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
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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
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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
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Mic ael A. Scherer, Esquire
I.D.# 61974
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff
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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.
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HEATHER J. KOBLISH,
Plaintiff
V.
MATTHEW M. KOBLISH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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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:
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ichael A. Scherer, Esquire
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2. Article Number 7Q09 282 Q~~2 21a3 1487
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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:
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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.
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HEATHER J. KOBLISH
Plaintiff
v.
MATTHEW M. KOBLISH
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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NO. 2010 - 1044 CIVIL TERM
IN DIVORCE
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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
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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.
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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:
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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,
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