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HomeMy WebLinkAbout09-0214D AMY C. SKVARKA, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW LINCOLN T. SKVARKA, NO. ©cl " ~-~ "'l CIVIL TERM Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 AMY C. SKVARKA, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v' :CIVIL ACTION -LAW LINCOLN T. SKVARKA, NO. ~ 9 ~ ~,~ y CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1 • Plaintiff is Amy C. Skvarka, an adult individual currently residing at 151 Roxbury Road, Newville, Cumberland County, Pennsylvania. 2• Defendant is Lincoln T. Skvarka, an adult individual currently residing at 151 Roxbury Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 19, 1996, in Adams County, Pennsylvania. 5• There have been no other prior actions for divorce or annulment between the parties. 6• Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 7. Plaintiff and Defendant are citizens of the United States of America. 8• The parties' marriage is irretrievably broken. 9. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Hannah Herman Snyder, Esquir Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION understand that false statements herein are made subject to the penalties of 4904, relating to unsworn falsifications to authorities. DATE: I verify that the statements made in the foregoing document are true and correct. I 18 Pa.C.S. Section AMY C. VARKA, Pl ntiff t7 0 ~~' r-; ~'- ~ . bl ~ .f..' ~ 1 `N ~ (.! V V ~ a~ ~ t { ~ 1, ('~ ~~ i . _ ~r~1..J ~- Y + ~ f ~ "C``` ~" '`£ N ~~ -~ ~` ~r F , ~. R~ ~. ~ • _ ~ SHERIFF S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~~-~=~C ~ ~ _ Sheriff '~ . ` TF c ~~' ,, _, .' ~-,~,:~y ~9~~~p ~~ ~uu~brrl,~~~ Jody S Smith ~- 2~~~ ~~~ i ~ ~~~ G; ~~ ~~ Chief Deputy r ~~ r' Richard W Stewart ~- ~ ~~ ~~ °~~ ~l~Ytir ~, ,~,~-r., f SOIICItOr UFF C~ OP rHE $N~RIFF ~~ ~ i.,~ ~ y ~i ~ F: Chase Bank USA, N.A. vs. Case Number Fred V George, Jr 2009-214 SHERIFF'S RETURN OF SERVICE 12/15/2009 03:40 PM -Michael Ba rick, Deputy Sheriff, who being duly sworn according to law, states that on ;,~ December 15, 2009 at 540 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies oft a within named defendant, to wit: Fred V. George, Jr., in the hands, possession, or control of the within amed garnishee, First National Bank, 4231 Trindle Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Danielle Crawford, Personal Banking Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made th contents there of known to her. 12/15/2009 04:00 PM -William Clin ,Deputy Sheriff, who being duly sworn according to law, states that on December 15, 2009 at 1535 hours attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within na ed defendant, to wit: Fred V. George Jr., in the hands, possession, or control of the within named gami hee, Members 1st Federal Credit Union, 401 E King Street, Shippensburg, Cumberland County, P nnsylvania, by handing to Luanne E. Kyle, Branch Manager, personally three copies of interrogatorie together with three true and attested copies of the writ of execution and made the contents there of know to her. The writ of execution a d notice to defendant was mailed on December 15, 2009 to Fred V. George, Jr., at 17 Brubeck Circle, M rysville, PA 17053. 07/16/2010 Ronny R. Anderson, S eriff, who being duly sworn according to law, states this writ of execution is returned as ABANDON D. No action on writ in over 6 months. SHERIFF COST: $173.91 July 16, 2010 SO ANSWE RONN NDERSON, SHERIFF