HomeMy WebLinkAbout99-06316IN THE COURT OF COMMON PLEAS
y
OF CUMBERLAND COUNTY
f
r STATE OF + PENNA.
JOAN L. ZNANIECKI,
Plaintiff ?u._9.9-631.6 ... .................
\'??rsus
LARRY S. ZNANIECKI,
Defendant
DECREE IN
DIVORCE
Y AND NOW,.... S4 2F, M. 2D.4Q it is ordered and
decreed that . JQAK .4..fKANIECKI ............................ plaintiff,
and .. -4ARRX .6.. Z.NANUCKI .................................. defendant,
are divorced from the bonds of matrimony.
r 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
r been entered;
NONE
..., .....................
0y 7 to Co 'r1
Attest: ? J.
Pr, honotary
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JOAN L.'ZNANIECKI,
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
LARRY S. ZNANIECKI, CIVIL DIVISION
Defendant
NO.99-6316 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following Information to the court for entry of a divorce decree:
Ground for divorce:
Irretrievable breakdown under §3301(c)
3301(d)(1) of the Divorce Code.
(Strike out Inapplicable section).
2. Date and manner of service of the complaint: Certified mail return receipt
requested - Restricted Delivery on 10/10199
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code:
by plaintiff 9114/2000 ; bydefendant S/1/2o00
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending: None
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:
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: S441?, / ' Pane)
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary:
Atf n for Plaintiff /JLiwQHISt
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JOAN L. ZNANIECKI,
Plaintiff
VS.
LARRY S. ZNANIECKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-431G
IN DIVORCE
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,
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
(717) 249-3166 n!
Anthony L. DeLuca, Esquire O
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
JOAN L. ZNANIECKI, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
LARRY S. ZNANIECKI, NO. q 9. L3J6
Defendant
DIVORCE COMPLAINT
AND NOW, comes the Plaintiff, JOAN L. ZNANIECKI, by her
Attorney, Anthony L. DeLuca, Esquire, and seeks to obtain a Decree
in Divorce, from the above-named Defendant, upon the grounds
hereinafter more fully set forth:
1.
Plaintiff is JOAN L. ZNANIECKI, who currently resides at 33
High Street, p.o. Box 281, Boiling Springs, Cumberland County,
Pennsylvania since June, 1976.
2.
Defendant is LARRY S. ZNANIECKI, who currently resides at 153
Morningside Drive, Falling Waters, West Virginia 25419, since
Dacember, 1997.
3.
Plaintiff has been a bona fide resident of the Commonwealth
for at least six months immediately previous to the filing of this
Complaint. •,
4.
The Plaintiff and Defendant were married on January 131 1978
at Carlisle, Cumberland County, Pennsylvania.
I 0j
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 have been no prior actions of divorce or for annulment
between 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.
COUNT I
REQUEST FOR A NO-FAULT DIVORCE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE
S.
The prior paragraphs of this complaint are incorporated herein
by reference as though set forth in full.
9.
The marriage of the parties is irretrievably broken.
10.
After ninety (90) days have elapsed from the date of the
filing and service of this Complaint, Plaintiff intends to file an
affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an affidavit.
WHEREFORE, if both parties file affidavits consenting to a
divorce after ninety (90) days have elapsed from the date of the
filing of this complaint, the Plaintiff respectfully requests the
Court to enter a decree in divorce pursuant to Section 3301 (c) of
the Divorce Code.
REQUEST FOR A FAULT DIVORCE UNDER
SECTION 3301 (a) (6) OF THE DIVORCE CODE
11.
The prior paragraphs of this Complaint are incorporated herein
by reference as though set forth in full.
12.
Defendant has offered such indignities to Plaintiff who is the
innocent and injured spouse as to render Plaintiff's condition
intolerable and life burdensome.
13.
This action is not collusive as defined by Section 303 of the
Divorce Code.
WHEREFORE, Plaintiff respectfully requests the Court to enter
a decree of divorce pursuant to Section 3301 (a) (6) of the Divorce
Code.
COUNT III
EQUITABLE DISTRIBUTION
14.
The prior paragraphs of this complaint are incorporated herein
by reference as though set forth in full.
15.
Plaintiff and Defendant have acquired property, both real and
personal, during their marriage until gecember 31,1997, the date of
their separation.
16.
Plaintiff and Defendant have been unable to agree as to an
equitable distribution of said property.
WHEREFORE, Plaintiff prays for the entry of an Order
distributing all of the aforementioned property, real and personal,
as the Court may deem equitable and just, plus costs.
COUNT III
ALIMONY
17.
Paragraphs 1 through 16 of this complaint are incorporated
herein by reference as though set forth in full.
. el
18.
Plaintiff lacks sufficient property to provide for her
reasonable means and is unable to support herself through
appropriate employment.
19.
Plaintiff requires reasonable support to adequately maintain
herself in accordance with the standard of living established
during the marriage.
WHEREFORE, Plaintiff requests your Honorable Court to enter an
award of reasonable temporary alimony until final hearing and
permanently thereafter.
Respectfully Submitted,
Anthony L1 eLUca, Esquire
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
(717) 258-6844
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VERIFICATION
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 unsworn
falsification to authorities. f '
Date: Joan L. 2 #niecki, Plaintiff
JOAN L. ZNANIECKI, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION -LAW
LARRY S. ZNANIECKI, NO. 99-6316
Defendant : IN DIVORCE
1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on
October 15, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of final decree of divorce after service of notice of intention to
request entry of the decree.
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. Sec. 4904 relating to unworn
falsification to authorities.
Dale:
L#ry S. Znani Defendant
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JOAN L. ZNANIECKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
LARRY S. ZNANIECKI,
Defendant
CIVIL ACTION - LAW
: NO. 99-6316
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyers
fees or expenses if I do not claim them before a divorce is granted.
3. I 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 P&C.S. §4904 relating to unswom
falsification to authorities.
Date:
L6iTy S. Znaniecki, Defendant
. .
JOAN L. ZNANIECKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
LARRY S. ZNANIECKI,
Defendant
CIVIL ACTION - LAW
: NO. 99-6316
: IN DIVORCE
1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on
October 15, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of final decree of divorce after service of notice of intention to
request entry of the decree.
1 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. Sec. 4904 relating to unswom
falsification to authorities.
Date: 9- lq- Od "` ,crccc<<,Ec
Joan L. Znanieckr Plaintiff
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JOAN L. ZNANIECKI,
Plaintiff
VS.
LARRY S. ZNANIECKI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6316
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. 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.
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 arc made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
falsification to authorities.
Date: - -Gv ,zit 1?,uQe?
1 an6 L. Znaniec , Plaintiff
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JOAN L. ZNANIECKI,
Plaintiff
VS.
LARRY S. ZNANIECKI,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
NO. 99-6316
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF CUMBERLAND
SS.
Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says
that he mailed by certified mail, return receipt requested, a true and correct copy of the
Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Defendant at his
residence and that Defendant did receive same, as evidenced by the signed receipt attached
hereto as Exhibit "A".
By. ; 41
Anthony L. DeL quire
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
(717) 258-6844
'e, c_a'
otary Public
Sworn to and subscribed
before a this /101day
of 4X.4,, 2000.
NOTARIAL SEAL
MARJORIE A. DeLt1CA, Notary Public
SaAh Middleton Twp. Cumb ftW Co.
CommissW Ex ies Nov. i.=
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