HomeMy WebLinkAbout09-2290ANN KRZYZOSIAK,
Plaintiff
v.
STEVEN KRZYZOSIAK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 09 - ,Z~,Q(j CIVIL TERM
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 or other rights important to you, including custody or visitation of your children.
When the ground for 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,
Cumberland County Courthouse, Carlisle, Pennsylvania, 17013.
)F YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES OR EXPENSES BEFORE A DNORCE 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 HIDING A LAWYER.
1F YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH 1NFORAMTION 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, PA 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County, Pennsylvania, is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business before the Court.
ANN KRZYZOSIAK,
Plaintiff
v.
STEVEN KRZYZOSIAK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 09 - CIVIL TERM
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Ann Krzyzosiak, an adult individual, who resides at 105 Willow Dr.,
Shippensubrg, Cumberland County, Pennsylvania, 17257.
2. Defendant is Steven Krzyzosiak, an adult individual, who resides at 261 Newburg Rd.,
Newburg, Cumberland County, Pennsylvania, 17240.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on Apri126, 2007 in Las Vegas, Nevada.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right
to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
-- lJ
Date:
Respectfully submitted,
BAYLEY & MANGAN
Mazk F. Bayley, Esquire
17 West South St.
Carlisle, PA 17013
(717) 241-2446
Supreme Court I.D. # 87663
Attorney for Plaintiff
~ ~ • ^.
ANN KRZYZOSIAK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
STEVEN KRZYZOSIAK, NO. 09 - CIVIL TERM
Defendant IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint aze true and correct. I understand that
false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn
falsification to authorities.
Date: ~, 23` O ~
Ann KrLyzosiak, Pl
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