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Home My WebLink About99-06837V \ l f S C$;5.1-I i'cn.icnvl IUI<.cnn I PIS. 4'12. jS I'M APRIL MARIE TAYLOR \9EROVICl1, Plaintiff Vs. DYLAN"ITIONIAS MEROVICII, Defendant IN'11II:C'OUR'I'OPC'O\1\10\ PLEAS CU\IBERLAND000NTY, PENNSYLVANIA NO. 99.6817 Civil Turin CIVIL ACTION - DIVORCE CF.RTI FICATE OF SERVICE I, Heather D. Royer, Esquire, attorney Iilr Plaintiff, April \9aric'faylor \lcrovich, do hereby certify that I served a true and correct copy, of the Complaint in Divorce upon the Defendant in the above captioned matter by depositing it in the United States mail, certified, restricted delivery, return receipt rcqucstcd, addressed as follows: Dylan Thomas Merovich 2459 County Line Road York Spring, PA 17372 The signed return receipt card is attached hereto. SMIGEL,ANDERSIDN & SACKS Date: Heather D. Royer, E. 1fnru? LD.II 76327 `// 1917 North Front Street flar-risburc. PA 17110 (717) 234-2401 Attorney for Plaintiff m SENDER' lalsowishtoreceivethefollow- °_ m OCanplele camel arxUor2ter additional services. in9 services (for an extra lee)' 0 Complete items 3. 4a, and 4b. p Peal your name and address on the rB,em of this loan so that we can Main INS (3 Addressee's Address `m cardtoyou. O Altach this inn to ON front of the hr,itoce. or on the back if Space dose not 21st Restricted Delivery p permit. i°" c aWeis -Refum Receipt Requested' on the mailpiew below the aNdo number. 0 The Return Receipt %ill slow to whom the aside was delivered and the dale p delvered. v 3. Article Addressed to: 4a. Article Number t 1 1o p ?,S1a r\ h qb. Service Type 0 L;.._. IQc? ? Registered Certified ? Express Mail ?Insured L}yii riaq I ? Return Receipt far merchandise ?COD 5. Received U Plee is paid) 0 %F1I IM59&W. -0223 Z N m ar 0 m n, 0 T Y C APRIL MARIE TAYLOR NIEROVICII PLAIN H-T- `r DYLANTIIONIAS MEROVIC'1I, DEPENDANT IN T IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - DIVORCE NO'T'ICE TO DEFEND.kND CLAIM RTGNTS YOU HAVE BEENSUED IN COUR'T'. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You arc wanted that if you fail to do so, the case may proceed avithoul you and a decree of divorce or annulment may 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 I-or 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, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL&IENI' IS GRANTED, YOU MAY LOSE TIIE RIGHT TO CLAIM ANY OFTHEII. 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 IIELP. CUMBERLAND COUNTY BAR ASSOCIATION TWO 1.1 BERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Conunon Pleas of C•umbcrl:md County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and t'easotuable acconunodmtions available to disabled individuals having business before the Court, please contact our office. All arrangemcnh must be made at least 72 hours prior to any hearing ofbusincss before the Court. 5525.141DI%'OltC'CCO\II'LAIN17111)lUerni 11:8/992:211'.\1 APRIL MARIE TAYLOR MEROVICH, PLAINTIFF V. DYLAN THOMAS ML•ROVICI1, DEFENDANT IN TI-IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(4) OFTHE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plainti ff, April Maric Taylor Merovich, by her attorneys, SMIGEL, ANDERSON & SACKS, and represents as follows: COUNTI DIVORCE UNDER SECTION 3301(c) OR 3301(d) OFTHE DIVORCE CODE Plaintiff is April Maric Taylor Merovich, who currently resides at 506 West Main Street, Mechanicsburg, Pennsylvania and has resided there since on or about February 18, 1999. 2. Plaintiffs Social Security No. is 209-66-9574. 3. Defendant is Dylan 'Thomas Merovich, who currently resides at 2459 County Line Road, York Springs, Pennsylvania and has resided there since on or about March 1998. 4. Defendant's Social Security No. is 210.60-4677. 5. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the tiling of this Complaint. 6. The Plaintiff anti Defendant were married on September 7, 1996, in York County, Pennsylvania. 7. There have been no prior actions of clivorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT If EQUI'T'ABLE DIS'T'RIBUTION 10. Plaintiff repeats and rcalleges the averments of paragraphs I through 9 which are incorporated by reference herein. 11. Plaintiff and Defendant possess various items of both real and personal marital property which arc subject to equitable distribution by this Court. WHEREFORE, PlaintifTrequcsts this Court to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. SMIGEL, ANDERSON S SACKS Date: 13y: l/ I (TLl_tL (: HEATHER D. ROYE R;CSQ DIRE I.D. ##76327 11 2917 NORTH FRONT-STREET HARRISBURG, PA 171 10 (717) 234-2401 ATTORNEYS FOR PLAINTIFF 1) - VGRII_ ?CAIIp- f verify that the statements made in this Complaint are true and correct, f understand shat false slatemenls herein are made subject to the penalties of I S Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: April Marie Taylor i?tcro' ich, Plaintiff ,. -.'; , ; y... i APRIL MARIE TAYLOR MEROVICH, PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6837 Civil Term DYLAN'ri-IONIAS MEROVICI I DEFENDANT CIVIL ACTION- DIVORCE ACCEPTANCE OF SIsRVICE 1, Dylan Thomas Merovich, Defendant in the above-referenced action, accept service of (lie Complaint in Divorce filed on November 12, 1999. Dater- 1- b(0 D ' A T O? S NIEROVICH