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Home My WebLink About08-2816•A LAURA FARRELL POLOVINA Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERTLAND COUNTY, PENNSYLVANIA NO. 0-2008 - 1g?6, &?J 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 of 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 counseling. A list of marriage counselors is available at the Office of the Prothonotary at the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEED OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GTRANTED, 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 S. Bedford Street Carlisle, PA 17013 OANNE MARINO MC GREEVY ATTORNEY FOR PLAINTIFF -a. LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Q P-a -M %-2008 CIVIL ACTION-LAW IN DIVORCE COMPLAINT UND R SECTION 3301 c OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Joanne Marino McGreevy, Esquire, and seeks to obtain a Divorce from the above-named Defendant upon the grounds hereinafter set forth: I. Plaintiff, LAURA FARRELL POLOVINA, an adult individual who is sui juris and resides at 528 Doubling Gap Road, Newville, PA 17241. 2. Defendant is CHRISTOPHER POLOVINA, who is sui juris and resides at 2900 Cliff Drive, Newport Beach, CA 92663. The present whereabouts of the Defendant, Christopher Polovina, to the knowledge of the Plaintiff, is the same. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. To the knowledge of the Plaintiff, the Defendant has been a bona fide resident in the State of California for at least six (6) months immediately previous to the filing of this complaint. 5. The Plaintiff and Defendant were married September 30, 2006, in Carlisle, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the court require the parties to participate in counseling. 8. The Defendant is not currently member of the armed services of the United States or any of its allies. COUNT I REQUEST FORA NO-FAULT DIVORCE UNDER SECTION 3301 c OF THE DIVORCE CODE -.. 9. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. 10. After ninety (90) days from the date of the filing 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 FILING OF THIS COMPLAINT, PLAINTIFF RESPECTFULLY REQUESTS THE COURT TO ENTER A DECREE OF DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE., DATE f LAURA FARRELL POLOVINA PLAINTIFF JCl )7'`?•' t NNE MARINO MCGREEVYJ ATTORNEY FOR THE PLAINTIFF 137 S. West Street Carlisle, Pennsylvania 17013 717-243-0092 S.Ct. #47612 ,4w LAURA FARRELL POLVINA, : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. . 5-2008 CHRISTOPHER POLOVINA : CIVIL ACTION-LAW Defendant : IN DIVORCE 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. DATE LAURA FARRELL POLOVINA PLAINTIFF w o w a? ." Coo '/' LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 42008- (,c(,j CIVIL ACTION-LAW IN DIVORCE ENTRY OF APPEARANCE To the Prothonotary: Please enter my appearance as attorney of record for Laura Farrell Polovina, Plaintiff, in the above-captioned matter. I may be served as follows: Joanne Marino McGreevy Attorney at Law 137 S. West Street Carlisle, PA 17013 717-243-0092 My Supreme Court I.D. # is 47612. ZS'ncerely, ne Marino McGreevy CW3 +^? s? -n-A 9 ^:i'7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA t-PEUoe.R t=ARR Li (9oLov'1N -4 Plaintiff Vs File No. l o o k- a el" IN DIVORCE CLfletSnPtt£rL Pol. oV1 A/q Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the lin the above matter, [select one by marking "x' j r/ prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated M 4 Ll Z° 11,49' hereby elects to resume the prior surname of F Iq R 12 ELL , and gives this written notice avowing his /(6)ntention purs t to a provi ' of 54 P.S. 704. Date: Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OFC?ymWki ? On the -frI4 day of_ 200 8 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that bt-./ she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. 11 COMMONWEALTH OF PENNSYLVANIA Notary Public NOTARIAL SEAL DEBRA L. 8VAGERT, NOTARY PUBLIC SOUTH MIDDLETON TWP., CUMBERLAND COUNTY MY COMMISSION EXPIRES JUNE 26, 2010 it ?A V3 r? s n ON C- --.r_ LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.9,04-;Op 8--2MT CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Joanne Marino McGreevy, Esq., hereby certify that on the date indicated below I did serve true and correct copies of the Divorce Complaint attached hereto, Defendant's copy of an Affidavit of Consent and Defendant's copy of a Waiver of Notice of Intention to Request Entry of Divorce Decree by depositing copies of same in the U.S. Mail, Postage prepaid, at Carlisle, PA, by regular mail, addressed to and requiring an Acceptance of Service receipt from: CHRISTOPHER POLOVINA 2900 CLIFF DRIVE NEWPORT BEACH, CA 92663 DATE: 2,,o Y L=?_ 7,hw_? ! 2LC Joanne Marino McGreevy 137 S. West Street Carlisle, PA 17013 717-243-0092 Attorney for Plaintiff ra ? C bra LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO..7o o 9- Sr- ' a 0' / J(- CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the complaint in divorce. I certify that I am authorized to accept service on behalf of the Defendant. DATE: Defendant ot At-24.11"i Mailing Address IU63 C"3 ca -rt t f f :i? Y CJ"? *.:a i..Y LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 200 Z 5-299$ CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on MAC 2oo? 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the complaint. 3. I consent to 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 herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. DATE: /Od (Plaintiff) 4D*€t) r - 0 Nra ct:? LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. .'t. o a g 2-4*0- CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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, lawyer's 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 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: 8 `f la'? (Plaintiff) (Hefencmt) l ci w LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. .2 00f 5.2998- CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing and service of the complaint. 3. I consent to 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 herein ar a subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to ties. DATE: / 0 '°`'' i ?. ° --t cn Ln °y- n ? caj LAURA FARRELL POLOVINA, Plaintiff V. CHRISTOPHER POLOVINA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. a. v o 1 .5-2998 ;- k ls° CIVIL ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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, lawyer's 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 Pa.C.S. §4904 relating to unsworn falsification to authorities. DATE: 9/`} to ( (Defendant) a ^crw.. r ?w ??.? t I- A U tZ A f- A- 212£. L L PoL-0VIAtA VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION C kf 12 I s 7-01P /t-t.-PZ . NO. ,2DO?"? $/(o CIVIL TERM PRAECIPE TO TRA.NSNUT 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 3301 (c) -3M f* (1) of the ivorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: ?9 a , 2-0 a k F/2sT CL-A-SS M41L 4 CCf-l DAVCE 0P Smy1C£. 3. Complete either paragraph (a) or (b). OV:k?V 04AZ 7' a. Date of execution of the affidavit of consent required by 3301 (c) of the Divorce code: by plaintiff g l y l O k ; by defendant 8 I y p 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: NO A14F 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 plaintiffs Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: hta" h Attorney for PlaintiffAkfendmit-- U ,n C=2 ^rJ ?? " ac ? ? y . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. p o_u_rcj.- "acrd i r01o Vr r-a 10i ca w4rf-?* VERSUS C k r? s+ o e k Lr Po' n y i Ala N 0. DECREE IN DIVORCE AND NOW, A 04 0 Z0. 05i, IT IS ORDERED AND C) I DECREED THAT 4-cLur'LL FQrre- It PoIQ I-l& PLAINTIFF, AND (, Rr{ S+d e ke-r Po 'U V 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 YET BEEN ENTERED; None- BY THE COURT: PROTHONOTARY -r744.4, ,W - &o -,S rw-ow - p- zem);x,w ?V-vw -I-jeow -,ep