Loading...
HomeMy WebLinkAbout09-3480 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff KEVIN B. ISTVAN, Plaintiff VS. KIMBERLY D. ISTVAN, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No Oq - 3480 0,1"a Ter-+w CIVIL ACTION - AT LAW 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 at the Cumberland Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF 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, PA 17013-3308 (717) 249-3166 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff KEVIN B. ISTVAN, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No 09- 3y r0? ?c- VS. KIMBERLY D. ISTVAN, CIVIL ACTION - AT LAW Defendant DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Kevin B. Istvan, by and through his attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Divorce: 1. Plaintiff, Kevin B. Istvan, is an adult individual currently residing at 4183 Cove Court, #101, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant, Kimberly D. Istvan, is an adult individual currently residing at 1102 Copper Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 1, 1994, in Wilmington, Delaware. 5. There have been no prior actions of divorce or annulment between the parties. 1 COUNT I - DIVORCE 6. Plaintiff avers that the grounds on which this divorce action is based are that the marriage is irretrievably broken. 7. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 10. There are two (2) dependent children from this marriage, namely Joseph G. Istvan, born March 28, 1994, and Jack S. Istvan, born December 28, 2001. 11. This action is not collusive. COUNT II - EQUITABLE DISTRIBUTION 12. While no settlement has been reached as of the date of the filing of this Complaint, Plaintiff is and has always been willing to negotiate a fair and reasonable settlement of all matters with Defendant. To the extent that a written Settlement Agreement might be entered into between the parties prior to the time of hearing on this Divorce Complaint, Plaintiff desires that such written Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage 2 between the parties. 13. Plaintiff and Defendant are the owners of various items of real and personal property, furniture and household furnishings acquired during their marriage, which are subject to equitable distribution by this court. 14. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, and insurance policies acquired during their marriage, which are subject to equitable distribution by this court. WHEREFORE, Plaintiff, Kevin B. Istvan, requests this Honorable Court to enter a Decree in Divorce and equitably distribute all property, both personal and real, owned by the parties. Respectfully Submitted: By: JEANNE B. COSTOPOULOS, ESQUI Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 ` ATTORNEY FOR PLAINTIFF Date: 3 VERIFICATION I, Kevin B. Istvan, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: 5") a 6 1 o g Kevin/]K. Ian F'+ r r "9y '7' {FE: qt ? ?t1 ?" j "?? 14 Ci L?U tii`.,t C. 7 43ip4. S6 p o AT(5/ ctl M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEVIN B ISTVAN V. KTMB RT Y D TSTVAN _ • N~• .~~Q.~4 r' °il `~'A~'iFl DIVORCE DECREE AND NOW, ~~M*~s iy~ zdJO , it is ordered and decreed that Kevin B. Istvan ,plaintiff, and Kimberl ~ D Tct~~an ,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 follows: (If no claims remain indicate "None.°) None . By the Court, Atte t! ~• __ y _ Prothonotary