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Home My WebLink About14-4013 �► i` Liliya Krapova, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Veniamian Voshchilo, -0:K =' Defendant '' �= NO. til 4013 CIVIL TERM C v Ci-r= NOTICE TO DEFEND AND CLAIM RIGHTS C-D C_ti YCJJ ou have been sued in court. If you wish to defend against the claims set forth'in Chi 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 right 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 LAWYER, GO TO OR TELE PHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford St. Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. .1 f' 4' Liliya Krapova, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Veniamian Voshchilo, Defendant NO. CIVIL TERM DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION COUNT The plaintiff, Ms. Liliya Krapova, by her attorneys,the Community Law Clinic, sets forth the following causes of action in divorce: COUNT DIVORCE UNDER TITLE 23 Pa. C.S. §§3301(a),c) and(d) OF THE DIVORCE CODE 1. Plaintiff is Liliya Krapova, who currently resides at 435 First Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Veniamian Voshchilo, who currently resides at 111 NE 63rd street, Ocala, Marion County, Florida. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 9, 2009 in Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since September 16, 2013. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 8. Defendant has offered such indignities to Plaintiff as to make her condition intolerable and life burdensome. 9 9. Plaintiff has been advised that counseling is available and that she may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. COUNT II EQUITABLE DISTRIBUTION 10. Plaintiff repeats and realleges paragraphs one through nine as if fully set forth herein. 11. Plaintiff and Defendant have acquired property during their marriage, including, but not limited to: a. Property at 111 NE 63rd street, Ocala, Marion County, Florida. b. Debt in the amount of$6,998.12 on six credit cards opened by Mr. Voshchilo in Ms. Krapova's name. WHEREFORE, Plaintiff requests the court to enter a decree dividing the property equitably between the parties and other such relief as the court deems just. Respectfully submitted, Date � ! Andrew O'Grady Certified Legal Intern MEGA RIESMEYER Supervising Attorney Community Law Clinic 371 West South Street Carlisle,Pennsylvania 17013 (717) 243-3696 Fax: (717)241-3596 VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge 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. Dated: 07 -d7 Liliy ap� a Liliya Krapova, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA - V. CIVIL ACTION-LAW DIVORCE Veniamian Voshchilo, ). Defendant NO. r X1013 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Liliya Krapova, Plaintiff, to proceed in forma pauperis. The Community Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date 0`7-15"7 Andrew O'Grady Certified Legal Intern A-4m &&� MEGANYUESMEYER Supervising Attorney Community Law Clinic 371 West South Street Carlisle,Pennsylvania 17013 (717) 243-3696 Fax: (717)241-3596 Liliya Krapova, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW DIVORCE Veniamian Voshchilo, Defendant NO. 14-4013 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint at the above -captioned docket. Date: October 28, 2014 Fp Andrew O'Grady Certified Legal Intern Megan ' 'esmeyer Supervising Attorney Liliya Krapova, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : DIVORCE : NO. 14-4013 CIVIL TERM CERTIFICATE OF SERVICE Veniamian Voshchilo, Defendant () I, Gabriella H. Grosso, Certified Legal Intern, Community Law Clinic, hereby certify that a true and correct copy of the Divorce Complaint in the above -captioned matter was served on Defendant Veniamian Voshchilo, residing at 111 N.E. 63" Street, Ocala, FL, 34479, by the Sheriff's Department of Marion County, Florida. Service was complete upon receipt by Mr. Veniamian Voshchilo , on the 26th day of November, 2014 as evidenced by the enclosed return of service. Gabriella H. Grosso Certified Legal Intern COMMUNITY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 241-3596 SHE IFF MARION -COUNTY SEitVICE #: S14020228 TYPE OF: SUMMONS PLAINTIFF: KRAPOVA, LILIYA DEFENDANT: VOSHCHILO, VENIAMIAN RETURN TO: COMMUNITY LAW CLINIC ADDRESS: 45 NORTH PITT ST CITY: CARLISLE, PA 17013 POE: DESC: DIRECTIONS: COMMENTS: DIVORCE COMPLAINT AND NOTICE TO DEFEND AND CLAIM RIGHTS//PRAECIPE TO REINSTATE COMPLAINT SHERIFF'S RETURN OF SERVICE 1111111111111111111111111111111111111111111111111111111 ACCOUNT #: A14002514 CASE #: 144013 COURT: CUMBERLAND COUNTY COUNTY COURT DATE: DUE DATE: SERVE: VENIAMIN VOSHCHILO ADDRESS: 111 NE 63RD ST CITY: OCALA, FL 34479 Rew i on the 3 day of November A.D. 2014 and served same on the within named at A.D. 2014 in Marion County, Florida \ININDIVIDUAL By delivering a true copy of this writ with the date and hour of service endorsed thereon by nie and a true copy of the initial pleading. SUBSTITUTE By delivering a true copy of this writ with the date and hour of service endorsed thereon by me and a copy of the initial pleading by leaving the copies at (his/her) usual place of abode with a resident of the household above the age of 15 years, to -wit: and informing the person of the contents thereof. it q6— on the day of (Name and Relationship) CORPORATION By delivering a true copy of this writ with the date and hour of service endorsed thereon by me and a copy of the initial pleadings to as of said corporation: In the absence of the President, Vice President, Cashier, Treasurer, Secretary, General Manager, Director or any officer. (as defined in FS 48.081(1)). To as registered agent of the within named Corporation (as defined in FS 48.091(1)). To as an employee of the within named corporation at said corporation's place of business because service could not be made on the registered agent for failure to comply with FS 48.091 thereby complying with 48.081(3). _POSTING By posting on the premises located at a true copy of this writ with the date and hour of service endorsed thereon by me and a copy of the inital pleadings attached to a conspicuous place on the property described within after making two (2) attempts not less than six (6) hours apart in that the tenant could not be found and there was no person on the property residing therein, fifteen (15) years of age or older upon whom service could be made. OTHER NON -SERVICE For the reason that atter diligent search and inquiry failed to find said _COMMENTS CHRIS 1ERIFF BY B eputy Sheriff Note: Only that service indicated by the X is applicable to this return. ORIGINAL COPY MCSO FORM #CIV 101 DEC 2010