1. The Plaintiff, Karen E. Mihalik, is an adult individual
domiciled at 924 Meily Street, Lebanon, Pennsylvania, 17046,
Lebanon County. Plaintiff currently resides at 130 Arnold
Street, lot Floor, Quincy, MA 02169 but maintains her domicile in
Lebanon, Pennsylvania.
2. The Defendant, Valeriy V. Selleck, is an adult
individual who currently resides at 439 Sioux Drive,
Mechanicsburg, Pennsylvania, 17055, Cumberland County.
3. The Defendant has been a bona fide resident in the
Commonwealth of Pennsylvania for at lease six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February
26, 1999, in Mechanicsburg, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. Neither the Plaintiff or Defendant is a member of the
Armed Services of the United States or any of its Allies.
COUNT I
IRRETRIEVABLE BREAKDOWN OF MARRIAGE
8. The Plaintiff incorporates herein, by reference, the
allegations set forth in paragraphs 1 through 7 of this
Complaint.
9. The marriage is irretrievably broken.
10. The Plaintiff has been advised of the availability of
marriage counseling and she may have the right to request the
Court to require the parties to participate in marriage
counseling.
WHEREFORE, the Plaintiff requests that your Honorable Court
enter a Decree of Divorce under section 3301(c) of the
Pennsylvania Divorce Code.
Respectfully submitted
i
Clay n W. Davidson, Esquire
I.D # 79101
2201 North Second Street
Harrisburg, PA 17110
717/233-4141
Date: June 28, 1999
VERIFICATION
I, KAREN E. MIHALIK, hereby verify that
fact made in the foregoing DIVORCE COMPLAINT
to the best of my knowledge, information and
understand that any false statements therein
criminal penalties contained in 19 Pa.C.S. §
unsworn falsification to authorities.
the statements of
are true and correct
belief. I
are subject to the
1904, relating to
KAREN E. MIHALIK
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KAREN E. MIHALIK
Plaintiff
v.
VALERIY V. SELLECK
Defendant
IN THE COURT OF COMMON'PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
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 within twenty (20) days. 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 import 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, York County Courthouse, 28 East High
Street, York, Pennsylvania.
IF YOU DO NOT FIE 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 Court Administrator
4- Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 290-6200
.-I-
KAREN E. MIHALIK
Plaintiff
v.
VALERIY V. SELLECK
Defendant
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
IN DIVORCE
AMENDED DIVORCE COMPLAINT
UNDER SECTION 3301(D)
1. Plaintiff filed a no-fault divorce under Section
3301(c) of the divorce code on June 29, 1999. A copy is attached
hereto and marked as Exhibit "A".
2. Plaintiff and Defendant have been separated since
February 27, 1999, and have lived separate and apart since that
date.
WHEREFORE, Plai.nti.ff respectfully requests this Honorable
Court enter a decree in Divorce pursuant to Section 3301(d) of
the divorce code.
Respectfully submitted
I
DATE: February 26, 2001
Frarcis M. So a, q ire
1 North Second Street
Harrisburg, PA 17110
717/233-9191
Attorney for Plaintiff
KAREN E. MiHALIK
Plaint.itf
V.
VALERIY V. SELLECK
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the allegations set forth in this
Affidavit, you must, file a counterclaim within twenty (20) days
after this affidavit has been served on you or the allegations
will be admitted.
AFFIDAVIT OF PLAINTIFF UNDER
SECTION 3301(d) OF THE DIVORCE CODE
1. The parties Lo this action separated on February 27,
1999, and have continued to live separate and apart.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights, concerning
alimony, division of marital property, atto'rney's fees
or expenses if I do not claim them before a divorce is
granted.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE
TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND
BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 9909 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
Date: ?lzl ?o? 7 Aw
KE. MIHALIK
VERIFICATION
I, KAREN M. MIHALIK, do hereby verify that the statements made
in the foregoing AMENDED DIVORCE COMPLAINT UNDER SECTION 3301(D)
are true and correct to the best of my knowledge, information and
belief. I understand that any false statements therein are subject
to the criminal penalties contained in 18 Pa.C.S. §4904, relating
to unsworn falsification to authorities.
A EN E. MIHALIK
KAREN E. MIHALIK, IN THE COURT OF COMMON ';PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA I'
v. 1999- .??OrI
VALERIY V. SELLECK, CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM OF RIGHTS j
You have been sued in court. If you wish to defend against
the claims set forth in the COMPLAINT herein, 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 may be
entered against you for any other claim of 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, CARLISLE,
PENNSYLVANIA.
If you do not file a claim for alimony, division of marital
property, lawyers fees or expenses before the final decree 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 COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717)-240-6200
KAREN E. MIHALIK,
Plaintiff
V.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
1999-
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION
3301(cl OF THE PENNSYLVANIA DIVORCE CODE
AND NOW, this 28th day of June, 1999, comes the Plaintiff,
Karen E. Mihalik, by and through her attorney, Clayton W.
Davidson, Esquire, and hereby avers the following in support of
her divorce complaint:
1. The Plaintiff, Karen E. Mihalik, is an adult individual
domiciled at 924 Meily Street, Lebanon, Pennsylvania, 17046,
Lebanon County. Plaintiff currently resides at 130 Arnold
Street, 1st Floor, Quincy, MA 02169 but maintains her domicile in
Lebanon, Pennsylvania.
2. The Defendant, Valeriy V. Selleck, is an adult
individual who currently resides at 439 Sioux Drive,
Mechanicsburg, Pennsylvania, 17055, Cumberland County.
3. The Defendant has been a bona fide resident in the
Commonwealth of Pennsylvania for at lease six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February
26, 1999, in Mechanicsburg, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. Neither the Plaintiff or Defendant is a member of the
Armed Services of the United States or any of its Allies.
COUNT I
IRRETRIEVABLE BREAKDOWN OF MARRIAGE
8. The Plaintiff incorporates herein, by reference, the
allegations set forth in paragraphs 1 through 7 of this
Complaint.
9. The marriage is irretrievably broken.
10. The Plaintiff has been advised of the availability of
marriage counseling and she may have the right to request the
Court to require the parties to participate in marriage
counseling.
WHEREFORE, the Plaintiff requests that your Honorable Court
enter a Decree of Divorce under section 3301(c) of the
Pennsylvania Divorce Code.
Respectfully submitted
Clay n W. Davidson, Esquire
I.D # 79101
2201 North Second Street
Harrisburg, PA 17110
717/233-4141
Date: June 28, 1999
VERIFICATION
I, KAREN E. MIHALIK, hereby verify that the statements of
fact made in the foregoing DIVORCE COMPLAINT are true and correct
to the best of my knowledge, information and belief. I
understand that any false statements therein are subject to the
criminal penalties contained in 18 Pa.C.S. §9904, relating to
unsworn falsification to authorities.
L
EN E. MIHALIK
I, Carrie E. Conk, Secretary for Francis M. Socha, Esquire,
hereby certify chat <i tru,e ind correct copy of the foregoing
Amended Divorce Complaint Under Section 3301(D) was served this
date, in the manner indicated, to following:
SERVICE BY U.S. FIRST CLASS MAIL
Austin F. Grogan, Esquire
24 North 32`' Street
Camp Hill, PA 17 11
17 xn Carrie E. Cook
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KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. '
No. 1999 - 3987
VALERIY V. SELLECK,
Defendant CIVIL ACTION - LAW
• IN DIVORCE
AFFIDAVIT OF SERVICE
It Clayton W. Davidson, Esquire, being duly sworn according to
law, depose and state that service of the Complaint in Divorce in
the above-captioned matter was served by certified mail, restricted
delivery, on the Defendant, Valeriy V. Selleck, at 439 Sioux Drive,
Mechanicsburg, PA 17055 on July 1, 1999. The original certified
receipt is attached hereto as Exhibit "A".
Respectfully Submitted,
Submitted,
a 1.
Clayt W. Davidson, Esquire
Attorney I.D.# 79139
2201 North Second Street
Harrisburg, PA 17110
(717)-233-4141
Attorney for Plaintiff
Date: July 7, 1999
Exhibit A
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KAREN E. MIHALIK
Plaintiff
v.
VALERIY V. SEL,LECK
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
TO: VALERIY V. SELLECK, Defendant
You have been sued in an action for divorce. You have failed
to answer the complaint or file a counter affidavit to the
Plaintiff's affidavit. Therefore, on or after April 11, 2001, the
Plaintiff can request the court to enter a final decree in divorce.
If you do not file with the Prothonotary of the court an answer
with your signature notarized or verified or a counter affidavit by
the above date, the court can enter a final decree in divorce.
Unless you have already filed with the court a written claim for
economic relief, you must do so by the above date or the court may
grant the divorce and you will lose forever the right to ask for
economic relief. A COUNTER AFFIDAVIT WHICH YOU MAY FILE WITH THE
PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
UNLESS YOU HAVE ALREADY FILED WITH THE COURT A WRITTEN CLAIM
FOR ECONOMIC RELIEF, YOU MUST DO SO BY THE ABOVE DATE OR THE COURT
MAY GRANT THE DIVORCE AND YOU WILL LOSE FOREVER THE RIGHT TO ASK FOR
ECONOMIC RELIEF. THE FILING OF THIS FORM COUNTER AFFIDAVIT ALONE
DOES NOT PROTECT YOUR ECONOMIC CLAIMS.
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 Court Administrator
4" Floor, Cumberland County Courthouse
Carlisle, PA 17013
1,717) 240-6200
KAREN E. HIHALIK
Plaintiff
v.
VALERIY V. SELLECK
Defendant
IN THE COURT OF COMMCN PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S COUNTER AFFIDAVIT
UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. Check either (a) or (b):
_ (a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both) :
(i) The parties to this action have not lived separate
and apart for a period of at least two (2) years.
(ii) The marriage is not irretrievably broker.
2. Check either (a) or (b):
(a) I do not wish to make any claims for economic
relief. 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.
(b) I wish to claim economic relief which may include
alimony, division of property, lawyer's fees or
expenses or other important rights.
I understand that in addition to checking (b) above, I must also
file all of my economic claims with the Prothonotary in writing and
serve them on the other party. If I fail to do so before the date
set forth on the Notice of Intention to Request Divorce Decree, the
divorce decree may be entered without further delay.
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 unsworn
falsification to authorities.
Date:
Valeriy V. Selleck
NOTICE: If you do not wish to oppose the entry of a divorce decree
and you do not wish to make any claim for economic relief, you need
not file this counter affidavit.
,tJ
4 bw • -. ' -- -
KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. 1999 - 3987
VALERIY V. SELLECK, CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM OF RIGHTS
You have been sued in court. If you wish to defend against
the claims set forth in the COMPLAINT herein, 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 may be
entered against you for any other claim of 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, CARLISLE,
PENNSYLVANIA.
If you do not file a claim for alimony, division of marital
property, lawyers fees or expenses before the final decree 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 COURT ADMINISTRATOR
4TH FLOOR, CUMBERLAND COUNTY COURTHOUS.
CARLISLE, PA 17013
(717)-240-6200
KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. 1999 - 3987
VALERIY V. SELLECK, CIVIL ACTION - LAW
Defendant IN DIVORCE
AMENDED COMPLAINT IN DIVORCE UNDER SECTION
3301(c) OF THE PENNSYLVANIA DIVORCE CODE
AND NOW, this 4th day of January, 2000, comes the Plaintiff,
Karen E. Mihalik, by and through her attorney, Clayton W.
Davidson, Esquire, and hereby avers the following in support of
her divorce complaint:
1. The Plaintiff, Karen E. Mihalik, is an adult individual
domiciled and residing at 924 Meily Street, Lebanon,
Pennsylvania, 17046, Lebanon County.
2. The Defendant, Valeriy V. Selleck, is an adult
individual who currently resides at 439 Sioux Drive,
Mechanicsburg, Pennsylvania, 17055, Cumberland County.
3. The Defendant has been a bona fide resident in the
Commonwealth of Pennsylvania for at lease six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February
26, 1999, in Mechanicsburg, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling.
7. Neither the Plaintiff or Defendant is a member of the
Armed Services of the United States or any of its Allies.
COUNT I
IRRETRIEVABLE BREAKDOWN OF MARRIAGE
8. The Plaintiff incorporates herein, by reference, the
allegations set forth in paragraphs 1 through 7 of this
Complaint.
9. The marriage is irretrievably broken.
10. The Plaintiff has been advised of the availability of
marriage counseling and she may have the right to request the
Court to require the parties to participate in marriage
counseling.
WHEREFORE, the Plaintiff requests that your Tionorable Court
enter a Decree of Divorce under section 3301(c) of the
Pennsylvania Divorce Code.
COUNT TWO
CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL FEELS,
COSTS AND EXPENSES UNDER SECTION 502 OF THE DIVORCE CODE
11. The Plaintiff incorporates herein, by reference, the
allegations set forth in paragraphs 1 through 10 of this
Complaint.
12. The Plaintiff believes and avers that she is entitled
to an award of reasonable alimony pendente lite, counsel fees,
costs and expenses.
13. Defendant is fully well and able to pay Plaintiff
alimony pendente lite, counsel fees and cots and expenses
incidental to this divorce action.
WHEREFORE, Plaintiff requests that this Honorable Court
enter a decree that the Defendant pay alimony pendente lite,
counsel fees, costs and expenses to the Plaintiff
Respectfully submitted
Clayt n W. Davidson, Esquire
I.D.# 79101
2201 North Second Street
Harrisburg, PA 17110
717/233-4141
Date: January 4, 2000
CERTIFICATE OF SERVICE
I, Clayton W. Davidson, Esquire, hereby certify that a true
and correct copy of the foregoing Amended Complaint in Divorce
was sent by first class, U.S. mail to the following:
Valeriy V. Selleck
439 Sioux Drive
Mechanicsburg, PA 17055
Pro-se Defendant
Clayto W. Davidson
Date: January 4, 2000
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
KAREN E. MIHALIK ) Docket Number 99-3987 CIVIL
Plaintiff )
Vs. ) PACSES Case Number 939301962/D29382
VALERIY V. SELLECK )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this 2ND DAY OF FEBRUARY, 2001 IT IS HEREBY
ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other
COMPLAINT FOR APL filed on JANUARY 4, 2000 in the above captioned
matter is dismissed without prejudice due to:
PETITIONER WITHDRAWING HER CLAIM FOR ALIMONY PENDENTE LITE.
Q The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
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BY THE
DRO: Rl Shadday
j xc: plaintiff Edgar B. Bayley
defendant
Francis Socha, Esquire
Austin Grogan, Esquire
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Form OE-506
Worker lD 21005
KAREN E. MIFIALIK,
Plaintiff
VS.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-3987 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS
BEFORE BAYLEY AND HESS. JJ
ORDER
AND NOW, this Z -IL' day of July, 2000, the preliminary objections of the
defendant to the plaintiff's complaint are DENIED.
BY THE COURT,
Clayton W. Davidson, Esquire
For the Plaintiff
Austin Grogan, Esquire
For the Defendant
Kevi A. Hess, J.
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY
Please list the within matter for the next:
_ Pre-Trial Argument Court
,/Argument Court
KAREN E. MIHALIK,
Plaintiff
V.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
1999 - 3987
CIVIL ACTION - LAW
IN DIVORCE
1. Matter to be Argued: Defendant's preliminary objections
to jurisdiction of the parties divorce action.
2. Counsel:
Plaintiff: Clayton W. Davidson, Esquire
2201 North Second Street
Harrisburg, PA 17110
(717)-233-4141
Defendant: Austin Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
(717)-737-1956
3. I will notify all parties in writing within two days that
this case has been listed for argument.
4. Argument Court Date: July 26, 2000
Call of Argument List Date: July 6` 2000
Clayton W. Davidson, Esq.
I.D. #79139
2201 North 2nd Street
Harrisburg, PA 17110
(717)-233-4141
Attorney for Plaintiff
Date: 6/6/2000
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KAREN E. MIHALIK,
Plaintiff
V.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
1999 - 3987
CIVIL ACTION - LAW
IN DIVORCE
ANSWER TO DEFENDANT'S PRELIMINARY OBJECTIONS
AND NOW, this 16th day of March, 2000, comes the Plaintiff,
Karen E. Mihalik, by and through her attorney, Clayton W.
Davidson, Esquire, and hereby avers the following:
1. Admitted in part and denied in part. Plaintiff admits
that she does not live in Cumberland County. However, Plaintiff
denies that Cumberland County lacks venue over these proceedings.
Furthermore, Plaintiff contends that at the time of the filing of
her divorce complaint the Defendants domicile was Cumberland
County, Pennsylvania.
2. Denied. By way of further answer Plaintiff contends
that she has always maintained her domicile in Pennsylvania
throughout these proceedings and currently lives in Lebanon
County, Pennsylvania. Furthermore, Plaintiff contends that at
the time of the filing of her divorce complaint the Defendants
domicile was Cumberland County, Pennsylvania.
WHEREFORE, Plaintiff requests that this Honorable Court to
deny Defendant's preliminary objections.
Respectfully submitted
Clayton W. Davidson, Esquire
I.D.# 79139
2201 North Second Street
Harrisburg, PA 17110
717/233-4141
Date: March 16, 2000
CERTIFICATE OF SERVICE
I, Clayton W. Davidson, Esquire, hereby certify that a true
and correct copy of the foregoing Answer was sent by first class,
U.S. mail to the following:
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
Attorney for Defendant
Clayton W. Davidson
Date: March 16, 2000
I, Karen E. Mihalik, Plaintiff in the above captioned case,
hereby swear and affirm, that the information contained in my
Answer is true and correct to the best of my information,
knowledge and belief. I further understand that false statements
made herein are subject to criminal penalties under 18 Pa.C.S.A.
§4904 concerning unsworn falsification to authorities.
XAREN E. MIHALIK
Date:
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KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V NO. 1999-3987
VALERIY V. SELLECK, CIVIL ACTION - LAW
Defendant
NOTICE TO PLEAD
TO: KAREN E. MIHALIK, PLAINTIFF and
CLAYTON W. DAVIDSON, ESQ., ATTORNEY FOR PLAINTIFF
You are hereby notified to file a written response to the within Preliminary
Objection within 20 days from service hereof or a judgment may be entered against
you.
Date
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Austin F. Grogan, Es(luuir
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Defendant
ID #59020
KAREN E. MIHALIK,
Plaintiff
V.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
DEFENDANT'S PRELIMINARY OBJECTION TO PLAINTIFF'S COMPLAINT
PRELIMINARY OBJECTION TO LACK OF JURISDICTION
AND NOW, this P9day of February 2000, the Defendant, Valeriy V. Selleck,
by and through his Attorney, Austin F. Grogan, Esquire, avers the following:
1. Neither party lives in Cumberland County, therefore, Cumberland County lacks
jurisdiction over the subject matter and/or the person of the Defendant;
2. Currently the Plaintiff lives in Quincy, Massachusetts and the Defendant lives in
the State of New York and it is inconvenient for the parties to pursue Divorce action in
Cumberland County.
WHEREFORE, the Defendant respectfully requests this Honorable Court to dismiss
this action for lack of jurisdiction over the subject matter and/or the person.
Date-f`&--o " A
Austin F. Gr6g Es uire
24 North 32nd Stree
Camp Hill, PA 17011
(717) 737-1956
Attorney for Defendant
ID 1/59020
AFFIDAVIT OF SERVICE
I, Austin F. Grogan, Esquire, hereby certify that I did mail a true and correct copy of the
Preliminary Objection and Notice to Plead in the above-captioned matter on the a$'Ps' day of
A401, 2000 to:
((JJ Clayton W. Davidson, Esquire
2201 North Second Street
Harrisburg, PA 17110
which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403.
I understand that false statements are made herein are made subject to the penalties of
Pa.C.S. § 4904, relating to unworn falsification to authorities.
Date
Austin F. Grogan, squire
24 North 32nd Street--
Camp Hill, PA 17011
(717) 737-1956
Attorney for Defendant
ID #59020
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KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO.99-3987 CIVILTERM
VALERIY V. SELLECK, IN DIVORCE
Defendant/Respondent DR# 29,382
Pacses# 939101942
ORDER OF COURT
AND NOW, this 10" day of February, 2000. upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Shaddav on March 2. 2000 at 10:30 A.M. for a conference, at 13 N. Hanover
St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered.
YOU are further ordered to bring to ilia conference:
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.110
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT.
George E. Hoffer. President Judge
Mail copies on Petitioner
2-10-00 to: < Respondent
Clayton Davidson, Esquire 7
Date of Order: February 10. 2000
JRShadklay. Conference Officer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE. PENNSYLVANIA 17013
(717) 249-3166
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KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. No. 1999-3987
VALERIY V. SELLECK, CIVIL "ACTION - LAW
Defendant IN DIVORCE
TO THE HONORABLE KEVIN A. HESS, JUDGE OF SAID COURT:
PLAINTIFF'S RESPONSE TO RULE TO SHOW CAUSE
AND NOW, this loth day of July, 2000, comes the Plaintiff,
Karen E. Mihalik, by and through her attorney, Clayton W.
Davidson, Esquire, and hereby avers the following:
1. On or about February 29, 2000 the Defendant filed
preliminary objections regarding Pennsylvania having jurisdiction
in the above captioned divorce action.
2. On June 7, 2000, present counsel listed the above
referenced preliminary objections for argument court.
3. On June 22, 2000, Defendant filed a motion for
continuance and on June 30, 2000 this Honorable Court issued a
rule upon Plaintiff, returnable within ten (10) days, as to why
the Defendant's motion should not be granted.
4. Present counsel has been informed by the Plaintiff that
the Defendant's preliminary objections are meritless and
unfounded since she was domiciled in Pennsylvania at all times
during the parties marriage and all times thereafter.
Furthermore, Plaintiff is currently domiciled in Lebanon County,
Pennsylvania.
5. Present counsel has been informed by the Plaintiff that
the Defendant was domiciled in Cumberland County, Pennsylvania at
the time of the filing of the divorce action, accepted service of
the divorce action in Cumberland County and was domiciled in
Cumberland County during the parties marriage.
6. Present counsel has been informed by the Plaintiff that
the Defendant is an illegal alien, has assaulted her recently and
should be deported since his "visa" has expired. Furthermore,
Plaintiff believes Defendant's preliminary objections are a delay
tactic to circumvent his deportation.
7. Present counsel has been informed by the Plaintiff that
she desires a timely resolution of the Defendant's preliminary
objections since has been suffering emotional distress due to the
Defendant's filing and wants closure of her divorce action
whether in this state or another.
WHEREFORE, the Plaintiff respectfully requests this
Honorable Court deny the Defendant's motion for continuance.
Respectfully Submitted,
Clayton Davidson, Esquire
I.D.# 139
2201 North 2nd Street
Harrisburg, PA 17110
(717)-233-4141
Attorney for Plaintiff
Date: July 10, 2000
I, Clayton W. Davidson, Esquire, hereby verify that the
facts contained in the foregoing Response are true and correct to
the best of my information, knowledge and belief. I further
understand that false statements made herein are subject to
criminal penalties under 18 Pa.C.S.A. §4904 concerning unsworn
falsification to authorities.
CLAY W. DAVIDSON
Date: July 10, 2000
I, Clayton W. Davidson, Esquire, hereby certify that a true
and correct copy of the foregoing Response was sent to the
following persons by the manner indicated below:
FIRST AS U MAIL PO TAGE PR PA D:
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
Attorney for Defendant
Clayton . Davidson, Esquire
Date: July 10, 2000
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KAREN E. MIHALIK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : 99-3987 CIVIL
VALERJY V.SELLECK,
Defendant CIVIL ACTION - LAW
IN RE: MOTION TO CONTINUE
ORDER
AND NOW, this 360 day of June, 2000, a rule is issued on the plaintiff to show
cause why the relief requested in the within Motion to Continue ought not to be granted. This
rule returnable ten (10) days after service.
BY THE COURT,
Kev' A. Hess, J.
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KAREN E. MIHALIK,
Plaintiff
V.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
ORDER
AND NOW, this day of . 2000 the attached Motion to Continue is GRANTED.
It is further ORDERED that the Argument be listed for the day of 2000.
BY THE COURT,
J.
KAREN E. MIHALIK,
Plaintiff
V.
VALERIY V. SELLECK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999-3987
CIVIL ACTION - LAW
IN DIVORCE
MOTION FOR CONTINUANCE
AND NOW, this 2 day of June 2000, the Defendant, Valeriy V. Selleck, by
and through his Attorney, Austin F. Grogan, Esquire, avers the following:
1. On or about February 29, 2000 the Defendant filed preliminary objections to
jurisdiction in the above captioned divorce action;
2. The Plaintiff's counsel has listed the matter for argument on July 26, 2000;
3. The undersigned counsel serves as a Public Defender for Cumberland County
and is currently scheduled for court on July 26, 2000;
4. The undersigned counsel has contacted the Plaintiff's counsel, Clayton
Davidson, who opposes this Motion to Continue.
WHEREFORE, the Defendant respectfully requests this Honorable Court to continue
the argument listed for July 26, 2000.
Date ID,2
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Austin F. Grogan, Es
24 North 32nd Stre
Camp Hill, PA 17011
(717) 737-1956
Attorney for Defendant
ID #59020
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KAREN E. MIHALIK IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 1999-3967
VALERIY V. SELLECK CIVIL ACTION - LAW
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, AUSTIN F. GROGAN, ESQUIRE, attorney for the Defendant in
the above-captionec! case, do hereby accept service of the AMENDED
DIVORCE COMPLAINT UNDER SECTION 3301(d) and hereby acknowledge
receipt of a true, correct and complete ropy.
I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. Section 9904, relating to unsworn
falsification to authorities.
Date: March 2, 2001
Austin F. G gan,i squire
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