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Home My WebLink About04-1416 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODY L. MAJESKIE, Plaintiff KALVIN A. MAJESKIE, Defendant No. 2004 _]q[(o (Civil Term) : CIVIL ACTION - LAW (In Divorce) NOTICE 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 in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, Carlisle, Pennsylvania. W YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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, Pennsylvania 17013 (717) 249-3166 Date: ff~,l~ SAIDIS, SHUFF, FLOWER & LINDSAY Lindl/ay Ginl~ch Mhclay, Esquif. e~ ~/~upreme '~ / Court ID # 87954 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODY L. MAJESKIE, Plaintiff KALVIN A. MAJESKIE, Defendant No. 2004 - iqJt, (Civil Term) CIVIL ACTION - LAW (In Divorce) COMPLAINT UNDER SECTION 3301(c) OR 330Hd) OF THE DIVORCE CODE SAIDIS Sh'UFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA COUNT I - DIVORCE 1. Plaintiff is Jody L. Majeskie, who currently resides at 1786 Rockledge Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Kalvin A. Majeskie, who currently resides at 8714-21 Pinnacle Cross Drive, Huntersville, North Carolina. 3. Plaintiff, Jody L. Majeskie, has been a bona fide resident of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Defendant, Kalvin A. Majeskie, is agreeable that this matter shall proceed in Cumberland County, Pennsylvania, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Wisconsin. 6. 2000. 7. parties. Plaintiff and Defendant were married on July 12, 1980, in Hubertus, Plaintiff and Defendant have been living separate and apart since July 15, There have been no prior actions of divorce or for annulment between the 8. Plaintiff, Jody L. Majeskie, has been advised of the availability of marriage counseling and the Plaintiffmay have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. See Plaintiff's Affidavit attached hereto as Exhibit "A" and incorporated herein by reference. 9. The marriage is irretrievably broken. The foregoing facts are averred under Sections 3301 (c) or 3301 (d) of the Divorce Code of 1980, as amended. WHEREFORE, Plaintiff requests Your Honorable Court enter a Decree in Divorce, thereby divorcing Plaintiff and Defendant from the bonds of matrimony. COUNT II - EOUITABLE DISTRIBUTION 10. The allegations in Paragraphs One through Nine, inclusive, are made a part hereof and incorporated herein by reference. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. WHEREFORE, Plaintiff requests this Honorable Court determine the extent of the marital assets and liabilities and order an equitable distribution thereof. By: Respectfully submitted, SAIDIS, SHUFF, FLOWER & L1NDSAY 26 West High Street Carlisle, PA 17013 (7 l 7) 243 -6222 Attorneys for Plaintiff SAIDIS SHUFF, FLOWER & L1NDSAY 26 W. High Street Carlisle, PA AYFIDAVIT I, Jody L. Majeskie, being duly sworn according to law, depose and say: (1) I have been advised of the availability of manfage counseling and understand that I may request that the court require that my spouse and I participate in counseling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. J~y L IV~jeskie, Plaintifffd SAIDIS SHUFF, FLOWER & L1NDSAY 26 W. High Street Carlisle, PA VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Dated: _ . .Z ~-"J~ L. ~ajeskie, Plaint~ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Stree! Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODY L. MAJESKIE, Plaintiff KALVIN A. MAJESKIE, Defendant bio. 2004 - 1416 (Civil Term) CIVIL ACTION - LAW (In Divorce) ACCEPTANCE OF SERVICE I, Kalvin A. Majeskie, Defendant in the above-captioned matter, hereby accept service of the Complaint in Divorce, which was filed on April 2, 2004. Dated: ~__~04 By: 8714-21 Pinnacle Cross Drive Huntersville, North Carolina 28078 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JODY L. MAJESKIE, Plaintiff KALVIN A. MAJESKIE, Defendant No. 2004 - 1416 (Civil Term) CIViL ACTION - LAW (In Divorce) PRAECIPE TO WITHDRAW~ DISCONTINUE and END TO THE PROTHONOTARY: Upon instruction of Plaintiff, ~ody L. Majeskie, and upon concurrence of Defendant, Kalvin A. Majeskie, please withdraw the Divorce Complaint in the above-captioned matter and mark the matter discontinued and ended. Date: Respectfully Submitted, SAIDIS, SHUFF, FLOWER & LINDSAY ~indqay Ging~acl~, Esquire ~/Attofney I.D.qq'o. 87954 26 West High Street Carlisle, Pennsylvania 17013 (717) 243-6222 Attorneys for Plaintiff, Jody L. Majeskie