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Home My WebLink About08-7472LUCAS P. SLOBODIAN, Plaintiff V. ANNA K. SLOBODIAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . NO. 08 - 741A 0,M[TeeM : 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 of 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, One Courthouse Square, Carlisle, Pennsylvania 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 LUCAS P. SLOBODIAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. :.NO. 0?- 7y 7? ANNA K. SLOBODIAN, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes Plaintiff Lucas P. Slobodian, pro se, and files the within Complaint against the Defendant, averring as follows: Divorce Under § 3301(c and § 3301(d) of the Divorce Code 1. Plaintiff is Lucas P. Slobodian, an adult individual who currently resides at and has a mailing address of 2015 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiff has lived at said address since July, 2005. 2. Defendant is Anna K. Slobodian, an adult individual who currently resides at 215 Briggs Street, Apt. B, Harrisburg, Dauphin County, Pennsylvania 17102. Defendant has lived at such address since September, 2008. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 31, 2005 in Camp Hill, Pennsylvania and separated in July, 2008, and have lived separate and apart since that time. 5. The Plaintiff and Defendant are both citizens of the United States of America and are not members of the Armed Forces. 6. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. Plaintiff understands that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce pursuant to Section 3301(c) or Section 3301(d) of the Pennsylvania Divorce Code of 1980, as amended. I, Lucas P. Slobodian, 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. LUC P. SLOB0DIAN Dated: ?r °c c,.a LUCAS P. SLOBODIAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. -14-12-- 2008 ANNA K. SLOBODIAN, CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Anna K. Slobodian, the Defendant in the above-captioned matter, do hereby accept service of the Complaint In Divorce. S obodian o7 Dated: f ?? ljZ) _, LUCAS P. SLOBODIAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-7472 ANNA K. SLOBODIAN, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 24, 2008 and served on the Defendant on January 13, 2009. An acceptance of service form was filed on January 27, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final 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. §4904 relating to unsworn falsification to authorities. Lucas P. Slobodian, Plaintiff DATE: 1? O 0U7 ALED--t i-T iE OF T 2009 MAY -7 PM 3: 09 VLJmb" ,...? tip PEj', f?tiS f M YANVN LUCAS P. SLOBODIAN, Plaintiff V. ANNA K. SLOBODIAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-7472 Civil Term : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 falsifications to authorities. Lucas P. Slobodian, Plaintiff Dated: .? U ALE&, " CF OF THE PPOTHW iAPY 2009 MAY -7 PM 3: 09 PENNS 1 UA,m LUCAS P. SLOBODIAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-7472 ANNA K. SLOBODIAN, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on December 24, 2008 and served on the Defendant on January 13, 2009. An acceptance of service form was filed on January 27, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final 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. §4904 relating to unsworn falsification to authorities. w Anna K. Slobodian, Defendant DATE: ??Z 0 Oq RID-0r"FIC%E- OF THE Pf Tt I II OTARY 2009 MAY -7 PM 3: 8 tm 4 d J u! v LUCAS P. SLOBODIAN, Plaintiff V. ANNA K. SLOBODIAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-7472 Civil Term : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 falsifications to authorities. __,L2 Anna K. Slobodian, Defendant Dated: °ur v?o9 FILED-: Fi E- OF THE FKII- NIOTAPY 2009 MAY -7 Pig 3: 08 LUCAS P. SLOBODIAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Civil Term 2008-747a ANNA K. SLOBODIAN, CIVIL ACTION - LAW Defendant 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) 3301(d)] of the Divorce Code. (Strike out inapplicable section). 2. Date of filing and manner of service of complaint: filed December 24, 2008, served via U.S. first class mail, postage paid upon Defendant on January 13, 2009. Acceptance of Service was filed on January 27, 2009 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff May 5, 2009; by Defendant May 5, 2009. (b)(1) Date of execution of the affidavit required by §3301(d) if the Divorce Code: N/A; (2) Date of filing and service of the Plaintiffs affidavit upon the respondent: N/A 4. Related claims pending. None. 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: N/A. (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: May 7, 2009 Date Defendant's Waiver of Notice Divorce was filed with the Prothonotary: May 7, 2009 Respectfully submitted, Date: S 7167 °j Lucas P. Slobodian, Plaintiff ALED-OFFICE OF THE P`c O HMTARY 2009 JUN -4 PH Z: 4 7 COUNTY PENNsYMNLA Lucas P. Slobodian V. Anna K. Slobodian IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-7472 DIVORCE DECREE AND NOW, KQ.- O ,_?, it is ordered and decreed that Lucas P. Slobodian plaintiff, and Anna K. Slobodian defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as fol!qws: (If no claims remain indicate "None.") mil., By the Court, Attest: J. /IJ-/t A. le" rothonotary W6? t?v? ?? 0?? f ? 1L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. c - 14702, hQ • J , „ (D ei IN DIVORCE tC Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated (0110 0 hereby elects to resume the prior surname of eQrn , and gives this s 54 P.S. 704. written notice av wing his / her intention purs t tot Oignaitiuj?re Date: ignatur of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF On the day of 200, 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 he / 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. EAL ARY PUBLIC 6ifti UNTY COURTHOUSNot Pu blic JANUARY 4, 2010 pL %' ;?-7 // t/ q3S "T THE 2909 JJN 25 Al-i lu: 0c, ---, ?7e