Loading...
HomeMy WebLinkAbout04-0352VERA JIRASKOVA, Plaintiff PETR JIRASEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- CIVIL ACTION ~ LAW 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 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR 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 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, Pennsylvania 17013 Telephone (717) 249-3166 VERA JIRASKOVA, Plaintiff PETR JIRASEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- .~6~,7~ CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Vera Jiraskova, who currently resides at 511 Highland Court, Carlisle, Pennsylvania 17013. 2. Defendant is Petr Jirasek, who currently resides at 511 Highland Court, Carlisle, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 13, 1991 in Kostelec nad Orlici, Czech Republic. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the fight to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Sh6nahafi, Esquire Attorney ID No. 90917 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: January 28, 2004 VERIFICATION I verify that the statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unswom falsification to authorities. Vera Jiraskova VERA JIRASKOVA, : Plaintiff : V. : PETR JIRASEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04- 359 CIVIL ACTION - LAW 1N DIVORCE ACCEPTANCE OF SERVICE I, Petr Jirasek, Defendant in the above divorce action filed in the Court of Common Pleas of Cumberland County, hereby accept service of said Divorce Cmnplaint on the 20 day of January, 2004. Petr Jirasek ?'¢~ ~ff~-'-~T~ 511 Highland Court Carlisle, PA 17013 CERTIFICATE OF SERVICE I, Steven J. Shanahan, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Acceptance of Service was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Petr Jirasek 511 Highland Court Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Steven J. S'hanahan Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: February 2, 2004 VERA JIRASKOVA, : Plaintiff : PETR JIRASEK, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-352 CIVIL ACTION - LAW 1N DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 28, 2004. 2. The marriage of Plaintiffand 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 a final decree of divorce. 4. I understand that I may lose rights concerning alitnony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. Date: April 29, 2004 Vera Jira~skova, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(e) AND § 3301(d) OF THE DIVORCE CODE 1. 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, lawyers fees or expenses ifI 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 mad waiver are tree 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: April 29, 2004 Vera Jir~kowa, Plaintiff CERTIFICATE OF SERVICE I, Steven J. Shanahan, an authorized agent for Martson D,eardorff Williams & Otto, hereby certify that a copy of the foregoing Affidavit of Consent and Waiver of Notice was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Petr Jirasek 511 Highland Court Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Sh/anahan Ten East High :Street Carlisle, PA 17013 (717) 243-3341 Dated: May 3, 2004 VERA JIRASKOVA, Plaintiff PETR JIRASEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-352 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of' the Divorce Code was filed on January 28, 2004. 2. The marriage of Plaintiffand 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 a final decree of divorce. 4. I understand that I may lose rights concerning ali aaony, division of property, lawyer s fees or expenses ifI do not claim them before a divorce is granted. Date: April 29, 2004 Petr~/irasek, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301(d) OF THE DIVORCE CODE 1. 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, lawyers fees or expenses ifI 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 atier it is filed with the prothonotary. I verify that the statements made in this affidavit mad waiver 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: April 29, 2004 Petr~irasek, Defendant CERTIFICATE OF SERVICE I, Steven J. Shanahan, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Affidavit of Consent and Waiver of Notice was served this date by depositing same in the Post Office at Carlisle, PA, first class tnail, postage prepaid, addressed as follows: Mr. Petr Jirasek 511 Highland Court Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Shanahan Ten East High Street Carlisle, PA 17'013 (717) 243-3341. Dated: May 3, 2004 CERTIFICATE OF SERVICE I, Steven J. Shanahan, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Affidavit of Consent and Waiver of Notice was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. Petr Jirasek 511 Highland Court Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Shanahan Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: May 3, 2004 CERTIFICATE OF SERVICE I, Steven J. Shanahan, an authorized agent for Mar[son Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe to Transmit was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Petr Jirasek 511 Highland Court Carlisle, PA 17013 MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Shanahan Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: VERA JIRASKOVA, Plaintiff Vo PETR JIRASEK, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-352 CIVIL ACTION - LAW 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Defendant signed an Acceptance of Service on January 29, 2004, and it was filed in the Court of Common Pleas of Cumberland County on February 2, 2004. 3. Date of execution of the Plaintiffs affidavit of consent required by Section 3301 (c) of the Divorce Code; April 29, 2004; by the Defendant; April 29, 2004. 4, Related claims pending: none. 5. Date PlaintiWs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 3, 2004, a copy of which is attached. 6. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 3, 2004, a copy of which is attached. Date: MARTSON DEARDORFF WILLIAMS & OTTO Steven J. Shanahan, Esquire Attorney ID No. 90917 Ten East High Street Carlisle, PA 17013 (717) 243-3341 At(orneys for Defendant iN THE COURT Of COMMON PLEAS OFCUMBERLAND COUNTY STATE OF PENNA. VERA JIRASKOVA 04-352 VERSUS PETR JIRASEK DECREE IN DIVORCE And NOW, ~ ~ -)~-~ 2004 , IT IS ORDERED AND DECREED THAT VERA JIRASKOYA , PLAINTIFF, AND PETR JIRASEK , 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 THE CO. YET BEEN ENTERED; PROTHONOTARY