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Home My WebLink About05-0751PAUL LUJANAC, Plaintiff V. LEONORE LUJANAC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 0 S 75?1 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YQV 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 COUNTYBAR ASSOCIATION 32 SOUTHBEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 PAUL LUJANAC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. : NO. 05 - '7.5'1 CIVIL TERM LEONORE LUJANAC, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Paul Lujanac, who currently resides at 61 Burd Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Leonore Lujanac, who currently resides at 3305 Market Street, Camp Hill, Pennsylvania 17011. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 1, 1985, at Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since July 16, 2004, and continue to do so. 8. 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 such counseling. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from February 1, 1985, to July 16, 2004, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. F DATE Respectfully submitted, ABOM & KUTULAKis, L.L.P. s Kara W. Haggerty 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 86914 VERIFICATION I, PAUL LUJANAC, verify that the statements made in this Divorce 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.C.S. § 4904 relating to unsworn falsification to authorities. Date L- /-! _- -? PAUL LUJ A -t, -, 1 4?1 \ 1... a O p ?:, c V\ ?? cam',-? G li r PAUL LUJANAC, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PA V.. NO. 05-751 CIVIL TERM LEONORE LUJANAC, . CIVIL ACTION - LAW Defendant . IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on February 10, 2005, at Carlisle, Pennsylvania, addressed as follows: Leonore Lujanac 3305 Market Street Camp Hill, PA 17011 Return card acknowledging receipt on February 11, 2005, is attached as Exhibit "A". ABom & KuTuLAKis, LLP Date: OZ t} Q? ?/JjctLZCKara W. Haggertyr 36 South Hanover Str Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 86914 ¦ Carnpiete kerns 1, 2 rq 9.Mda A?eked.eottyl?s Bern 4 k Reetelcbd 0 AWd DelNrry ¦ Pdta your name and addeee on the reverse X ,Q.....?,... 0 Addte"W so that we can )etum the cod to you, & bjefWA sdNall C..__.. of 0 Attach this cad to the back of the tneMpleca, ?. or on the front H space peffft D. Md0myaddtaes dAMOAWlisin M f4 t.Arodendareeeedw: tfYftmtbrd*mv eaerbebw 0NO 3 30 ? `?. U-sr 0kw ad MIN 0COAX- 4, RnMcWDrWery O!kftW nrdcls waqar 2. nb?V,tsenl'cerottdp 7003 3110 0004 5769 8150 P$ Form 3811, February 2004 Domeetto Return ReWot 7025e6-02•hYtarp EXHIBIT "A" w 41 PAUL LUJANAC, Plaintiff V. LEONORE LUJANAC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-751 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE STATEMENT OF INTENTION TO PROCEED TO THE COURT: Plaintiff, Paul Lujanac, intends to proceed with the above-captioned matter. Respectfully submitted, Asom & KUTULAKi4 LLP r-A jC0 k Date: Lrl 12-Z Kara W. Haggerty, Esq e 36 South Hanover Stree Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 86914 CERTIFICATE OF SERVICE AND NOW, this 23`a day of September, 2008, I, Kara W. Haggerty, Esquire of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Statement of Intention to Proceed by First Class U.S. Mail addressed to the following: Michael J. Pykosh, Esquire Law Office of Darrell C. Dethlefs 2132 Market Street Camp Hill, PA 17011 &?- ?A/ Lot, t 0. L'o, C-6 Kara W. Haggerty, Es e U r$> fT N rn TIC) -?j'ct ABOM ?' KuTUVKis Kara %R . I la-,crt?, 1?syuirc Attorney I.D. #: 216914 2 West I ligh Street Carlisle, PA 17013 (717) 249-0900 Fj1 ... J .. A 1 I PH 2: 1? 17, 'UNBERLAP'D COUNT,, PENNSYLVANIA PAUL LU1ANAC, Plaintiff V. LEONORE LUJANAC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 05-751 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE TO THE PROTHONOTARY OF SAID COURT: PRAECIPE TO WITHDRAW COUNT II - EQUITABLE DISTRIBUTION FROM THE DIVORCE COMPLAINT AND NOW, comes the above named Plaintiff, Paul Lujanac, by and through attorney, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P., and wishes to Count II - Equitable Distribution fiom the Divorce Complaint that was filed on February 1 2005, due to the fact that the parties have satisfactorily divided all marital property. Respectfully submitted, DAB ABOM & KUTULAKls, L.L.P. LL lL' Kara W. Haggerty, Oj6 Supreme Court ID 14 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for the Plaintiff . -1 . CERTIFICATE OF SERVICE AND NOW, this 11th day of July, 2012, I, Kara W. haggerty, Esquire, of ABOM 4? KUTULAKIS, L.L.P., hereby certify that I did serve a true and correct copy of the Praecipe to Withdraw Count II - Equitable Distribution of the Divorce Complaint, by First Claos Mail addressed to the following: Michael J. Pykosh 2132 Market Street Camp Hill, PA 17011 DATE ????? III Respectfully submitted, ABOM & KUTULAKIS, L.L.P. Kara W. Haggerty, ?Zvl Supreme Court 14 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for the Plaintiff QED F' f?. OM & 2912 JUL I7 PAS 2* 24 KUTULAKIS ? ? I CUMBERLAND PSYLVAIA Kara W. Haggerty, Esquire Attorney I.D. #: 86914 2 West High Street Carlisle, PA 17013 (717) 249-0900 PAUL LUJANAC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 05-751 CIVIL TERM LEONORE LUJANAC, CIVIL ACTION - LAW Defendant IN DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE I, Kara W. Haggerty, Esquire, hereby certify that I did serve a true and correct copy of the Affidavit and Counter-Affidavit to Defendant's counsel, by depositing, or causing to be deposited, the U.S. mail, certified mail, postage prepaid, on Michael Pykosh, Esquire, at Camp Hill, addressed as follows: Michael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 Return card acknowledging receipt on July 13, 2012, is attached as Exhibit "A". KUTULA"S, LLP Date: t `tu /i L'. Kara W. Haggerty, Esq Attorney I.D. No: 8691 2 West High Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff (d) in lvania, ¦ Complete Items 1, 2, and 3. Also complete ItKn 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 mailpiece, or on the front if space permits. 1. Article Addressed to: /v,Cl-6d y/Lash, 5?tc ire ;-13A rnkr6f S?- Cf<pmp M// Ph- ON/ A. V v( u L*' I - U- Addressee ived by Pri N ) C. Date of QAivery D. Is delivery address different from Rem 1? ? Yes If YES, enter delivery address below: ? No 3. service 011* fi d?Mail ? Expo Mail ? Registered L14WRT Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? yes 2. ArticleNumbe 7008 3230 0002 8005 4091 Mansfer from - PS Fort 3011, February 2004 Domestic Return Receipt 102595-02-10-1540 EXHIBIT A OM ~' n~%~~.~ {~ ~~~ ~ LILAI~IS ~: i~ _~' . ' -- - Kara W. Haggerty, Esquire ~ ~ ~f ~- f , ~ " ' ~ ~ ~ ~ ~ ~ `~ ~`' ~ ~' a ~ ` ~~ Attorney LD. #: 86914 "'-`' ~~ ~' `~ 2 West High Street Carlisle, PA 17013 (?1?) 249-09(10 PAUL LUJANAC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA ~. NO. 05-751 CIVIL TERM LEONORE UJJANAC, CIVIL ACTION -LAW Defendant IN DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE I, Kara W. Haggerty, Esquire, hereb•j~ certify that I did serve a true and correct copy of the Ndtice of Intention to Request Entry of a Divorce Decree Under 3301 (d) of the Divorce Code and Counter-A~fidavit Under Section. 3301 (d) of the Divorce Code to Defendant's counsel, by depositing, or causing) to be deposited, same in the U.S. mail, certified mail, postage prepaid, on Michael Pykosh, Esquire, at Cat~p Hill, Pennsylvania, addressed as follows: Michael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 Return. card acknowledging receipt on August 9, 2012, is attached as Exhibit "A". ABOM & KUTUI.AKIS, LLP ~ _ _~ ~ ~ Z- ~L ~, lC ~ ~ - --~., Dater Kara W. Haggerty, Esquixe Attorney LD. No: 86914`~y~ `...~ 2 West High Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff ^ Complete items 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 mailpiece, or on the front if space permits. - 1. Article Addressed to: - l-~ rti D{~c~s o~ l~G r ~Q ~l C~'. ~~ t =, ~ r'~1wt ~4~ ~ Sfr~ ~C~~1 ~~~ ~-~r~~l, ~a 11011 vignature I ~ _` ,_., -Wi=t ~^ Addressee B. Received by (Printed Name C. Date of ~ ~i~verY C 1y1 a~r~.o ~ ~ Q6 oC _. address differdnt from item 1? ~ Y~ D. Is delivery If YES, enter delivery address below: ^ No 3. Serve ~YPe Certified Mail ^ Express Mail ^ Registered CCU-f~um Receipt for Merchandise ^ Insured Mail ^ C.O.D. _._. 4. Restricted Delivery? (Extra Fee) ^ Yes z. ArticlelJu 'DD8 323D DDD2 8DD5 4695 (Transfer frG...~.-.--~--~--^~-~-----~'- 102595-02-M-1540 Domestic Return Receipt PS Form 3811, February 2004 EXHIBIT A