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Home My WebLink About05-2195 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHIS, Plaintiff CIVIL ACTION - LAW vs. 1/9.5 No. of 2005 GERASIMOS DIONYSATOS, Defendant ACTION 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 t following pages, you must take prompt action. You are warned that if you fail to do so, the may proceed without you and a Decree of Divorce or Annulment may be entered against yo by the Court. A judgment may also be entered against you for any other claims or relief reques d in these papers by the Plaintiff. You may lose money or property or other rights important to y u, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown ofthe marriag , you may request marriage counseling. A list of marriage counselors is available in the Offic of the Prothonotary at Mifflin County Courthouse, Lewistown, Pennsylvania, 17044. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRAN D, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D 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. MidPenn Legal Services 2054 East College Avenue State College, PA 16801 (814) 238-4958 AMERICANS WIlli DISABILITIES ACT OF 1990 The Court of Common Pleas of Juniata 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 Co , please contact our office. All arrangements must be made at least 72 hours prior to any hearin or business before the Court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHIS, Plaintiff CIVIL ACTION - LAW vs. :;2 / 1-5- No, of 2005 GERASIMOS DIONYSA TOS, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) UNDER THE DIVORCE CODE DIVORCE AND NOW, comes the above-named Plaintiff, Theodora Tsarouhis, by her attorney, Donis Zagurskie, and seeks to obtain a divorce based upon the grounds hereinafter more fully set forth: 1. Plaintiff is Theodora Tsarouhis, an American citizen, whose address is 3537 Log St., Camp Hill, PA 17011, Cumberland County. 2. Defendant is Gerasimos Dionysatos , an citizen, who currently resides at Othonos 11, Agrinio, Greece 30100. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint, having resided from October 2002 until the date of separation at 3537 Logan St., Camp Hill, P 17011- the current address of the plaintiff 4. Plaintiff and Defendant were married on August 19, 2000 in Agrinio, Greece. 5. Parties separated on or about February 25, 2004. 5. There have been no prior actions in Divorce or Annulment of marriage between e parties hereto in this or any other jurisdiction. 6. Plaintiff seeks his divorce from Defendant on the following grounds: The marria e is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that he may have the ri ht to request the Court to require the parties to participate in counseling. 8. Parties are the parents of one child, Marco who was born on March 30, 2002 prim ry custody being with plaintiff/mother as per a custody order is already in place in the above c at Docket number 04-3494. 9. Plaintiff requests the Court to enter a Decree of Divorce, Theodora Tsarouhis - Plaintiff By Donis Hirakis Zagurskie Attorney for Plaintiff P,O. Box 399 Mifflin, P A 17058 7174365868 Date: i II j j ju '5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHIS, Plaintiff CIVIL ACTION - LAW vs. No. of2005 GERASIMOS DIONYSATOS, Defendant ACTION IN DIVORCE Verification: I verifY that the statements made in this Complaint are true and correct. I understand taht fa se statements herein are made subject tot he penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to autho 'ties. l-\-~1.05 -c:> ~ 9- ~. .s ::t-'Q r -.1-] \) IT- v:.) Iv'" -0 r--._ .....,.~ ~ --0 C'::::> '-.-":,, o (') """ 0 <= c "'" -n c~ <.n -4 ..-. :> -r) T..<,- ~:n y rnj;" -0 --;;-.- .... , ::0 .~ ~7. ;e- N -00 (J"'_:/:L -0 -l ,-) I -< ~-~ '::.-to r;:::.:" ~.- -r. 'J..;J ,.,. .-J-,-11 J~n ";2'" :x ~ c> L ~:.(~, B orn >'c -l a ~ ;?-: .r:- ,0 '< - .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHIS, Plaintiff vs. CIVIL ACTION - LAW 11"16 No. of2005 GERASIMOS DIONYSATOS, Defendant ACTION IN DIVORCE ACCEPTANCE OF SERVICE I, GERASIMOS DIONYSATOS, the above-captioned Defendant, accepts service of the Complaint in Divorce relative to the above-captioned matter. 2LMrun) ,2005 A'DIl~~kro! ~A1.I KiP GERASIMOS DIONYSATOS- Defendant Residing at0GW\ia> 1\ arPt IJID ~ .<.:t.. \~- '1,~;~: [D\2"!.- ~lW u..:r. j-' \:s \i"> If> - - ~ :2 ';:... C"> I c- r..> o ,r> =' ""' <.... ^""-':. ~"') o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW ~)95 No. of 2005 THEODORA TSAROUHIS, Plaintiff GERASIMOS DIONYSATOS, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE !, Konstantinos Zisimopoulos hereby state that on the 2g day of May, 2005 ! did personally serve a true and correct copy of the Notice to Defend and Claim Rights along with Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code upon Defendant, Gerasimos Dionysatos, at his last known address: Othonos II, Agrinio, Greece 30100. By: \.... ""' Date:2.2 ;1f C; Id ;:<00 j--- >; t,n :>-, ~ U") to;; ,,::-. 1""'-- =~ ~fs :;:: "'" ',::!-; r~~ '-.}:~ <") ;~ (~~~ , tuu_ ,-- ::.-.::!w u..:c (.;> {i 1-- c::> "'~~ lL 'r.> --, = ~ 0 = U '''' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHlS, Plaintiff CIVIL ACTION - LAW vs. J,IQ5 No. of2005 GERASIMOS DIONYSATOS, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under@ 330I@oftheDivorce Code was filed on,~,2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. @ 4904 relating to unsworn falsification to authorities. Date: gt'pWJhi'.II,.~,9a)~ ~aL1;{}AffiCu Theodora Tsarouhis, Plaintiff OS :S lid 8- 1.JO SOal ^' \~LI! u': ,f.;. !!V.! ' :It '1 ~O '-..Ii.-.. ,'C._" ,.\,-,,-,wO ....11 .:J 3Jt~~O{]31!:f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHIS, Plaintiff CIVIL ACTION - LAW vs. oUCfS No. of2005 GERASIMOS DIONYSATOS, Defendant ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER (a).3301@AND (a).33019(d) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights conceming 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. @ 4904 relating to unsworn falsification to authorities. DattX <;fau~ I~ atty( ~~~ Theodora Tsarouhis, Plaintiff ti- ~Z \'"'" UJQ t.)....:.;.-;- .<'> '1ft: 'U:::\\J- .(,:,J. ,uJ i-:t: .- D... o .. tn tn - - ..... :4 C'? I ,.... <.-" o ,r.> ~ ? '.':i:; ;,~:~ ~- ~j o IN mE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA THEODORA TSAROUHIS, Plaintiff CIVIL ACTION - LAW vs. J Iq5 No. of 2005 GERASIMOS DIONYSATOS, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under@ 3301f9 of the Divorce Code was filed on, Ape"\ a '7 ,2005, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. @ 4904 relating to unsworn falsification to authorities. Date: q - 2 - ~ (){)5 ~ -\ Gerasimos 'ionysatos, Defendant ._ \r:.{\\ SI$~l ,'~ 1\6 't, ~ ~s.v " ,,/?:\- ~p ,.\,.,,,,,...,<(]. -;:i j' ',1\ d;~J::';-))::;S :\C\ ,u .-' ?{:'k):'I.-, - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA THEODORA TSAROUHlS, Plaintiff CIVIL ACTION - LAW vs. alqs No. of 2005 GERASIMOS DlONYSATOS, Defendant ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ra>3301@ AND @,33019(d) OF THE DIVORCE CODE I. 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, @ 4904 relating to unsworn falsification to authorities. Date:~ - 2 - ~OD5 Gerasimos ionysatos, Defendant (') c ~~.., <--' "'" ~ c:> " -I I W Q. -.... :"C"""\; f11.F': "'In",; :CjQ C)t~ :.:.:::1:,>, . -~ ') ~.ro S~ '~,~~ :::'::t --0:> :..:: <.J'\ <.F< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA THEODORA TSAROUHIS, Plaintiff CIVIL ACTION . LAW vs. NJ.> ASof 2005 GERASIMOS DIONYSA TOS, Defendant ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECmm To the Prothonotary: Transmit the record, together with the following infonnation, to lhe court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under@3301<<::>oftheDivorceCode. 2. Complaint was served on Defendant by personal service on May 22, 2005 by Konstantinos Zisimopoulos and Accepted by defendant on May 22, 2005. 3. Affidavit of Consent required by @3301<<::> of the Divorce Code was executed by Plaintiff on September 13,2005 and by Defendant on September 2, 2005. 4. No related claims are pending. 5. Plaintiff's Waiver of Notice WlIS filed with the prothonotary: sinulfaDeously henw.ith. Defendant's Waiver of Notice was filed with the prothonotary : sinultaorously her"'fith. ~ Donis Hirakis Za Attomey for Plaintiff P.O. Box 399 Mifflin, PA 17058 (717)436-5868 Atty ID # 65682 (') ~. ~~ --c.t:: -rrH-;'- ~' ~ ~ cg :-< I ....! 72 {p ~;~ :2, '2. .~. CP. s:- ....! ~ ~~ -'(}"f'0 :1JC( 0.0 ;2.~1 -::1= ~;~~ ';~ ~ .:f. . Of. , , , , + , + + + , + , , + , + , + + + + + , , + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +;+;;f.;f. + + ++ + + , + , <f.<f. iI:;f. iI:;f. :f.:f.iI::f.:f.<f.:f. ;f.:f.:+. + ;f.+ +;f.:+.;f.:+.+++. + + + + + + + + ,++ + IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ThpnrlnT~ T~~Tnl1h;Q No. 2195 of 2005 VERSUS Gerasimos Dionvsatos DECREE IN DIVORCE AND NOW, ()L1 \.7 Zo~-, IT IS ORDERED AND DECREED THAT Theodora Tsarouhis . PLAINTIFF. AND Gerasimos Dionysatos , 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; ATT + + + +Of. Of.:f.+ + + ++:f.+ ++++:+:++:+:++:+: + + + + + + ++ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + J, + + + + + + + + + + + + + + + + + + . . + + . + + . . + + + . + . . + . . + + .+ + , LI!r t!- ~ 7U, Jfr ~ ~4.(,p - F9 S'?" [i, cr y/' f/,a/