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Home My WebLink About09-8769 MATTHEW R. SOPER Plaintiff V. VICTORIA YAKOVLEVNA BOYARSKAYA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO. (q-87(p9 Civl ( ?era, CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE AND NOW, comes the Plaintiff, Matthew R. Soper, by and through his counsel, Cunningham & Chernicoff, P.C., and seeks to obtain a Decree in Divorce from the Defendant, Victoria Yakovlevna Boyarskaya and support thereof avers as follows: 1. The Plaintiff, Matthew R. Soper ("Plaintiff'), currently resides at 2153 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013. The Plaintiff is a citizen of the United States of America. Plaintiff s Social Security Number is 211- 60-7792. 2. The Defendant, Victoria Yakovlevna Boyarskaya, ("Defendant"), currently resides at 2153 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013. The Defendant is a citizen of the United States of America. Defendant's Social Security Number is 089-86-3488. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on August 24, 2007 in Staten Island, New York. 6. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that Defendant may have the right to request that the Court the parties to participate in counseling. WHEREFORE, Plaintiff, Matthew R. Soper, hereby respectfully requests this Honorable Court to enter a Decree in Divorce from the bars of matrimony. COUNT II - EQUITABLE DISTRIBUTION 9. The averments of Paragraphs 1 through 8 are incorporated herein by reference as if fully set forth. 10. During the course of the marriage, the parties acquired marital property. 2 WHEREFORE, Plaintiff, Matthew R. Soper, hereby respectfully requests this Honorable Court to determine, divide, distribute and assign the marital property of the parties pursuant to Section 35 of the Divorce Code. submitted, .C. By: Date: December 18, 2009 F:\Home\KKNIGHT?DOCS\SOPER.MATTHEW Complaint.WPD A Sul#eme Courtt I 320 North Second treet P.O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 Attorneys for Plaintiff, Matthew R. Soper 3 VERIFICATION I verify that the statements made in the foregoing 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. I'? F, ? 7 " < 'J" - MATTHEW R. SOPER Date: I) '/? -09 MATTHEW R. SOPER IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff t CASE NO. o CJ g 71° / C k1l V. VICTORIA YAKOVLEVNA BOYARSKAYA, CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS -/ Gl'ft4' 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 minor 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, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 849-3166 ly submitted, C Date: December 18, 2009 By: I.D( #87365 \ // 2320 North Seco d Street P. O. Box 60457 Harrisburg, PA 17106-0457 Telephone: (717) 238-6570 6 FIR f' ) 'ii?'G2Y *391. 5o Po ATf Gc,? ?aa ? o " a as 3cY"/(n?L of CA , 6'7(.? 0,jvtMem AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss; I, MATTHEW R. SOPER, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MATTHEW R. SOPER SWORN and Subscribed to Before me this j day of e? 52009 OTARY PUBLIC OOMMONWEALTN OF PENNSYLVAN A NOTARIAL S:EA JULIEANNE AMETRANotary Public ty of Harrisburg, Dan County Ci My Commission Expires uary 22, 2011 G_ THE , RY 2 0 J 9 DEC 2 ! Pit 2: 30 - ??w N - e l&o I ivi 1Tec?1 I AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN : ss; The Plaintiff, being duly sworn according to law, deposes and says that he is the Plaintiff in the above captioned matter and that he personally knows that the Defendant is over the age of eighteen (18) years. The Plaintiff further avers that the Defendant is not in the Military Service or in any branch of the Armed Forces of the United States of America or its Allies or otherwise within the provisions of the Soldier's and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. SWORN and Subscribed to Befor e this r I day of %11(k4m &--) , 2009 TARY PUBL ZAVx.1 - MATTHEW R. SOPER {__,,ijA0Nbh1EAL H OF PENNSYLVANIA NOTARIAL SEAL Lm- EANNE AMETRANO, Notary Public ty of Harrisburg, Dauphin County mmission Expires February 22, 2011 fi NRY 1??9