HomeMy WebLinkAbout04-2876
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GINA L. ABROMITIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIL ACTION /1 ./~
NO. O'l-~'- L';oL.t.., JEn...rv1
IN DIVORCE L
NOT ICE
T 0
D E FEN D
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:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013-3387
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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
717-249-3166
"
GINA L. ABROMITIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIL ACTION
NO.
IN DIVORCE
NOTICE OF RIGHT TO COUNSELING
You are one of the parties in the above captioned action in
divorce. By virtue of Section 202 of the Pennsylvania Divorce
Code, it is a duty of the Court to advise both parties of the
availability of counseling and upon request of either provide both
parties a list of qualified professionals who provide such
services.
Accordingly, if you desire counseling a list of marriage
counselors is available in the Office of the Prothonotary at:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013-3387
Prothonotary
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GINA L. ABROMITIS.
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIL ACTION
NO. 9~- .4"""
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Gina L. Abromitis, a citizen of Pennsylvania,
residing at 280 Juniper Drive, Etters, York County, Pennsylvania.
2. Defendant is James Abromitis, Jr., a citizen of Pennsylvania,
residing at 228 South High Street, Mechanicsburg, Cumberland
County, Pennsylvania.
3. Plaintiff and Defendant are sui iuris and have been bonafide
residents of the Commonwealth of Pennsylvania for at least six
months immediately preceding the filing of this Complaint.
4. The parties are husband and wife and were lawfully married on
April 13, 1996, in Dauphin County, Pennsylvania.
5. The marriage is irretrievably broken.
6. Neither Plaintiff nor Defendant are in the military or naval
service of the United States or its allies within the provisions
of the Soldiers' & Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
7 . There has been no
instituted by either
jurisdiction.
prior
of the
action for divorce or annulment
parties in this or any other
"
8. The Plaintiff has been advised of
counseling and of the right to request that
parties to participate in counseling.
the availability of
the Court require the
COUNT I
Request for a Fault Divorce
Under 330l(a) (6) of the Divorce Code
9. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
10. Defendant has offered such indignities to the Plaintiff, who
is the innocent and injured spouse, as to render Plaintiff's
condition intolerable and life burdensome.
11. This action is not collusive.
12. Plaintiff has been advised of the availability of counseling
and that Plaintiff and Defendant have the right to request the
Court to require the parties to participate in such counseling.
WHEREFORE, Plaintiff respectfully requests that the Court
enter a Decree of Divorce, pursuant to 3301(a) (6) of the Divorce
Code.
COUNT II
Request for Divorce Due to Irretrievable Breakdown
Under 3301(c) of the Divorce Code
13. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
14. The marriage of the parties is irretrievably broken.
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15. After ninety (90) days have elapsed from the date of the
filing of this Complaint, plaintiff intends to file an affidavit
consenting to a divorce. plaintiff believes that Defendant may
also file such an affidavit.
16. Plaintiff has been advised of the availability of counseling
and that Plaintiff and Defendant have the right to request the
Court to require the parties to participate in such counseling.
WHEREFORE, if both parties file affidavits to a divorce after
ninety (90) days have elapsed from the filing of this Complaint,
plaintiff respectfully requests the Court to enter a Decree of
Divorce, pursuant to 3301(c) of the Divorce Code.
COUNT III
Request for Divorce Due to Irretrievable Breakdown
Under 330l(d) of the Divorce Code
17. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
18. The marriage of the parties is irretrievably broken.
19. After a period of two (2) years has elapsed from the date of
separation, Plaintiff intends to file her affidavit of having
lived separate and apart.
20. Plaintiff has been advised of the availability of counseling
and that Plaintiff and Defendant have the right to request the
Court to require the parties to participate in such counseling.
WHEREFORE,
separation and
if two (2)
Plaintiff
years have elapsed from the date of
has filed her affidavit, Plaintiff
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respectfully requests the Court to enter a Decree of Divorce,
pursuant to 3301(d) of the Divorce Code.
Respectfully submitted,
DISSINGER and DISSINGER
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Attorney for Plaintiff
Supreme Court rD # 27736
28 N. 32nd Street
Camp Hill, PA 17011
(717) 975-2840
"
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VERIFICATION
I, Gina L. Abromitis, verify that the statements made in the
Divorce 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.
Wfft2 yJiU~~
~~L. ~o~itis, Plaintiff
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GINA L. ABROMITIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIL, ACTION
NO. 04-2876 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF MAILING
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
Mary A. Etter Dissinger, attorney for Plaintiff, being duly
sworn according to law, says that she mailed by United States
Certified Mail, Restricted Delivery, a true and correct copy of
the Plaintiff I s Complaint in Divorce in this action to the
Defendant at his residence, and that Defendant did receive same as
evidenced by the signed receipt dated June 25, 2004, attached
hereto as Exhibit "A".
~~.~t~~
Attorney for Plaintiff
Supreme Court ID #27736
28 North Thirty-second Street
Camp Hill, PA 17011
(717) 975-2840
Sworn to and subscribed
before me this twenty-eighth (28th)
day of June, 2004.
~o.~
Notary Public
NOTARIALSEAL
MEGAN A. LABASHOSKY....., N*
Can., HllIonI. ~,ib.lI.lldCiUtY
My c....nJlllrn EllpnI NcIv. 18. 2lIOI
11
. Complete ~ems 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the front if space permits.
,. Article Addressed to:
3Cl.t"\N. ~ A I::lto~~; S,; Jr.
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o Insured Mail 0 C.O.D.
4. Restril;ted Delivery? (Extra Fee)
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2. Article Number
(Transfer from service label)
PS Form 3811, August 2001
7003 3110 0002 7192 6873
Domestic Return Receipt
10259S-Q1-M.2509
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II
GINA L. ABROMITIS,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIl, ACTION
NO. 04-2876 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A Complaint in divorce under s 3301(c) of the Divorce Code was
filed on June 23, 2004 and served on J"une 25, 2004.
2. The marriage of Plaintiff and Defendant is irretrievably broken
nd 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 in divorce without
otice.
I understand that I may lose rights concerning alimony, alimony
endente lite, marital property, division of property or lawyer fees
nd expenses if I do not claim them before a divorce is granted.
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
o me immediately after it is filed with the~rothonotary.
6. Plaintiff's and Defendant's
ivorce are being filed with the
espective consent documents.
Waiver of Notice in s3301(c)
Prothonotary as a part of their
I verify that the statements made in this affidavit are true
nd correct. I understand that false statements herein are made
ubject to the penalties of 18 Pa. C.S. s4904 relating to unsworn
alsification to authorities.
ate: jU/-tP.5
,i/j~iA$~~
'Wa L.J'Abromitis, Plai tiff
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GINA L. ABROMITIS,
Plaintiff
IN TaE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIL ACTION
NO. 04-2876 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A Complaint in divorce under ~ 3301(c) of the Divorce Code was
filed on June 23, 2004 and served on crune 25, 2004.
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 in divorce without
notice.
4. I understand that I may lose rights concerning alimony, alimony
pendente lite, marital property, division of property or lawyer fees
and expenses if I do not claim them before a divorce is granted.
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.
6. Plaintiff's and Defendant's
Divorce are being filed with the
respective consent documents.
Waiver of Notice in ~3301(c)
Prothonotary as a part of their
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:~/-J/()5
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~=s Abromitis, Jr., Def
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II
GINA L. ABROMITIS,
plaintiff
IN THE COURT OF COMMON PLEAS
OF C'~BERLAND COUNTY
PENNSYLVANIA
vs.
JAMES ABROMITIS, JR.,
Defendant
CIVIL ACTION
NO. 04-2876 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information,
to the Court for entry of a divorce decree:
1. Ground for divorce:
3301(c) of the Divorce Code.
Irretrievable breakdown under s
2. Date and manner of service of the Complaint: June 25,
2004, by United States Certified Mail, Restricted Delivery.
3 .
s 3301 (c)
Defendant
Date of execution of the
of the Divorce Code:
March 4, 2005.
Affidavit of Consent required by
By Plaintiff March 4, 2005; by
4. Related claims pending: NONE.
5. Date Plaintiff's Waiver of Notice in s 3301(c) Divorce
filed with the Prothonotary: March 10, 2005
Date Defendant's Waiver of Notice in s 3301(c) Divorce
filed with the Prothonotary: March 10, 2005
Respectfully submitted,
DISSINGER AND DISSINGER
Date' ".I'of""
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/'/t"'^-I Lj\ tl(~,/J-^-<'1~"""'~" ^--"'--
Mary A. Etter Dissinger J
Attorney for Plaintiff
28 North 32nd Street
Camp Hill, PA 17011
717-975-2840
cc: James Abromitis, Jr.
Gina Abromitis
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
GINA L. ABROMITIS.
Plaintiff
No.
04-2876
VERSUS
JAMES ABROMITIS, JR.,
Defendant
DECREE IN
DIVORCE
Gina L. Abromitis
, PLAINTIFF,
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.20115", IT IS ORDERED AND
AND NOW,
/h bcA
DECREED THAT
James Abromitis,
Jr.
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONV.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
VET BEEN ENTERED;
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