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Home My WebLink About99-05405lkil a s h h 9 J a N .o C) 0 It 1y IR, 1 Y FYI ? (5 1 1 ?c . i : f ?.: IN THE COURT OF COMMON PLEAS CF CUMBERLAND COUNTY STATE OF PENNA. n+ a Joseph T. Snitrovich, Jr., syUS Plaintiff I NO. '5065 Civil 1999 VERSUS Michelle M. Tiahok, Defendant DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT Joseph T. ovich, Jr. PLAINTIFF, AND Michell M liabok 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 . BY TH O ? J. PROTHONOTARY ? ?a .off Ce?',..?? ? iis?+-?' ? ?? ??? ???ao? ?????? ?? Plaintiff vs. MICHELLE M. TISHOK, Defendant CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5405 Civil Term. ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under F43301 of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail restricted delivery return receipt re.quested delivered on: September 21, 2001. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: January 4, 2002. By Defendant: December 27, 2001. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 8, 2002. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 8, 2002. - C Date: I -8: Jan Adams, Esquire I. . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff i,; I ' j_ V i i '? _- .a t _ ?)?; I?_1 i a Ll .' ? ?-. .. n : i ; -j . ij JOSEIIII T. LMITROVICII, IR. I'laintiff V5. MICHELLE M.TISHOK, Defendant IN *11I1i COURT OF COMMON PLEAS CIMBERLAND000NTY, I'FNNSYLVANIA No. q 5'- S•'LPOs : ACTION 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 tail 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE: A CLAIM FOR ALIMONY. DIVISION 01' PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMI NI, IS GRANTED. YOU MAY LOSE T[ IF RIGI IT TO CLAIM TI II?M. YOU SHOULD TAKE. "I-IIIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO. OR'1'ELI:1'IiONt ,'II IE OFFICE SET FORTH BELOW TO FIND OU*I WI II'.RI: YOU CAN GFF LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pa. 17013 (717)249-3166 JOSEPH T. ZMITROVICH, JR., Plaintiff VS. MICHELLE M. TISHOK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99- sous' (?' .? -Te,_ ACTION IN DIVORCE COMPLAINT IN DIVOR AND NOW comes Joseph T. Zmitrovich, Jr., by and through his Attorney, Jane Adams, Esquire and respectfully avers the following: COUNT 1- DIVORCE 1. Plaintiff is Joseph T. Zmitrovich, Jr., an adult individual, who has resided at 96 Tory Circle, Enola, Pennsylvania, since 1995. 2, Defendant is Michelle M. Tishok, an adult individual, who has resided at 96 Tory Circle, Enola, Pennsylvania, since 1995. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 24, 1995 in Lexington Park, Maryland. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and his life burdensome. WHEREFORE, Plaintiff requests the court to enter adecree in divorce. COUNT 11- EQIJIT B E DISTRIBUTION 11. Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as set forth in full. 12. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from June 24, 1995 through the present, which property is "martial property." 13. Plaintiff and Defendant may have owned, prior to the marriage, property which has increased in value during the marriage and/or which has been exhcanged for other property, which has increased in value during the marriage, all of which property is "marital property." 14. Plaintiff and Defendant have been unable to agree as to an equitable division of the said property prior to the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property. 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 unworn falsification to authorities. Respectfully submitted, Date: e 2 Adams, Esquire No. 79465 117 South Hanover St. Carlisle, Pa. 17013 017) 245-8508 ATTORNEY FOR PLAINTIFF c^c^o _o ?.?-.r oils SCE s . cc)- gdcf `C 0 C'k bff S rF q s'td' P, e LLJ a EL ?; 1 ct? oc JOSEPH T. 7MITROVICH, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 99 - 5405 Civil Term. MICHELLE M. TISHOK, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE, AND NOW, this September 27, 2001, I, Jane Adams, Esquire, hereby certify that on September 21, 2001, a true and correct copy of the NOTICE TO DEFEND, COMPLAINT, AFFIDAVIT OF SEPARATION, AND PRAECIPE TO REINSTATE were served, via certified mail, restricted delivery, return receipt requested, addressed to: Michele Tishok c/o Fritolay 3553 Gillespi Drive York, Pa. 17404 DEFENDANT LD/No. 79465 I South h Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ??: :.% l?- 1.. ?'? li ??. _? t'J '.J ¦ Comi9ete items 1, 2, and 3. Also complete item 4 if ¦ t Print Your name and addr Delivery on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front it space permits. I. Article Addressed to: /;5iGAVA Vd . F?? >? ??y ,3SS3 6YI4 0,-, uA„G ?i / -Ili /-. i I O Express Mall ? Return Receipt for Merchandise rs rorm Jd11, July 1999 Domestic Retum Receipt , tozssssarknee f 1] Agent ? Addre 19 dell-y address digerent f om Rem 17 p? Yes II YES, enter delivery address below: F No JOSEPH T. ZMITROVICH, JR., Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5405 Civil Term. MICHELLE M. TISHOK, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 2, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verity that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: I - - I _ OD _ se h T. Z Arbvi-&, Plaintiff WAIVER OF NOTICE OF INTENTION \J TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(8) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verity 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 P&C.S. §4904 relating to unsworn falsification to authorities. Date: I - U Z_ Jo ph T. mitrgvic , Plaintiff - : ' r « - ;- ?`:. -" - ..: , -_? :.? ?? ,: . _ <; ?? MITROVICH, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 99 - 5405 Civil Term. MICHELLE M. TISHOK, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 19881. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 2, . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa S. 4904, relating to unsworn falsification to authorities. Date: Michelle M. Tishok, Defend WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 433011c1 OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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: Michelle M. Tishok, Defendant ? ,_ f: = ?? _ , ?:., r'.1 i_) 1 ? 7 .J '?- r-VL ;-"?'- V6. In the Court or Common Pleas of Cumberland County, Pennsylvania No. 6#0 Civil. 19 JC_- nn eta tN; J-e?d>.a ?? fP lu ,-Fr-?s ?lOlt Fo2 i To Prodtonoutry Attorney for Plaintiff I 4 Or C F vi a z O 4 U w Q a a I t I tJ i r r ?f5 JOSEPH T. ZMITROVICH, JR., Plaintiff VS. MICHELLE M. TISFIOK, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA 5y05 No. 99 - 3#M Civil Tenn. ACTION IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully submitted, Date: G , / IV 0/ a, . No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245.8508 ATTORNEY FOR PLAINTIFF V3 , ,. r .. 'IL; ? U _ JOSEPH T. ZMITROVICH, JR., Plaintiff VS. MICHELLE M. TISHOK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 99 - 5405 Civil Term. ACTION IN DIVORCE AFFIDAVIT OF SEPARATION The parties to this action separated on June 15, 1999 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that 1 may lose my rights concerning alimony, division of property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 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 unswom falsification to authorities. Date: 5 Jr., Plaintiff JOSEPH T. ZMITROVICH, JR.. Plaintiff vs. MICHELLE M. TISHOK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5405 Civil Term. ACTION IN DIVORCE PRAECIPE TO REINSTATF COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully Date: , lP . 01 Jan Adams, Esquire 1. D. o. 79465 4,L7 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?- N 3 ? _ .?. ? w>< , 4 7 t .• ..- z ? " i =;.?1.. ' ' z = ? u 7 L+?' ?D fl Vl L_ .? ? '-? r_? U JOSEPH T. ZMITROVICH, JR., Plaintiff VS. MICHELLE M. TISHOK, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 94 Civil Term. 99- ryos ACTION IN DIVORCE PRAECIPE TO REIN TATE COMPLAIN TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully submitted, Date: (Ja Adams, Esquire ] .No . 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ,k N ?- UO iL C ? h r ? C ? N 1 7 J, i jj cr1 U