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Home My WebLink About03-5161PAUL KEVIN CHRENCIK, PLAINTIFF VS. REBECCA SUSAN CHRENCIK, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.~ - £~6,1 CIVIL TERM CIVIL ACTION - LAW ACTION FOR DIVORCE / CUSTODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, ffyou wish to defend against the claims s~t 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 the Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 1-800-990-9108 PAUL KEVIN CHRENCIK, PLAINTIFF VS. REBECCA SUSAN CHRENCIK, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA ; : NO.~.~ _ ,~1 ~, t CIVIL TERM : : CIVIL ACTION - LAW : ACTION FOR DIVORCE / CUSTODY COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, PAUL KEVlN CHRENCIK, by and through his counsel Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and makes the following consolidated complaint in divorce for divorce and custody. 1. Plaintiffis PAUL KEVIN CHRENCIK, an adult individual, who resides at 1940 Market Street, Camp Hill, Cumberland County, Pennsylvania, 17011. The Plaintiff has resided in Cumberland County for over three (3) years. 2. Defendant is REBECCA SUSAN CHRENCH~, an adult individual, who resides at 362 North 29th Street, Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiffand Defendant were lawfully married on August 8, 1987. 5. There have been no prior actions of divorce or for annulment between the parties except this Complaint filed for divorce. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the court require the parties to participate in counseling. Plaintiff has chosen not to engage in, or to request any counseling. 8. Neither Plaintiff nor Defendant has ever been a member of the United States Military Services. 9. Plaintiff and Defendant have four (4) children from their marriage, KEVIN PAUL CltRENCIK, bom August 24, 1994; MICBAEL DAVID CltRENCIK, bom June 8, 1996; KATIE ELISE CItRENCIK, born June 29, 2002; and ASBLEY LAURA CltRENClK, bom June 29, 2002. COUNT I - REOUEST FOR NO-FAULT DIVORCE UNDER SECTION 330Hc) OF ~ DIVORCE CODE 10. thereto. 11. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference After ninety (90) days have elapsed fi.om the date of filing of this Complaint, Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiffbelieves Defendant may also file such an affidavit. WHF~REFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of filing of this Complaint, Plaintiff, PAUL KEVIN CItRENCIK, respectfully requests the court to enter a Decree of Divorce pursuant to section 3301(c) of the Divorce Code. COUNT H - REOUEST FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3~02(a~ OF THE~ DIVORCE CODE 12. thereto. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just alter consideration of all relevant factors. WltEREFORE, Plaintiff, PAUL KEVlN CItRENCIK, respectfully requests the Court to enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. COUNT Ill - REOUEST FOR CONFIRMATION OF CUSTODY UNDER SECTIONS 3104(a~2} and 3323(b) OF ~ DIVORCE CODE 14. thereto. 15. Defendant at this time: NAME KEVIN PAUL CtlRENCIK MICHAEL DAVID CHIIENCIK KATIE ELISE CHRENCIK ASm.EY LAURA CHRENCIK Paragraphs 1 through 13 of this Complaint are incorporated herein by reference The parties are the parents of the following minor children who reside with the AGE SEX DATE OF BIRTH 9 years Male August 24, 1994 7 years Male June 8, 1996 1 year Female June 29, 2002 lyear Female June 29, 2002 16. the addresses herein indicated: WITH WHOM Plaintiff and Defendant Defendant During the past three (3) years the children have resided with the parties and at ADDRESS 362 North 29t~ Street Camp Hill PA FROM / TO August 2000 to July 1, 2003 362 North 29th Street July 1, 2003 to Present Camp Hill PA 17. Plaintiff has not participated in any other litigation concerning the children in this or any other state. 18. There are no other proceedings pending involving custody of the children in this or any other state. 19. Plaintiff knows of no person not a party to these proceedings who has physical custody of the children or who claims to have custody, partial custody or visitation rights with respect to the children. 20. The best interests of the children will be served if Plaintiff and Defendam have Shared Legal Custody and Shared Physical Custody of their children. WItEREFORE, Plaintiff, PAUL KEV1N CBRENCIK, requests this Honorable Court grant Plaintiff, PAUL KEVIN CItRENCIK, and Defendant, REBECCA SUSAN CltRENCIK, Shared Legal Custody and Shared Physical Custody of the minor children, KEVIN PAUL CItRENC1K, MIClIAEL DAVID CItRENClK, KATIE ELISE CItRENCIK and ASi~II,EY LAURA CItRENCIIC Respectfiffiy submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Dated: SeptemberOgxO-~ 2003 .qmre PA I.D. # 64998 5021"a 42221 ed Suite 100 Mechanicsburg PA 17050 (717) 796-1930 VERIFICATION The undersigned hereby verifies that the facts averred in the foregoing document are true and correct to the best of his knowledge, information, and belief. This verification is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. PAUL KEVIN CHRENCIK PLAINTIFF REBECCA SUSAN CHRENCIK DEFENDANT IN ~iHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5161 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, October 03, 2003 _, upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Es~q. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 _ on Thursday, October 30, 2003 at I0:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to de£me and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be vresent at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all ealsting Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl~. FOR TIrE COURT~ By: /s/ Dawn S. Sund~,~!. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 REBECCA SUSAN ( PRAEC] AND NOW, v counsel, Susan Kay C~ requests to Withdraw Code in the above ma~ Dated: October~Tt'~, ~ 'HRENCIK, )EFENDANT : IN Ti~E COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 03-5161 CIVIL TERM : : CIVIL ACTION' - LAW : ACTION FOR DIVORCE / CUSTODY PE FOR WITHDRAWAL OF COMPLAINT mes the Plaimiff, PAUL KEVIN CHRENCIK, by and through his ndiello, Esquire, of the Law Firm of Susan Kay Candiello, P.C., and he Complaint for No-Fault Divorce under Section 3301(c) of the Divorce er Without Prejudice. )03 Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. PA I.D. 9,,.64998~/ 5021 East'r'fi-ffdle Road, Suite 100 Mechanicsburg PA 17050 (717) 796-1930 OCT ZOO3 PAUL KEVIN CHRENCIK Plaintiff VS. REBECCA SUSAN CH~NCIK Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 03-5161 CIVIL ACTION LAW IN CUSTODY ORDER AND NOW, this i 27TH day of October~ 2003 , the conciliator, being notified by counsel that the Complaifit in this matter is being withdrawn by the plaintiff, hereby relinquishes jurisdiction. The Custod34 Conciliation Conference scheduled for October 30, 2003 is cancelled. FOR THE COURT, D~S. Sunday, Esquire Ct Custody Conciliator cz ~ ~