HomeMy WebLinkAbout04-4846ZDE~ TOMIC,
Plaintiff'
VS.
DKAGAN TOMIC,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - AT LAW IN DIVORCE
NOTICE TO DE]FEND AND CLAIM RIGHTS
YOU ltAVE 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 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, Harrisburg Pennsylvania.
IF YOU DO NOT FI'I,F, 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 ~LP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(800) 990-~08
ZDENKA TOM/C,
Plaintiff
VS.
DRAGAN TOMIC,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION- AT LAW IN DIVORCE
COlVlPLAINT FOR DIVORCE
AND NOW, comes the above captioned Plaintiff, Zdenka Tomic, through her attorneys,
The Law Offices of Patrick F. Lauer, Jr., L.L.C, and makes the following averments:
1. Plaintiff is Zdenka Tomi¢, an adult individual, who currently resides at 860 Walnut
Street, Lemoyne, Cumberland County, and State of Pennsylvania.
2. Defendant is Dragan Tomic, an adult individual, who currently resides at currently
resides at 860 Walnut Street, Lemoyne, Cumberland County, and State of Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for a period of more than six (6) months immediately preceding the filing of this
Complaint.
COUNT I- COMPLAINT FOR DIVORCE
PURSUANT TO $301(e't AND $:~01(d} OF THE DIVORCE CODE
The Plaintiff, through her attorney's, seeks to obtain a Decree in Divorce from the above
named Defendant, Dragan Tomic, upon the grounds hereinafter set forth:
4. Paragraphs one (1) through three (3) are incorporated herein through reference.
5. The Plaintiff and Defendant were married on July 21, 1987.
6. There has been no prior action for divorce or annulment instituted by either of the
parties in this or any other jurisdiction.
7. The 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.
8. The Plaintiff avers that the marriage is irretrievably broken.
WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter a Decree
in Divorce.
Respcc~/~lly b 'e
i)~el~ D. Caraciolo, Esquire
,~/I08 Market Street, Aztec Building
/,Camp Hill, Pennsylvania 17011-4706
ID8 90919 Tel. (717) 763-1800
ZDENKA TOMIC,
Plaintiff
DRAGAN TOMIC,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No.
:
: CIVIL ACTION- AT LAW IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint for Divorce are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904,
relating to un*worn falsification to authorities.
Date: ~ 2./~ (57(( Signature:
Zdenka Tomic
ZDENKA TOMIC,
Plaintiff
VS.
DRAGAN TOMIC,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: No.
: CIVIL ACTION- AT LAW IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing Complaint for Divorce
upon the person and in the manner indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by mailing a copy of the same, certified mail, remm
receipt requested, to the person named as follows:
Dragan Tomic
860 Walnut Street
Lemoyne, PA 17043
~/~i//Jarastr °/~~uilding
tCamp Hill, Pennsylvania 17011-4706
90919 Tel. (717) 763-1800
ZDENKA TOMIC,
Plaintiff
VS.
DRAGAN TOMIC,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: No. 044846 Cix41 Term
:
: CIVIL ACTION' - AT LAW IN DIVORCE
.
PRAECIPE WITHDRAWING CUSTODY COMPLAINT
To Prothonotary:
Kindly withdraw the Complaint for Divorce for the above captioned civil action on behalf of
my client, Zdenka Tomic.
~ 108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 90919' Tel. (717) 763-1800