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HomeMy WebLinkAbout05-3941EMERIC KOCSIS, JR., Plaintiff V. ANDREA M. KOCSIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,, PENNSYLVANIA NO. DS- 34W L:w'. L 74i l 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. 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. 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 EMERIC KOCSIS, JR., Plaintiff V. ANDREA M. KOCSIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05' ?Iq 41 Cc,eJ'r-4 je k,"\ CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is EMERIC KOCSIS, JR., currently residing at 126 East Green Street, Shiremanstown, Cumberland County, Pennsylvania 17011. 2. Defendant is ANDREA M. KOCSIS, currently residing at 126 East Green Street, Cumberland County, Pennsylvania 17011. 3. 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 May 24, 1973 in Romania. 5. Plaintiff avers that there is one child of the parties under the age of 18, namely HENRIETTA EMMA KOCSIS, born October 15, 2001. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff is a citizen of the United States. The Defendant is not a citizen of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. COUNT I - DIVORCE 10. Paragraphs 1 - 9 are herein incorporated by reference. 11. The Plaintiff avers that the grounds on which the action is based are as follows: (a) That the marriage is irretrievably broken; and (b) That Defendant has offered such indignities to the Plaintiff, the injured and innocent spouse, as to make Plaintiff's condition burdensome and life intolerable. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Y-Aenn o spa? ?(m rz J fer L. Lehman, Esquire 27 South Arlene Street P.O. Box 6130 Harrisburg, PA 17112 (717) 671-1200 Date: 7-d q-05 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce/Custody 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. EMERIC KOCSIS, JR. Date: 7-.2(y-05- S Lk EMERIC KOCSIS, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-3941 CIVIL TERM ANDREA M. KOCSIS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 2, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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: --rte EMERIC KOCSIS, JR. PLAINTIFF C -0 CL ri-Itf; C::) M73 -oFq .K C: ? ? - C EMERIC KOCSIS, JR., Plaintiff V. ANDREA M. KOCSIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3941 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) 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. §4904 relating to unsworn falsification to authorities. Date: EMERIC KOCSIS, JR. PLAINTIFF rv G?? fV fV tG3 -?C EMERIC KOCSIS, JR., : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05-3941 CIVIL TERM ANDREA M. KOCSIS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 2, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) 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: 11S li?? tdza-a ANDREA M. OCSIS DEFENDANT j3: cf- EMERIC KOCSIS, JR., Plaintiff V. ANDREA M. KOCSIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3941 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(!* 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. §4904 relating to unsworn falsification to authorities. Date: ANDREA M. KOCSIS DEFENDANT rr-.s #'i'? r r`< rrJ EMERIC KOCSIS, JR., Plaintiff V. ANDREA M. KOCSIS, Defendant AN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYLVANIA :NO. 05-3941 :CIVIL ACTION - LAW AN DIVORCE 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery pursuant to an Affidavit of Service signed by the Defendant dated August 4, 2005, and filed with the Court August 29, 2005. 3. (a) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: by the Plaintiff on November 5, 2007; by the Defendant on November 5, 2007. 4. Related claims pending: None. 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: DATE: 1 1 I t 4 1 0 7, J fer L. Lehman, Esquire I.D. No. 52784 27 S. Arlene Street P.O. Box 6130 Harrisburg, PA 17112-0130 (717) 671-1200 ` Fry j ftE CJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF f PENNA. EMERIC KOCSIS, JR. VERSUS ANDREA M. KOCSIS No. 05-3941 DECREE IN DIVORCE AND NOW, N ovtmm t.d" 1.7 , 2007 , IT IS ORDERED AND DECREED THAT EMERIC KOCSIS JR, PLAINTIFF, AND ANDREA M. KOCSIS 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; BY THE COURT: PROTHONOTARY x /?v ?,p 'emu, , o.o?,i/ 00 -!y 17~ 4p C 62 - q- . //