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CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS
ROBERT R. WOZNIEWICZ,
Plaintiff,
vs.
MARY K. WOZNIEWICZ,
Defendant
ACTION -- LAW
NO.: rO - I7(d
DIVORCE
alvi I -Fen?,
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 THE CUMBERLAND COUNTY COURTHOUSE, 1
COURTHOUSE SQUARE, CARLISLE, PA 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 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 LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013 $& bO P'p ATff
(717) 249-3166 Ctr 34,30
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CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS
ROBERT R. WOZNIEWICZ, CIVIL ACTION -- LAW
Plaintiff,
VS. POCKET NO.:
MARY K. WOZNIEWICZ, ?N DIVORCE
Defendant
COMPLAINT
COUNT I - DIVORCE UNDER 83301(c) or 53301(d) OF THE DIVORCE CODE
1. Plaintiff is Robert R. Wozniewicz, who currently resides at 80 Pine Creek Drive,
Carlisle, Pennsylvania 17013.
2. Defendant is Mary K. Wozniewicz, who currently resides at 80 Pine Creek Drive,
Carlisle, 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. Plaintiff and Defendant were married on January 28, 1984 in Schuylkill County,
Pennsylvania.
5. The parties have no minor children of this marriage.
6. A prior action for divorce was filed in Dauphin County, Pennsylvania and
docketed to 2005-CV-2516-DV. This action was dismissed on February 12, 2009 for docket
inactivity.
7. Neither party is presently a member of the Armed Forces on active duty.
8. Plaintiff has been advised that counseling is available and that he may have the
right to request that the court require the parties to participate in counseling. Being so advised,
Plaintiff does not request that the Court require the parties to participate in counseling prior to a
Divorce Decree being issued.
9. The cause of action and sections of the Divorce Code under which Plaintiff is
proceeding are:
(a) §3301(c). The marriage of the parties is irretrievably broken; and
(b) §3301(d). The marriage of the parties is irretrievably broken and, at the
appropriate time, Plaintiff will submit an affidavit stating that the parties have been living
separate and apart for a period of at least two (2) years.
10. Plaintiff requests This Honorable Court enter a Decree of Divorce.
WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order
dissolving the marriage between Plaintiff and Defendant.
COLGAN MARZZACCO, LLC
Date:
by: Timothy . squire
Attorney for Defendant
Attorney I.D. #77944
130 West Church Street
Suite 100
Dillsburg, PA 17019
(717) 502-5000
VERIFICATION
I, Robert R. Wozniewicz, verify that the statements made in this Complaint are true and
correct to the best of my knowledge, information, and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa. CS. §4904, relating to unsworn falsification to
authorities.
T
Date: d
BE T R. ZNIE W]
Plaintiff /
o f c V,y,
David D. Buell" s e p Renee K Simpson
z
cProthonotary ' � D 1S` Deputy cProthonotary
� pie
11 t° Irene E. J�lorrow
Kirks. Sofionage, ESQ, Nut
Solicitor 7750 2"d Deputy Prothonotary
Office of the Prothonotary
Cumberland County, Pennsylvania
lo --/141/ CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH
PA R.C.P.230.2.
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Fax(717)240-6573