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Home My WebLink About03-4999Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumbcrland County, Pennsylvania :No. OJ--t../q*lq ~ ~ :Complaint in Divorce NOTICE TO DEFEND AND CLAIM RIGHT You have been sued in court. If you wish to defend against the claims sct 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 for any other claim or relive requested in these papers by the Plaintiff. You may lose money or property o~ other fights important to you, including custody or visitation of your children. When the ground for divorce is indigr, ities or irretrievable breakdowu of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Proth,motary, Cumberland County Courthouse, I Courthouse Square, Carlisle, PA. If you do not file a claim 1hr 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 [~ lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. Court Administrator Cumberland County Court House 4th Floor 1 Courthouse Square Carlisle, PA 17013 717-240-6200 Respectfuy submitted Eli M Kosanovich 5345 Oxford Circle #62 Mechanicsburg, PA 17055 717-691-4169 Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumberland County, Pennsylvania : :No. : :Complaint in Divorce COMPLAINT UNDER SECTION 3 301 (c) OR SECTION 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Eli M. Kosanovich, who currently resides at 5345 Oxford Circle #62, Mechanicsburg, Cumberland County, Pennsylvania, 17055 2. Defendant is Valeric M. Kosanovich RN, who currently resides at 7549 Stonebrook Parkway #211 I, Frisco, Collin County, TX 75034 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on 1 November 1998 in Denver, Colorado. 5. Plaintiff avers that there are no children of the parties. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriagc is irretrievably broken. 8. Plaintiffunderstands that counseling is available and Plaintiff bas the right to request that the Court require the parties to participate in counseling. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on 1 February 2003 11. Plaintiff requests the Court to enter a Decree of Divorce. 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. Section4904 relating to unsworn falsification to authorities. DATE: PLAINTIFF: li~M ~o~Ta~ovich Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumberland County, Pennsylvania :Complaint in Divorce ACEPTANCE OF SERVICE I accept service of the following documents relative to the Complaint listed above: NOTICE TO DEFEND AND CLAIM RIGHT COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301 (d) OF THE DIVORCE CODE MARITAL SETTLEMENT AGREEMENT AFFIDAVIT OF CONSENT WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION3301 (c) OF THE DIVORCE CODE DATE: DEFENDANT: ~J(.tb2-~- tt.~. },/6~a~';o.o,~J~'P~) Valede M. Kosanovich RN 7549 Stonebrook Parkway #2111 Frisco, Collin County, TX 75034 Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court: of Common Pleas :Cumberland County, Pennsylvania :Complaint Ln Divorce : , T AFFIDAVIT OF CONSEN A complain in divorce under Section 3301 (c) of the Divorce Code was filed on: The marriage of the plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of diw)rce after service of notice of intention to request entry of the decree. I verify that the ~;tatements made in this affidavit are true and co::rcct. I understand that false statemeni:; herein are made subject to the penalties of 18 Pa. C.S. Section4904 relating to unsworn falsification to authorities. DATE: (et ..V~I-C~ PLAINTIFF: Eli M Kosanovich 5345 Oxford Cimle #62 Mechanicsburg, PA 17055 Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumberland County, Pennsylvania :No. : :Complaint in Divorce AFFIDAVIT OF CONSENT 1. A complain in divorce under Section 3301 (c) of the Divorce Code was filed on: 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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 h~ tin are made subject to the penalties of 18 Pa. C.S. Section4904 relating to unswom falsification to authorities. DATE: q--~t-03 DEFENDANT: Valerie M. Kokan6vic~ RN 7549 Stonebrook Parkway #2111 Frisco, Collin County, TX 75034 Eli M Ko?,anovich, Pl,,dntiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumberland L~mn y, Pennsylvania :No. ~)$ "4~'~qq Ctw,- rtt~ :Complaint in Divorce WAIVER OF NOTICE OF INTENT TO REQUES~I ENTRY OF A DIVO,~CE DECP. EE UNDER SECTION '301 (c) OF THE DIVORCE CODi; 1. I consent to the entry ora final decree of divorce without notice. I understand that I may lose rights con,:crning alimony, &wsmn of property, lawyer fees or expense.; if l d,; not claim th,~rn before a divorce is granted.. l und..rstand,~ that' I will not be divorced until a divorce dc'crc is entered by the Court and that a copy of the decree will be sent to mc immediately after it is flied with thc Prothom~;: 'y. I verify that the statements made in this affidavit arc true and correct. I understand that falsc sLatenJents herein are made subject to the l; nalties or' 18 Pa. C.S. Section4904 relating to unsworn falsification to authorities. DATE: ~. ~ ~qr'C~'~ PLAINTIFF: Eli M Kosanovich 5345 Oxford Circle #62 Mechanicsburg, PA 17055 Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumberland County, Pennsylvania :No. -A 'x°l C :Complain'i in Divorce : WA1VER OF NOTICE OF INTENT TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 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.. 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 aller it is filed with the Prothonotary. I verify that the statements made in this affidavit are trne and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section4904 relating to unswom falsification to authorities. DATE: q - ~ I -0.3 DEFENDANT: {//F~_.X_. ~t4 ,]~6~Dt'/,~cq4//~ ?JO Valerie M. Kos~anovich RN 7549 Stoncbrook Park way #2111 Frisco, Collin Co'anty, TX 75034 MARITAL SETTLEMENT AGREEMENT Eli Michael Kosanovich, referred to herein as HUSBAND, of 5345 Oxford Circle #62, Mechanicsburg, Cumberland County, PA 17055 Valerie Marie Kosanovich RN, referred to herein as WIFE, of 7549 Stonebrook Parkway #2111, Frisco, Collin County, TX 75034 The parties were lawfully married on 1 November 1998 in Deny :r, Denver County, Colorado. There are no children born of th': parties' mar iage. Difficulties have occurred between the parties, and ti~:y have agreed to permaner~tly !ive s:;parate and apart from each other. The p~: ',i3s .';eparated on 1 Febn~ary 2003. The parties intend by this agr 'ement to fully and fir~,:~l~ ' :;ettle all of their respective rights and obligations as between each other, inch~¢, ,.,j .~ut not limited to the settling of all interests, rights and/or obligations between them or ~heir estates, whether arising out of ~heir marriage, including assets ,:cqdir,-'~d by either party prior to or subsequent to the date of execution of this The parties may seek legal advisors of their own choice regarding their legal rights and any disclosures made herein. The parties have made a complete disclosure to o]~o another of financial matters and each is satisfied that they have had sufficien[ disclosure of the parties' individual and joint finances. The parties held no debt at the time of separatio~. Either party shall fully assume 'my debt they may have incurred since sep~ration, r~¢:d hoM [he othe~ party harmle.:s from the same. The parties agree to fi!3 '[-heiJ' Federal Income Tax return for the tax year 2003 as "Married, Filing Separate~ fy" with each party being responsible for any tax debt owed to IRS f~r th~' Personal property of the parties had been equitr~bly divided upon separation. Var!ous small personal effects may later be id,_,~tii~ied a;qd ::hall be returned to the rightful party. HUSBAND shall be responsible for the filing of ~'equired documents and costs necessary to obtain a divorce decree pursuant to relative Pennsylvania laws. HUSBAND shall maintain health insurance coverage for the WIFE, as provided by his current employer (TYCO) for 30 (thirty) days following the final divorce date. WIFE shall file the necessary documents to legally change her last name from KOSANOVICH following the final divorc6~ date. HUSBAND and WIFE hereby sp.3cifically release and waLve any and all interest, claim, or right that he/she may hav '., to any and ~ll retirement benefits (including pension or profit sharin(j benefits) or other similar benefits of the other party. The parties shall execute any documents pursuant to the Retirement Equity Act or any similar Act that may be required from time to time to accemplish the purpose of this paragraph. HUSBAND and WiFE each have sufficient property and/or income to provide for his/her reasonable needs. There;ore, HUSBAND and WIFE expressly waive, di:~charge and re~ease any and all rights or claims which he/she may have, now or hereafter, by reason the pa es ri;ar;lags, to alimony, st~pport, maintenance and/or other such benefits resul~, ~g from tho ~arties' status as husband and wife. Each party acknowledges hav~qg rcceivod a fully execut 't original of [his Agreement. In witness thereof, the ca,ties hereto have set ti~eir hands and seals. Dated: '7_JO September 21 }3 El;Michael Ko/~/~~.~ HUSBAND _ Witness acs to HUSBAND: Commonwealth of Pennsylvania, County of Cumberland On this ~__ day of Septe ,~ber 2003, before me, a Notary Public for the Commonwealth of Pennsylvania, residing in Cumberland County, p ;rsonally appeared Eli M Kosanovich, known or proven to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. in witness whereof, I have hereun!o set ~//~ ~ and official seal. ' ,¢N~t~ ry,.l~ blic Lowe~ Alien Twr;., Cu~eberland My Oorrlrnlsslofi Expires Mar, 28, Valerie Marie Kosanovich RN, WIFE ~/~ ~.~. ~e.~c~,~o~c]~ ~7-.~ Witnesses a~ State of Texas. County of ~'/"~./'~ On this '2.'~ d; of September 2003, before me, a Notary Public for the State of'l-e~;a~"7 re Jing in_ ~/,~,',- County, personally appeared Valerie M Kos:u, ,ovich, known or proven to me to be the person M:ose name is subscribod to the within Apreement and acknowledged that she executed the samo for the purpos'~.s therein contained. In witness whereof, I, av. i :;reunto set my hand and official seal. Eli M Kosanovich, Plaintiff Valerie M Kosanovich, RN Defendant :In the Court of Common Pleas :Cumberland County, Pennsylwtnia : :No. O3-qqqq :Complaint in Divorce PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following intbrmation to the Court for entry of a divorce decree: 1. Ground of divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Service of the complaint in accordance with Rule 1930.4 (d) of the Divorce Code. D.~te plaintiff's Acceptance of Service was filed with Prothonotary: 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff tax ~3eel' C,J : by Defendant: 4. Related claims pending: NONE 5. Marital Settleme~t AgreemenI; between the parties to be incorporated, but not merged into the Decree of Divorce 6. Date plaintiff's Waiver of Notice was filed with Prothonotary: lax Da'.e defendant's Waiver of Notice was filed with Prothonotary: I.~. ecrr~, Respectfitlly submitted, Eli M Kosanovich 5345 Oxford Circle #62 Mechanicsburg, PA 17055 717-691-4169 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF _~,,~,:.,. PENNA. NO. Aq~ CW~L VERSUS PLEAS DECREEIN AND NOW, DECREED THAT AND , IT IS ORDERED AND ~"~' ('~ ~;ll:~'r4 0~/t ~--- L/ ,PLAINTIFF, 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; BY THE COURT: ROTHONOTARY