The URL can be used to link to this page

Home My WebLink About10-1140JP JASON J. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 10- /NO CIVIL TERM YVONNE L. WERZINSKY, : Defendant : 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 CUMBERLAND COUNTY COURTHOUSE. CARLISLE, PENNSYLVANIA 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 WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 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, Pennsylvania 17013 Telephone: 717-249-3166 W Sh e M "Jall ?ry ??t lrir i '_ .? ,; . 1 - ayne . ade, Esquire Supreme Court No. 15712 53 West Pomfret Street 3 L + 83J 0 OZ Carlisle, Pennsylvania 17013 q-3 r2 004 b . ' Telephone : 717-243-0220 AdVi 4&ii(D?d !_ ck4 Jg93 K ii- Attorney for Plaintiff j??a37`28 P JASON J. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 10- { j O CIVIL TERM YVONNE L. WERZINSKY, Defendant : IN DIVORCE COMPLAINT COUNTI DIVORCE 1. Plaintiff in this Action in Divorce is JASON J. JUMPER, an adult individual who resides at 541 Brandt Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is YVONNE L. WERZINSKY, an adult individual and citizen of the United States of America who resides at 541 Brandt Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for I more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 4. Plaintiff and Defendant were lawfully joined in marriage on January 30, 2009, in St. Maarten. 5. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which this action is based that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. 6. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 7. This Action in Divorce is not collusive. 8. Both parties to this Action in Divorce are legally capable of managing their own concerns. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street -2- Carlisle, Pennsylvania 17013 f 9. Defendant herein is not a member of the armed forces of the United States of America. 10. There were no children born to the parties. 11. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. /`? Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Street -3- Carlisle, Pennsylvania 17011 I verify that the statements made in this pleading 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: February 17, 2010 Ja o J J mper WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 JASON J. JUMPER, : 1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO. 10-1140 CIVIL TERM YVONNE L. WERZINSKY, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the WAYNE F. SHADE Attorney at Law 53 West Pomfret Stree Carlisle, Pennsylvania 17013 above-captioned matter, that he did, on February 17, 2010, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on February 20, 2010, as evidenced by the return receipt card attached hereto bearing Certified No. 7001 2510 0006 5861 4271. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: February 23, 2010 G~~yZcG F~ ~~~~ Wayne F. Shade ~ r,3 -.:~ , ~ ,.. ~~.~ - ~a .s _t ~~ `; x -na _:. '_ .- _ _ ~.~ ~m ~~ ~ ru ...0 Postage $ 6 ~„ t.t7 Certified Fee 2 80 Feb y 17 ...0 Return Receipt Fee O (Endorsement Required) O `L3 ~~~ ~ Restricted Delivery Fee (Endorsement Required) /~, 5 0 O r-1 Total Postage & Fees ~ 0.21 V7 rU Sent To _younne__-L_:___ Werzinsky '-'~ Street. Apt. No.; •°----...-----•--°------------------- ~ or PO Box No. .~,u~~u~ o - -- ------ --------X41.--~~.~~a~ - .. .-----._.....--------- ~ city; stare zip+a ew ~umberlan - ~, ^ Complete Rems 7,=Z, and 3. Also ~ttplete A re item 4 H Reatrkted belfry is desired. ~ X ~ .O ent ^ Print your name and Address on the reverse ~ v ,rdd„~,~ so that wo can return-the card to you. g, by ~ ~), ^ Attach this card to`the back of the mailpiece, ~ C. Date Dedvery c ~ G ' or on the front 1f space permits. ~ t a~. D. Is address different from 1, Article Addressed to: ? ^ Yes H YES, enter delNery address D No Ms. Yvonne L. Werzinsky 541 Brandt Avenue New Cumberland, PA 17070 s. sorvioe Tape ~ Certified Map O Express Mall D Registered ~ Retum Receipt for Mercttandlse ^ Insured Mall ^ C.O.D. 4. ~ , ~~.~ ; ~, 2. Article Number ~~ -- -. - pf,,,,,~, ~,,r„er,~;Wya~ 7 ~ ~ 1 2 510 O Q ~ 6 5 8 61 4 2 71 P3 Form 3811. Febrt,rry 2004 Dortrsstic Rettxn Rsosipt tasress.oo:a,~.ts~o JASON J. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. YVONNE L. WERZINSKY, Defendant NO. 10-1140 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: c c }. r ~: ~._: y. ~, ~~ c N 0 N tt~ c~ ~~ -r•, -~ ~, ..r._ ,~-„ =~= =r". _; ;~~ m Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. The date and manner of service of the Complaint were February 17, 2010, by certified United States mail, postage prepaid, return receipt requested, addressee only. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code by Plaintiff was May 28, 2010, and by Defendant was June 24, 2010. 4. Related claims pending: None. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 Date: June 28, 2010 Way F. Shade Attorney for Plaintiff w JASON J. JUMPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO. 10-1140 CIVIL TERM YVONNE L. WERZINSKY, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE C~ o ._l ' COMMONWEALTH OF PENNSYLVANIA) COUNTY OF LUZERNE ) ~? = . ~, s'_~' ~...,. ~~, 1 ~ ,~ . A Complaint in Divorce under §3301(c) of the Divorce Code with Notice ot°°' Z Availability of Counseling was filed on February 17, 2010, and served on February 17, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without notice. 4. 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. .~ s 5. 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. b. I have been advised of the availability of marriage counseling and of my right to counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 7. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 8. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree's being handed down by the Court. 9. 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. §4904 relating to unsworn falsification to authorities. Date: June 24 , 2010 oc, W Y onne L. Wer nsky -2- JASON J. JUMPER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. YVONNE L. WERZINSKY NO 10-1140 CIVIL TERM DIVORCE DECREE ~. ~ ~; ~ 7 ~•M . AND NOW, ~ ~ , ~_, it is ordered and decreed that JASON J. JUMPER plaintiff, and YVONNE L. WERZINSKY ,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. Httest: ~. Prothonotary `7.7• ! O /Uo-ti c,~ mQ:, tea -~-o -~ ~ Sr~~ ~ ~ ~,c o~