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Home My WebLink About99-04613F y A I { ?O h m-; V r? !I ,R i ^if a °T a c? 0 U ? d ? LL W B v¢a ¢ U) wow =ZZ UO? I N a zza C (5 0 Z CY R Z R ? Q U S T G O u u u `o U C A U M ? U O L U J O ?. v O L ? .. U V J C U O T .? L T U G U U C t t O O ? • t LINETTE CHARLENE LENKER, s IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA s V. s s No. -FIE" s CIVIL ACTION - LAW MATTHEW THOMAS NOVAK, : Defendant s 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. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Telephone: (717) 249-3166 Respect ted, P. C. Date: 7f/6 99 I.D. #23144 2320 North Second Street P. 0. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Plaintiff) LINETTE CHARLENE LENKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA l C??Q Tv. NO. 99- 414-1.3 g CIVIL ACTION - LAW MATTHEW THOMAS NOVAK, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, LINETTE CHARLENE LENKER, by and through her attorneys, Cunningham & Chernicoff, P.C., who files this Complaint in Divorce, alleging the following: 1. Plaintiff is LINETTE CHARLENE LENKER, who currently resides at 241 Reeser Road, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiffs Social Security Number is 193-68-4736. 2. Defendant is MATTHEW THOMAS NOVAK, who currently resides at P. 0. Box 79, Kewadin, Michigan 49648. Defendants Social Security Number is 375-98-3695. 3. The Plaintiff has been a bona fide resident in 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 March 1, 1999 in Key West, Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff further avers that Defendant is not in the Military Service or in any branch of the Armed Forces of the United States or its Allies or otherwise within the provisions of the Soldiers, and Sailors, Civil Relief Act of Congress of 1940 and its Amendments. 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. 2 WHEREFORE, Plaintiff requests this Court to enter a Decree of Divorce. ted, COFF, P. C. Date: ?/s ? I.D. #8144 2320 North Second Street P. 0. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Plaintiff) I verify that the statements made in the foregoing Complaint in Divorce 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. ?G4LGG'Y C /?IGSl?CG?(!'' ,?E- c-Pil LINETTE CHARLENE LENKER Date: I'IAI' "? AFFIDAVIT STATE OF FLORIDA . ss; COUNTY OF i2 E V NZ-b I, LINETTE CHARLENE LENKER, being duly sworn according to law, depose and say: (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 down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. LINETTE CHARLENE LENKER SWORN and Subscribed t,6by `` kcr 1.0 +o 1S Before me this 1IthJday o 1999. Y GLC.?i?-QX ..J? NOTARY PUBLIC fi4M S. TERRY MYCOMMMIOCC55M E70'MM00, 2DDO 6abe0 Thu MoWY ROb UMMxdbn AFFIDAVIT OF NON-MILITARY SERVICE STATE OF FLORIDA ss; COUNTY OF gi?EU P2D The Plaintiff, being duly sworn according to law, deposes and says that she is the Plaintiff in the above captioned matter and that she personally knows that the Defendant is over the age of eighteen (18) years. The Plaintiff further avers that the Defendant is not in the Military Service or in any branch of the Armed Forces of the United States of America or its Allies or otherwise within the provisions of the Soldiers, and Sailors, Civil Relief Act of Congress of 1940 and its Amendments. LINETTE CHARLENE LENKER SwoRN and Subscribed 't-a by Livie4C?c?'I?e.LeoJ(-v wG?o15e Before me this JA??, day f J7 ??/ , 1999. f?ckL?,?Q M' CMWON EWES: May 20.2700 tltl; Mary ROb OWWM , LINETTE CHARLENE LENKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. MATTHEW THOMAS NOVAK, CIVIL,ACTION - LAW Defendant IN DIVORCE IHtq.1n REV.3A wNNpwv.TALTH OF rEwenvANU, cerARlMLnoF HTALIH VITAL RECORDS RECORD OF STATE FILE NUMBER CpM1 DIVORCE OR ANNULMENT STATE FILE DATE Cumberland ® (CHECK ONE) ? HUSBAND 12. NUMBER OF THIS RRIAGE MA 1 3. RACE WHITE K SACK OTHER (Specify) 14. USUAL OCCUPATION Registered Nurse 1S PLACE OF (Cacn07 (SOW W Fmgn Cw F/) B. DATE OF (MMm) (Day) (you) AB Key West Florida 3/1/99 wS BRME M IAGe 17A. 14UMBOOF 78. NUMBEROFDEPENDENT 1B. PWNRFF E. DECREEGRANTEDTO CHEDREN THISO CHILDREN UNDER Ia. 0 HUSBAND WIFE gO1Q (SMU),) HUO D - O (SFNMI " MARRIAGE ?- ED 20. NUMBERCF HUSBAND WIFE SPUTCUSTODY OTHERISpw1y) 21. LEGAL OROUNOSFOR CHILDREN TO _ _ ? DIVORCE OR ANNULME13<301 ( C) CUSTODY OF 22. DATE OF DECREE (Mm W) (0q) (y"q 23. DATE REPORT SENT (1b10) (C*) Mao F TOV(TALRECORDS N. SIGNATURE OF TRANSCRIBING CLERK WIFE 8. MAIOEN NAME (Fk" IA WAI (LO4 B. DATE (Manm) (Dry) (YM0 (Canker) Linette Charlene Lenker BOF 5/29/74 10. RESIDENCE SuvwwRD. 0%Sam. ar Trp. CNUIy Swe 11. PLACE (S9NaF"g1CMfty) 241 Reeser Road, Camp Hill, Cumberland County, PA OF Hershey, PA LINETTE CHARLENE LENKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 4613 CIVIL TERM MATTHEW THOMAS NOVAK, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I do hereby state that I served a true and correct copy of the complaint in Divorce with regard to the above captioned matter, by placing the same in the United States mail, first- class, postage prepaid, certified mail, return receipt requested, restricted delivery, in Harrisburg, Pennsylvania, on August 9, 1999, as per the attached return receipt card, addressed to: Matthew Thomas Novak P. 0. Box 79 Kewadin, Michigan 49648 Respectfully submitted, CUNNINGHAM fis CHERNICOFF, P.C. Date: November 12. 1999 1lanche A. Morrison, ecretary o Jordan D. Cunningh m, Esquire D. #23144 2320 North Second Street P. 0. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 (Attorneys for Plaintiff) SENDER: eComplae nerve t rww 2 for adrtlaW serweee. I also wish to receive the eCamptae heft 3, M, and b. e? name emd eddrue an the mane of this bmn So met we oen raum five I'drit m following services (for an 6xitg 169): ? u eAeech tae iota to the tram of the meapce k, or m the emm if space does not a?NM alum RWW RpusetWon the nwlge e hab m id 1 w c e a e number. The Retum ReWpt will r wwb whom the aNde mite delivered and the date 2. Restrlded Delivery S delivered, 3. Artlde Addressed to: 4a. Atdde Nu r 4b. Service Type 13 Registered M_e' N ed ??u c7tf7n ?/ C" ?L ? Express Mall ? Insured 13 Return Receipt forMercherWse O COD JGL? 7. Date of Delivery _ q - !t/ C7 $ 5. Ned By: (Print Name) 8. Address6e's Address (Only If requested -? ef.(J u ) L and fee Is paid) 9. Signature: (Addlessm crAgenQ P 3811, r 1 10259SW B-0179 Domestic ntum Rana nt ,_, -