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HomeMy WebLinkAbout09-3641SHERRY MONOSKI Plaintiff V. DAVID J. MONOSKI Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09 - 3fo 1 CIVIL TERM 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 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 1 st Floor, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. 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, 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, PA 17013 (717) 249-3166 SHERRY MONOSKI Plaintiff V. DAVID J. MONOSKI Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 3 , y1 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Sherry Monoski, who currently resides at 1507 York Road, Carlisle, PA, 17013 since May 1995. 2. Defendant is David J. Monoski, who currently resides at 1507 York Road, Carlisle, PA, 17013 since May 1995. 3. Defendant has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 24, 1987 at Biloxi, Mississippi. 5. There have been no prior actions of divorce or annulment between the parties. 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 respectfully requests this Honorable Court enter a Decree of Divorce and such other relief as may be appropriate. LAW OFFICE OF DIRK BERRY, ESQ. Dirk E. Berry, Esquire Attorney for Plaintiff 44 S. Hanover Street Carlisle, PA 17013 (717) 243-4448 I 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 unworn falsification to authorities. T2 Z,/) 2 Mon L r Date SHERRY M SKI FILED 1. ? . ? .. •d i ?„ 23Fa.s-C-75,ed 144 M " - G l3 ,l SHERRY MONOSKI, Plaintiff V. DAVID J. MONOSKI Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 09 - 3641 Civil Term NO. _ __ DIVORCE DECREE AND NOW, ~S~~U~ ~ ~_~, it is ordered and decreed that SHERRY MONOSKI plaintiff, and DAVID J. MONOSKI 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.°) The parties incorporate, but do not merge, their Marriage Settlement Agreement dated November 6, 2009. By Attest: ~ J. Prothon ary ~