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Home My WebLink About05-0390 Suzanne M. Stezin IN THE COURT OF COMMON PLEAS PLAINTIFF, ) ) ) CUMBERLAND COUNTY, PENNSYLVANIA ) v. ) CIVIL DIVISION ) ) t:J5' 390 ~ ) NO. DEFENDANT ) NOTICE TO DEFEND AND CLAIM RIGHTS Victor B. Stezin YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 DNORCE 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 CHILD(REN), WHEN THE GROUND FOR THE DNORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARIAGE, YOU MAY REQUEST MARRIAGE COUNSELING, A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle ,PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES BEFORE A DNORCE 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, LAWYERS REFERRAL SERVICE 4th Floor, Cumberland County Couthouse Carlisle, PA 17013 Telephone: (717 ) 240-6 00 For P ti ner Address: 98 Cente Newville, PA Telephone: (717 ) 776-4656 , -~ - Victor B. Stezin ( IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( (CUMBERLAND_COUNTY, PENNSYLVANIA ( ( CML DIVISION ( (NO: V. Suzanne M. Stezin DEFENDANT, COMPLAINT IN DIVORCE AND NOW COMES, the Petitioner, Victor B. Stezin. by FILING PRO SE, who files this Complaint in Divorce statement of which is as follow: I, The Petitioner is Husband, and adult individual currently residing at 98 Center Road. Newville P A. 2, The Defendant is Wife, and adult individual currently residing at 807 South Market Street. Mechanicsbur!!. P A. 3, The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4, The Petitioner and Respondent were married on date: June 5. 1982 in the State of New Jersey. 5. There are 4 children born of this marriage. Name(s) Joshua Allin!!. Me<>an Rene. ChristoDher John and Sarah Elizabeth. Birthdate(s):5/23/83. 11/1/84. 8/26/86. 4110/88. 6, Neither party is a member of any branch of military. 7. The marriage is irretrievable broken, 8, The Petitioner, Victor B. Stezin. respectfully requests this Honorable Court to grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code Resp ~ I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa, C.S.A. Section 4904, relating to unsworn falsification to authorities. Dated I ,II 2...} 0 .S- ~ "" c:-~ c.;;..) '" "- a' ~ ':"> ~~ <- '- .,. '~';" ~ ~~ ..,..~~ ~ tr- f',' -'''" " ~. " \:j '\ 'V ',> "- -::"1 \ ~~ C. ..J;.- r:? ~ ' ~~ r u", ~~ t ~~ \ ~ ~ "- W '-^.' V \ ~ ~ w "'<\ '-J '-.. '^' }.j '-J ~ ~ / I ~ Victor B. Stezin IN THE COURT OF COMMON PLEAS PLAINTIFF, ) ) ) Cumberland COUNTY,PENNSYLVANIA ) v. ) CIVIL DIVISION ) ) NO. Of)-3~?o Suzanne M, Stezin ) DEFENDANT ) ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE PLEASE take notice that I, Suzanne M. Stezin _, Defendant, was provided with a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept service of same, I further enter my appearance in this action for all purposed, en ant Addr s:807 South Marke street M;;Chanicsburg. PA 17055 Telephone: <2!.L-Y 790-0428 ,- .' ~- l -'.'1 c-" C!; -., VICTOR B. STEZIN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 05-390 : CIVIL ACTION - LAW SUZANNE M. STEZIN, : IN DIVORCE Defendant. NOTICE TO PLEAD TO: Victor B. Stezin 98 Center Road Newville, P A 17241 You are hereby notified to plead to the within document within twenty (20) days after service hereof, or a default judgment may be entered against you. Respectfully submitted, AGNER & SPREHA By agner, Esquire /1.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 DATE: 3/1{"/1'0 , / Attorney for Defendant VICTOR B. STEZIN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 05-390 Civil CIVIL ACTION - LAW SUZANNE M. STEZIN, IN DIVORCE Defendant. ANSWER TO COMPLAINT IN DIVORCE WITH ADDITIONAL COUNTS ANSWER AND NOW, comes the Defendant, Suzanne M, Stezin, by and through her attorneys, Mancke, Wagner & Spreha, and files the following Answer to the Complaint in Divorce: 1. Admitted. 2. Admitted, however, the Defendant now resides at 11361 Capistrano Court, Fort Myers, Florida, 33908-4034. 3, Admitted, 4. Admitted. 5. Admitted. 6, Admitted. 7. Admitted. 8. Admitted, COUNT II ALIMONY PENDENTE LITE COUNSEL FEES. COSTS AND EXPENSES 9. Paragraphs I through 8 above are incorporated herein by reference and made a part hereof. 10. By reason of this action, Defendant will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. II. The Defendant is without sufficient funds to support herself and to meet the costs and expenses of this litigation and unable to appropriately maintain herself during the pendency of this action. 12, The Defendant's income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the cost of this litigation. 13, The Plaintiff has adequate earnings to provide support for the Defendant and to pay her counsel fees and expenses. COUNT III ALIMONY 14. Paragraphs I through 13 above are incorporated herein by reference and made a part hereof. 15, Defendant lacks sufficient property to provide for her reasonable needs. -2- 16. Defendant is unable to sufficiently support herself through appropriate employment. 17, Plaintiff has sufficient income and assets to provide continuing support for the Defendant. WHEREFORE, Defendant prays this Honorable Court: (a) Enter a Decree in Divorce; (b) Compel the Plaintiff to pay alimony pendente lite to the Defendant; (c) Compel the Plaintiff to pay alimony to the Defendant; (d) Compel the Plaintiff to pay the Defendant's counsel fees, costs and expenses and the costs and expenses of this action; and (e) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, Mancke, Wagner & Spreha t/ .~/ J _ " /'" By " ,P.' ard Wagner, Esquire .D. #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorneys for Defendant Date: .,j/;rN~ / -3- VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~(L41AiL SIa;~\ DATE: d-- /().d-/{)~ I { CERTIFICATE OF SERVICE I, Debra K. Spinner, secretary in the law firm of Mancke, Wagner & Spreha, do hereby certifY that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: Mr. Victor Stezin 98 Center Road Newville, PA 17241 By ~r~sp~~r~~:;:V Mancke, Wagner & Spreha 2233 North Front Street Harrisburg, P A 1711 0 P. Richard Wagner, Esquire Attorney for Defendant Date: 3// iR/ t' & / / (:::J \~ rt fA) ---::z l..J '---0 -- -"( u( ..0 C/ ---.() 11-> /' ,'"- if-J \) DC) t \> 1 (-". (j C' _ I' ~~~) -i~ '?'~ ( -<.-...... ~, ."..~. o 'n 'c; -r_ "T', \" n ;~~'~ i...., "'-..) ('.,) -,:; c.) ( ,.) t...:::'l ~ '-<: . " ~ IIAIlOLD So I"''', III, DQUI_ ATTOIIIIn ID 110. 288ZO .. SOUTH PITT STReET CARLI8L~ PA 17013 (717) 243-8OH ATTOIUIBY FOIl......DAIIT VICTOR B. STEZIN, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW . . SUZANNE M. STEZIN, : NO. 2005 . 0390 CIVIL TERM Defendant : CIVIL ACTION - LAW PLAINTIFF'S ANSWER TO DEFENDANT'S ADDITIONAL COUNTS NOW, comes the plaintiff, by his attorneys, Irwin & Bayley, Esquires, and responds to defendant's additional counts for economic relief, representing as follows: COUNT .. ALIMONY PENDENTE UTE. ATTORNEY FEES. COSTS AND EXPENSES 9. Plaintiff incorporates by reference the averments contained in paragraphs one through eight of his complaint, except that plaintiff admits that defendant now lives at the new address referred to in paragraph two of her answer. 10. The averments of paragraph ten of defendant's Count II are denied. On the contrary, if defendant is reasonable in her demands there is no reason why she should incur considerable expense. In addition, both parties will incur the costs of retaining legal counsel and preparing their case and both parties have sufficient income or other resources to pay such costs. Accordingly, both parties should be required to pay their own costs. J 11. The averments of paragraph eleven of defendant's Count II are denied. On the contrary, both parties will incur the costs of retaining legal counsel and preparing their case and both parties have sufficient income or other resources to pay such costs and appropriately maintain herself during these proceedings. Accordingly, both parties should be required to pay their own costs. 12. The averments of paragraph twelve of defendant's Count II are denied. On the contrary, both parties will incur the costs of retaining legal counsel and preparing their case and both parties have sufficient income or other resources to pay such costs and appropriately maintain themselves during these proceedings. Accordingly, both parties should be required to pay their own costs. 13. The averments of paragraph thirteen of defendant's Count II are denied. On the contrary, both parties will incur the costs of retaining legal counsel and preparing their case and both parties have sufficient income or other resources to pay such costs and appropriately maintain themselves during these proceedings. Accordingly, both parties should be required to pay their own costs. WHEREFORE, the plaintiff requests that the Court dismiss defendant's claim for alimony pendente lite, attorney fees, costs and expenses. COUNT III ALIMONY 14. Plaintiff incorporates by reference the averments contained in paragraphs one through eight of his complaint, except that plaintiff admits that defendant now lives at the new address referred to in paragraph two of her answer. Plaintiff also incorporates by reference his responses to defendant's additional counts, paragraphs nine through thirteen. J . ' 15. The averments of paragraph fifteen of defendant's Count III are denied. On the contrary, plaintiff believes and therefor avers that defendant has sufficient income or other resources to provide for her reasonable needs. 16. The averments of paragraph sixteen of defendant's Count III are denied. On the contrary, plaintiff believes and therefor avers that defendant has sufficient income or other resources to provide for her reasonable needs. 17. The averments of paragraph seventeen of defendant's Count III are denied. On the contrary, both parties have sufficient income or other resources to appropriately maintain themselves during these proceedings. Accordingly, both parties should be required to provide for their own support. WHEREFORE, the plaintiff requests that the Court dismiss defendant's claim for alimony, alimony pendente lite, attorney fees, costs and expenses I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. ..- June ~ ,2006 o ~~; ~ ::1 -~ r--..> = c:::} co,... o -n .-1 :r.:-n me;:; L~) N \-? c... S ..."'....... :s -.~1 f ~~ ~::;; -,...; ~b ~ -'~,"" ;- (Xl Ys. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW VICTOR B. STEZIN, Plaintiff SUZANNE M. STEZIN, Defendant : NO. 2005 - 0390 CIVIL TERM : CIVIL ACTION - LAW AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about January 21,2005. Service of the complaint was made by certified mail, return receipt requested, on February 4, 2005 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. October .~ I ,2006 . ~S, / " ~ . &LiA., SUZA NE M. STEZIN . - WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33011c) OF THE DIVORCE CODE 1 . I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. October 3..L, 2006 ~ 111 ~: 1lA1.1!~' -' SUZAN"NE .STEZIN . o ~; ,...." ~? C._..,,"} 0'""< o --n -{ .,.. hi 71 r- -om '.f",!l ~..< ....;... ;C' 2:~ -.:::: w N .. -~~'~ f- ,'~: . -'.n'i 53 ~-:o -< o o HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 28920 84 SOUTH PITT STREET CARLISLE PA 17013 (717) 2a-8080 ATTORNEY FOR PLAlNnFF VICTOR B. STEZIN, Plaintiff Ys. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW SUZANNE M. STEZIN, Defendant : NO. 2005 - 0390 CIVIL TERM : CIVIL ACTION - LAW 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: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: On or June 10, 2006, defendant was served with a copy of the divorce complaint by U.S. Mail (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: November 4, 2006 By the defendant: October 31, 2006 (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301 (c) divorce was filed with the Prothonotary: November 6, 2006 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: November 13, 2 6 November 13, 2006 HAROLD S. IRWIN, III Attorney for Plaintiff C) "" 0 = G (:;;;) -n e;r. -,.. c=:; ~ w 1'>) C'J ~JJ 0 .< VICTOR B. STEZIN, Plaintiff Ys. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW SUZANNE M. STEZIN, Defendant : NO. 2005 . 0390 CIVIL TERM : CIVIL ACTION. LAW AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about January 21, 2005. Service of the complaint was made by certified mail, return receipt requested, on February 4, 2005 (see acceptance of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. /II/) fI'. _ L1 ,-()"luber ~, 2006 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 tC) OF THE DIVORCE CODE 1 . I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. ~~~~ber -1-. 2006 ... o f~, -)1 ~~., ~ c;;> c:r- - ::~ d..... I ~ o -n ~-n 01 r::: -0,,"1-"\ -10 i'~\ t~:)\ ~ ~ .- ( " "~~(1 ':::~ '~::;lo' <'0 :....::. -0 -:- -- ~ N ~ ~ ~o. ~ Q Q ~ Q Q ~ Q ~ Q Q Q Q ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Q ~ ~ Q ~ ~ ~ ~ ~ Q ~ ~ Q ~ ~ ~ ~ Q ~ ~ Q ~ ~ Q ~ ~ ~ ~ ~ ~ ~ Q ~ ~ ~ ~ Q ~ ~ ~ ~ Q Q ~ ~ Q ~ ~ Q ~ Q Q ~ ~ ~ ~ ~ ~ ~ Q Q Q Q ~ ~ Q ~ ~ Q ~ Q ~ ~ ~ ~ Q "0"0"0":-0"0. 0. 0.'0. if. if. :Ii:li if. if. if. :.; if.if.:liif. if. i+i if.:Ii if.if. if. if.if. if.if.:';if.:';if.:'; :Ii:';:';:'; if.i+iif.if.:';~~:';i+ii+ii+i:';i+i IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. VICTOR B. STEZIN Plaintiff No. ?001; O~QO (",T\TTL T~RM VERSUS SUZANNE M. STEZIN Defendant DECREE IN DIVORCE AND NOW, N ()\Jt.~\ t.;- \5' , lWo , IT IS ORDERED AND DECREED THAT VICTOR B. STEZIN , PLAI NTI FF, AND SUZANNE M. STEZIN , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE PROTHONOTARY :f.:.; :f.i+i,.,"'''' "',., "''''''',.,:f. :f.~~"'~~~:';~~~:ti:ti:ti"'i+i'" ~i+ii+ii+i"'~i+i:';i+i:ti,.,:ti,.,~~ i+i:ti:ti~i+i J. _~fC ~ ~ ~ ~ -?- ~'k,-; 'r'l " >'.'.. .~} ~ .'7>' .. .....+., ;: d}(}. It=> .J! 'J(J' le.}/