The URL can be used to link to this page

Home My WebLink About09-2276•.A RICHARD LENKEVICH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SANDRA J. LENKEVICH, NO.69- 227b 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 C. -4 RICHARD J. LENKEVICH, Plaintiff V. SANDRA J. LENKEVICH, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Richard J. Lenkevich, an adult individual currently residing at 397 Allison Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Sandra J. Lenkevich, an adult individual currently residing at 397 Allison Avenue, Mechanicsburg, 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 June 13, 1992, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 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. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. -4 9. The parties' marriage is irretrievably broken. 10. 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, fyG-i e, Esqu ire ttor intiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsifications to authorities. DATE: v RICHARD J. LENKEVICH, Plaintiff A p NARY OF 'tl-t 2004 APR 13 PM 12'. 12 .x' 33 5. SO ?ct- C*9- jz--a- 3so5 RICHARD LENKEVICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW SANDRA J. LENKEVICH, NO. 09-2276 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Bradley L. Griffie, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, Sandra J. Lenkevich, at her address of 397 Allison Avenue, Mechanicsburg, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on April 14, 2009. oj? r?ylffie, Esquire t aintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this day of , 2009 A'A NOTARY UBLIC AOlMJ R 1+ Mt?b?1C 1111fM011-xpl??s Apt 17, 2011 l Ln . .- L „ C LLn Postage $ I•LI Certified Fee • rl1 C3 Return Receipt Fee O (Endorsement Required) O Restricted Delivery Fee O (Endorsement Required) S rr J Total Postage & Fees C3 rrr o 4 LeA ?L? r..- F ?K.. o Wr, gas.; 3--. ...... ` --- -- --- C3 or PO Box No. - y------ - ??------- ---------- 4 --- - - - ------------- City, State, ZIP+ III Cott O tb Eems 1, 2, and 3. Also Complete Ilan 4 If Reetticted Delivery Is desired. ¦ Pfint yotu ar4deddress on the reverse so return the card to you. Attach MFbwd to the back of the niailplece, or!n the front If space permits. 1 Article Addressed to: P-4W1 r %3g7 ail, o?'t 4µe'r MeAO-,UccsbwO-l PSI A O Agent C. Date of Delivery D. Is dd ary address sift nt from Rom 1? 0 yes it YES, enter delivery address below: O No JC 3. lSrpe Mail C Express man Registered 0 Return Recut for Me1t*ierldbe C3 hwxw and C3 C.O.D. 4. Restricted DeiNery? O?Kft FAO habi 2. ArtdeNumber 7007 0220 0002 2526 5578 f A'?+rr s??os I Ps Form 3811, February 2004 oomawc Pa%rrn Receipt 102 -W,s4o -r L ED - 2099 APR 23 FM 3. 1 :; V { 1, 1! f r ? t FILED-OF filvE OF THE PPOTHONOTIAPy RICHARD LENKEVICH, Plaintiff V. SANDRA J. LENKEVICH, Defendant 2011 APR -8 PM 2: 3 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 09-2276 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 4. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April 13, 2009, and served on April 14, 2009, by certified mail, restricted delivery. 5. 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. 6. I consent to the 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 THE FOREGOING 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: `SANDRA J. LENKE CH, Defendant 1-ILED-O FICEl 7 ^ 2011 APR -8 PM 2: 54 CUMBERLAND COUNTY PENNSYLVANIA RICHARD LENKEVICH, Plaintiff V. SANDRA J. LENKEVICH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 09-2276 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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 THE FOREGOING 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: SANDRA J. LEN VICH, Defendant FILED-OFFICE OF THE PROTHONOTAR` 2011 APR 21 AM 11: 13 OU PENNSYL.DVAN Q T RICHARD LENKEVICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW SANDRA J. LENKEVICH, NO. 09-2276 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April 13, 2009, and served on April 14, 2009, by certified mail, restricted delivery. 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. I consent to the 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 THE FOREGOING 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: ' z / /.y / I (? CHARD LENKEVICH, Plaintiff THEPPQTHQNOTA R, 2011 APR 27 AM II, I CUMBERLAND COUNd t Y PENNSYLVANIA RICHARD LENKEVICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW SANDRA J. LENKEVICH, NO. 09-2276 CIVIL TERM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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: -? I RICHARD LENKEVICH, Plaintiff RICHARD LENKEVICH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW SANDRA J. LENKEVICH, NO. 09-2276 CIVIL TERM " SE -q Defendant IN DIVORCE ` M „ Mou r' r- z N? iV -O Wit= STIPULATION FOR ENTRY OF RETIREMENT BENEFI* COURT ORDER c WHEREAS, Richard Lenkevich (hereinafter "Participant") and Sandra J. Lenkivich (hereinafter "Payee"), have agreed to a division of marital property which agreement includes a distribution from Participant's Thrift Savings Plan (hereinafter "Plan"); and WHEREAS, the parties wish to secure an Order of Court directing said distribution. NOW THEREFORE, it is stipulated and agreed as follows: 1. The parties intend for this Stipulation to be entered as a Retirement Benefits Court Order for the transfer of funds from the Plan of a federal civilian employee. 2. This Order applies to the Thrift Savings Plan of the aforenamed Participant, Social Security No. 194-42-9928*, date of birth October 5, 1963, and whose address is 397 Allison Avenue, Mechanicsburg, Pennsylvania, 17055. 3. This Order applies to the aforenamed Payee, Social Security No. 047-72-1301*, date of birth September 28, 1965, and whose last known address is 1330 Indian Peg Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. 4. The parties were married on June 13, 1992, in Cumberland County, Pennsylvania, and are securing a Decree in Divorce in the above captioned proceedings. 5. The Participant's account in the Plan is marital property subject to distribution by the Court of Common Pleas of Cumberland County, Pennsylvania. The Court has jurisdiction over the parties' divorce proceedings. 6. Participant continues as an employee of the federal government at the time of entry of this Stipulation and requested Order. 7. Pursuant to the parties' Agreement, the sum of ONE HUNDRED THIRTY-TWO THOUSAND AND XX/100($132,000.00) DOLLARS sum in Participant's TSP account as of April 13, 2011 together with pro-rata interest, dividends, and income or losses earned on that sum from that date, shall be rolled over to Payee's Thrift Savings Plan, immediately upon receipt of this Stipulation and the resulting Order of Court by the TSP Service Office in New Orleans, Louisiana. 8. No other benefits are designated to be received by the Payee from the Participant and no additional claims will be made against the Participant's TSP account by the Payee from the time of rollover of this distribution forward. 9. This transfer of funds shall not be a taxable transfer. 10. The parties intend that this Stipulation shall be entered as an Order of Court and that a true and attested copy of this Order shall be forthwith served upon the TSP Service Office, National Finance Center, P.O. Box 61500, New Orleans, Louisiana, 70161- 1500. Said Order shall be effectuated immediately upon receipt of the Order by the TSP Service Office. 11. No other Judge in the Court of Common Pleas of Cumberland County has been involved in this case with the exception of the Judge named in the docket information set: forth above, being the Judge who entered the Decree in Divorce in this matter. *The original Stipulation for Entry of Retirement Benefits being filed of record has had the parties' Social Security Numbers redacted for confidentiality purposes. IN WITNESS WHEREOF, the parties hereto have set forth the day and year hereinafter written. WITNESS: .1 J?- Jd,1?4,41A I l l/ 4r,,XAPI?1161A ate SANDRA J. L KEVICH 1 .1 7 -- --L i¢ !/ 20 j Dale RICHARD LENKEVICH .' STATE OF PENNSYLVANIA ; COUNTY OF l I r On this I 4 day of JJ-N-Q? 2011, before me, the undersigned officer, personally appeared SANDRA J. LENKEUCH, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL GINGER OF HARRISBURG L. GONTI, NOTARY PUBLIC , 2012 OMMISSION EXPIRES DAUPHIN COUNTY 2012 COMMONWEALTH OF PENNSYLVANIA : COUNTY OF 1 On this da of C' Y _ , 2011, before me, the undersigned officer, personally appeared RIC LEN CH, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunti COMMONWEALTH OF PENNSYLVANIA Notarial Seal Andrea L. Wingard, Notary Public Hampden Twp., Cumberland County My Commission BOM May 11, 2014 Member, Pennsylvania Association of Notaries _ C' rnca -9 -T1 z? -m co OC C " O o _n ? ?a .? C C7 C.r'S RICHARD LENKEVICH, Plaintiff V. SANDRA J. LENKEVICH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-2276 CIVIL TERM IN DIVORCE RETIREMENT BENEFITS COURT ORDER 1, ? AND NOW, this 2a day of J 1. , 2011, the attached Stipulation of the parties is hereby approved by the Court and is hereby entered as an Order of Court such that, IT IS HEREBY ORDERED AND DIRECTED that Sandra J. Lenkevich (hereinafter "Payee"), S.S. No. 047-72-1301*, of 1330 Indian Peg Road, Boiling Springs, Pennsylvania, 17007, is awarded the sum of ONE HUNDRED THIRTY-TWO THOUSAND ($132,000.00) AND XX/100 DOLLARS of the funds accumulated in the Thrift Savings Plan account of Richard Lenkevich (hereinafter "Participant"), S.S. No. 194-42-9928*, of 397 Allison Avenue, Mechanicsburg, Pennsylvania, 17055, as of April 13, 2011 together with pro-rata interest, dividends or income or losses accruing on said amount from that date to the date of distribution. IT IS FURTHER ORDERED AND DIRECTED that this sum shall be rolled over from f, the Participant's Thrift Savings Plan account to the Payee's Thrift Savings Plan, as promptly as reasonably possible by the Thrift Savings Plan or TSP Service Office upon receipt of a true and attested copy of this Order. cc: Bradley L. Griffie, Esq. Attorney for Plaintiff Donald Kissinger Esq. Attorney for Defendant COF tfS mSA LC 7/mil ?f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION L Ke' i a- th&r--d T Plaintiff• vs. Lin Kc Vl ) Sana +,1 File No. oq IN DIVORCE Defendant c` c v . r41C' NOTICE TO RESUME PRIOR SURNAME C!)f N - c Notice is hereby given that the Plaintiff / Defendant in the above matter, rte' , `--F (select one by marking "X"). > prior to the entry of a Final Decree in Divorce, z 3 or after the ent of a Final Decree in Divorce dated P4)6)24i `hereby elects to resume the prior surname of • 0Veir , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. § 704. Date: I I'%L 1 I jiiimittiet.Yi/riti4/a) Si ature .1-010/4- /66/(41 Si natu2 o g f name being resumed COMMONWEA TH OF PENNSYLVANIA COUNTY OF Uildii,/ oVid On the p? ifA day of VOV , ai(/y, before me, the Prothonotary or a 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 and offjcia,I seal. Pr thono ary or Notary Public Prothonotary, Cumberland County,Carlisle, PA My Commission Expires the First Monday of Jan. 2018 fa.a) c&s 7Z -el 3W 5