HomeMy WebLinkAbout09-4688Amy L. Bekelja, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
V. No. 09- 4682 Civi 1 7-er%
Patrick C. Bekelja, Jr.,
Defendant IN DIVORCE
NOTICE
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 the Cumberland County Court House, High and Hanover Streets, Carlisle.
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
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County 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. You must attend the
scheduled conference or hearing.
Amy L. Bekelja, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION LAW
vi. No. 09- yG F P C-:, J -7-`-
Patrick C. Bekelja, Jr.,
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Amy L. Beke1'a, who currently resides at 48 Hollywood Drive,Bttq9hin
County, Mechanicsburg, Pennsylvania since June 2009 and previous address of 118 West Keller
Street, Cumberland County, Mechanicsburg, Pennsylvania since January 2009.
2. Defendant is Patrick C. Bekelja, Jr., who currently resides at 5070 Highland Street,
Dauphin County, Harrisburg, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on, July 25, 2005 in Ocean City, New Jersey.
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 and the parties separated on June 26, 2008
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.
By:
Amy/. Bekelja, pro e
VERIFICATION
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 unsworn
falsification to authorities.
Date: 1a- q- 6l
Amy V.ekelja, Plaintiff
Assisted by:
Vincent M. Monfredo, Esquire
Rominger and Associates
155 South Hanover Street
Carlisle, PA 17013
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Amy L. Bekelja IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 09- 41P88 CIVIL TERM
Patrick C Bekelja, Jr.
Defendant IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Amy L. Bekelja Plaintiff, to proceed in forma au eris.
I, Vincent M. Monfredo, attorney for the party proceeding in forma au eris,
certify that I believe the parry is unable to pay the costs and that I am providing free legal
services to the party.
Vincent M. Monfredo, Esquire
Attorney for Plaintiff
Rominger Law Office
155 S. Hanover Street
Carlisle, PA 17013
(717) 241-6070
T l IF: Qv
?y '?: F'?; u `N
AMY L. BEKELJA,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
PATRICK C. BEKELJA, JR. NO 09-468$
DIVORCE DECREE
c.,~~
AND NOW, ~ 3 ~~ , it is ordered and decreed that
AMY L. BEKELJA, plaintiff, and
PATRICK C. BEKELJA, JR.
bonds of matrimony.
defendant, are divorced from the
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
A J.
Prothonotary