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HomeMy WebLinkAbout10-1044HEATHER J. KOBLISH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - 11) j CIVIL TERM MATTHEW M. KOBLISH, CIVIL ACTION-LAW Defendant IN DIVORCE c rn -n Q rll NOTICE TO DEFEND AND CLAIM RIGHTS ' - You have been sued in court. If you wish to defend against the clairff et ef",rth ' in the following pages, you must take prompt action. You are warned that if you faibto; 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, 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 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. 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, Pennsylvania 17013 (717) 249-3166 P,(? 7 3a. 00 HEATHER J. KOBLISH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - `pycf CIVIL TERM MATTHEW M. KOBLISH, CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Heather J. Koblish, an adult individual who currently resides at 137 Pleasant View Terrace, New Cumberland, York County, Pennsylvania 17070. 2. Defendant is Matthew M. Koblish, an adult individual who currently resides at 350 H Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 23, 2000 in Ocho Rios, Jamaica. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she 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 of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, Date: 2. H 10 O'BRIEN, BARIC & SCHERER r Mic ael A. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff St t VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. D J "1 ther J. li h HEATHER J. KOBLISH, Plaintiff V. MATTHEW M. KOBLISH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ("~ N NO. 2010 - 1044 CIVIL TERM `-= r ~ CIVIL ACTION-LAW -;v;. N DIVORCE 's'-'' _~- ~ {'~ .. ~~ ~i7 CERTIFICATE OF SERVICE ~ ~ ~""~ J f~ l!J .~ :r fi~~ -_ r; ; ~-~ .'' r~ _t, s _,_'7~ ~~ ~= t`r't ,;=,r "G I, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card . BARK SCHERER DATE: February 23, 2010 ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ^ Print your name and address on the reverse so we can return the card to you. ^ othis card to the back of the mallpiece, e front ff space permits. Addressed to: ~~nv nn . ~.o bl ~b` Ct~ ichael A. Scherer, Esquire a signature ~ ' '~~ ~~ X ~ !• > . ~~~- "~" :(_Cr' ^ Addressee B. ed by (Printed Name) C. D ~ivery D. Is delivery ~Jdress dHferent from If YES, enter delivery address b <:,v ,~ j •~ ~ r .ti ~ ,"` 4t~~~ 1 i. 3. Type ~~ ~ ~~ ~~~ Mail ^ Express Mail ^ Registered ^ Return Receipt for Mer~chandlse ^ Insured Mall ^ C.O.D. 4. Restricted Dellveri/t (Extra Fee) 'Yes 2. Article Number 7Q09 282 Q~~2 21a3 1487 (transfer from seMce tabu -- PS Form 38~ 1, February 2004 Domestic Return Receipt 102585-02-M-1540 HEATHER J, KOBLISH Plaintiff V. MATTHEW M, KOBLISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENN~'LV~JIA: .~, ~ ~ NO. 2010 - 1044 CIVIL TERM'`?" ,,-~ ,~~, N Gl~ ~: _~ ti,J7 ~ ` ,i, ..,, ~ ~(` IN DIVORCE ,~~ ' '' ~ ~ ~~~~_ /~ \ ` , _ _~ ~ PLAINTIFF'S AFFIDAVIT OF CONSENT AND 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 11, 2010. 2. Defendant signed an acceptance of service form on February 17, 2010. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. e' 1 HEATHER J. KOBLISH Plaintiff v. MATTHEW M. KOBLISH Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ Q NO. 2010 - 1044 CIVIL TERM IN DIVORCE rr tz. rn~:- _ ono (' rr l^~ ~_. DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OFD DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE _:, _„ ~~ -r: ~ :~c,a ~~ A.~ ~,.. 1 ~E2 a `=-; rr~ ry 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on February 11, 2010. 2. Defendant acknowledges receipt and accepted service of the Complaint on February 17, 2010. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised ofthe availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~' :,rte r,, Date: ~ ~~ ~~ Matthew M. -KobljSh~``` HEATHER J. KOBLISH, Plaintiff Vs. MATTHEW M. KOBLISH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.~ 1044 IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: c~ c ~_ ~~A" R-3 r i , -_ ~. ~_ L~3 ~,.. ~: ~: N 1 _~ 0 c c..;> ,~; _~ ..~ ~, r i T'! "]a7 '~t,± _i_ --x ~ ~' -- w. ~, :~~.; Transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the Complaint: Defendant was served through certified mail on February 17, 2010. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on June 19,m 2010; and Defendant on June 23, 2010. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/a (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: None served as the parties signed the Waiver of Notice. Defendant on June 23, 2010 and Plaintiff on June 19, 2010. Respectfully submitted, Michael A. Schere , squire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER J. KOBLISH V. MATTHEW M. KOBLISH NO. 2010 - 1044 DIVORCE DECREE AND NOW, ~ GG ` ~ ~~~~ , it is ordered and decreed that HEATHER J. KOBLISH plaintiff, and MATTHEW M. KOBLISH ,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, C~ ~ ~ 1 ~ ~c~}; cs~ tYtioc-t t .~ r~ -~, ~ L~--~-~- Sat.~u-