HomeMy WebLinkAbout01-4965TRUDI L. PELCZYNSKI,
Plaintiff
STEVEN M. PELCZYNSKI,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. q
IN DIVORCE
NOTICE
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 Court House, High and Hanover Streets, Carlisle.
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 F1ND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone: (717) 249-3166
TRUDI L. PELCZYNSKI,
Plaintiff
V.
STEVEN M. PELCZYNSKI,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: No. qq¢$
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) or(d)
OF THE DIVORCE CODE
1. Plaintiffis Trudi L. Pelczynski, who currently resides at 1111 East Lisburn Road,
Mechaniesburg, Cumberland County, Pennsylvania, 17055 for the past thirty-two years.
2. Defendant is Steven M. Pelczynski, who currently resides at 1111 East Lisburn Road,
Mechanicsburg, Cumberland County, Pennsylvania, 17055 for the past five years.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on September 9, 1995, in Hershey, Dauphin County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available, and that Plaintiffmay have the right
to request that the Court require the parties to participate in counseling.
8. Plaintiffrequests the Court to enter a Decree in Divorce.
I verify that the statements made in this Complaint are tree and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S § 4904, relating to unswom
falsification to authorities.
Trudi L. Pelczynski, ltlla~tiff
BY: Gr~e'~utde~r~~
Attorney for Plaintiff
50 E. High Street
Carlisle, PA 17013
(717) 258-8558
ID # 73471
TRUDI L. PELCZYNSKI,
STEVEN M. PELCZYNSKI,
Plaintiff
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
:
: NO. 01-4965 Civil
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
AND NOW, this 6th day of September, 2001, I, Heather L. Smith, hereby swear that I have
served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter,
upon the Defendant by hand delivery.
LAW OFFICES OF PAUL BRADFORD ORR
Heather L Smith
Paralegal