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HomeMy WebLinkAbout05-4865MELISSA K. WISNIEWSKI, Plaintiff vs. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. vs - ~/P~S Civil Term 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 County Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 MELISSA K. WISNIEWSKI, Plaintiff vs. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. OS - ~(j~/ s Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Melissa K. Wisniewski, a competent adult individual, who has resided at 352 Old Stonehouse Road, Boiling Springs, Cumberland County, Pennsylvania, since April 2005. 2. Defendant is Robert A. Wisniewski, a competent adult individual, who has resided at 4129 Penn Ave., Second Floor, Sinking Springs, Berks County, Pennsylvania, 17608 since August 2005. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 13, 2001 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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 counseling. 7. Plaintiff and Defendant have two children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 14. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint 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. ... elissa K. Wisni wski, Plaintiff Respectfully submitted, Date: ~ ~(ro (~ S e Adams, Esquire . No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~ ~ b ~- '$9, '~•. c c n t-~', ~.t- ~-~ ~~. '~~ ~-- r .-.~ w ~a cr+ -~ W Q W a -n ~~ rn r~~ _~ -~~ ~; ~~ ,{ MELISSA K. WISNIEWSKI, Plaintiff vs. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ~ ~j - ~ ~ S~ Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this September 28, 2005, I, Jane Adams, Esquire, hereby certify that on September 22, 2005, a certified true copy of the NOTICE TO DEFEND and DIVORCE COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Robert A. Wisniewski ^ Complete items 1, 2, and 3. Also complete 4129 Penn Ave, 2nd Floor item 4 'rf Restricted Delivery Is desired. ^ Print your name and address on the reverse Sinking Spring, Pa. 17608 so that we can return the card to you. DEFENDANT • Attach this card to the back of the mailplece, or on the front 'rf space permits. 1. Article Atldressed to: v ~ A 1 ~ r B. Received ~ (Printed Name) C. Dat` of Delivery D. Is delivery address different from Rem 1? ~ Yes If YES, emer delivery address below: ^ No 3. Service Type ertlfled Mail ^ Express Mail Registered ^ Return Receipt for Merchandise ^ Insured Mail Q C.O.D. 4. Restricted Delivery? (EMra Faef Yes 2. ArtICIeNUmber 703 1010 0004 7818 6992 ` (IiensM from serv/ce label) •. PS Form 3811, February 2fNW Domestk Raturn Receipt tozsas-0z-M-tsao Respectfully Submitted: J Adams, Esquire I.D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF a o n ~r c ..+ _, ~ ~ .,~c7 ~ ~ ~ ~ ~ ~ `~ ~, -~ <:? ~'~ ~i`n ~ - _ - r~ G4 c ~ < ~ MELISSA K. WISNIEWSKI, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. OS - 4865 Civil Term ROBERT A. WISNIEWSKI, ACTION IN DIVORCE Defendant CUSTODY COMPLAINT 1. Plaintiff is Melissa K. Wisniewski, who currently resides at 352 Old Stonehouse Road, Boiling Springs, Pa. 17007. 2. Defendant is Robert A. Wisniewski, who currently resides at 4129 Penn Ave., Second Floor, Sinking Springs, Pa., 19608. 3. Plaintiff is the mother of the following children and seeks custody of the following children: NAME DOB/AGE ADDRESS Robert Allen Wisniewski June 14, 2002, (3) 352 Old Stonehouse Rd. Boiling Springs, Pa. 17007 Logan Alexander Wisniewski Apri127, 2004 (1) 352 Old Stonehouse Rd. Boiling Springs, Pa. 17007 Mother and Father married on October 13, 2001. Mother currently has primary physical custody of the children. During the past three years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Melissa K. Wisniewski Barry and Sally Speck maternal grandparents 352 Old Stonehouse Rd. Boiling Springs, Pa. 17007 Apri12005 -present Melissa K. Wisniewski 4132 Penn Ave. Nov. 2004 - Apri12005 Robert A. Wisniewski Sinking Spring, Pa. 19608 Melissa K. Wisniewski S. 2nd St. Apt F Apri12004 -Nov. 2004 Robert A. Wisniewski Dillsburg, Pa. 17019 Melissa K. Wisniewski Robert A. Wisniewski 703 Old Cabin Hollow Rd. Dillsburg, Pa. 17019 Feb. 2003 -March 2004. Melissa K. Wisniewski Robert A. Wisniewski 4530 Linden Ave. F Mechanicsburg, Pa. 17055 March 2002 -Feb. 2003 The mother of the children is Melissa K. Wisniewski, and she currently resides at 352 Old Stonehouse Rd., Boiling Springs, Pa. 17007. She is married to Robert A. Wisniewski. The father the children is Robert A. Wisniewski, and he currently resides at 4129 Penn Ave., Second Floor, Sinking Springs, Pa., 19608. He is married to Melissa K. Wisniewski. 4. The relationship of plaintiff to the children is that of Mother. The persons that the Plaintiff currently resides with aze: maternal grandparents, Barry and Sally Speck. 5. The relationship of defendant to the children is that of Father. Defendant currently resides with a female companion. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information, of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or anyone who claims to have custody or visitation rights with respect to the children. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: The parties senazated in Anri12005. Since that time, mother has maintained primarv custody of the children Mother has been the primary cazetaker of the children and she feels that it is in the best interest of the children to enter a custody order which would confirm the current arrangement. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. Respectfully submitted, Date: ~ (1 l a (~ la S~ e Adams, Esquire I. . No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ~~ /y +,, M issa K. Wis iewski, Plaintiff C O t`i -,~'-- ,+ ", ~_ MELISSA K. WISNIEWSKI IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUN"FY, PENNSYLVANIA V. ROBERT A. WISNIEWSKI DIil=1'ND!1NT OS-4865 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Monday, October 31, 2005 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. ,the conciliator, al 4th Floor, Cumberland Couo Courthouse, Carlisle o^ Friday. December 02, 2005 at 9:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will he made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues t~o he heard by the court, and to aster into a temporary order. All children age five or older may also be present at the conference. Failure to appear tit the conference may provide grounds for entry of a temporary or permanent order. 'The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR T}IE LOUR"I. Ba . 1.1 _ _ _ Hubert X. Gi1r~ Esq. ~~ ___ __- Custody Conciliator 1'he Court of Common Pleas of Cumberland County is required by law to comply ~a~ith the ,Americans with Disahilites Act of 1990. For information about accessible facilities emd reasonahle accommodations available u> disabled individuals having busmcss hafore the court, please contact our office. All arrangements must be made at least 72 hours prior to auy hearinc or business before the court You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORN EY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THF. OFFICE SEI~ FORT}i BELOW TO FIND p[JT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ ~ 'l Sv. ~- it ti,~titn~ ~:s~,~ra~d ~n!n~.~ r_~ - G,u~~n~ S~ -5 fd~ Z° AO~S~QI A'~1C3~V%~I-+iJ d ~~ ~Q ~~i~ ~-~7~2~ MELISSA K. WISNIEWSKI, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. OS - 4865 Civil Term ROBERT A. WISNIEWSffi, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this November 8, 2005, I, Jane Adams, Esquire, hereby certify that on November 3, 2005, a certified true copy of the CUSTODY COMPLAINT was served, via certified mail, return receipt requested, addressed to: Robert A. Wisniewski 4129 Penn Ave, 2nd Floor Sinking Spring, Pa. 17608 DEFENDANT ^ 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 Addressetl to: Robert a Wisniewski 4129 Penn Ave - 2nd Floor Sinking Springs PA 17608 2. Article Number 7004 1350 0003 7288 4899 (Tians/er /rom service I PS Form 381 ~, February 2004 Domestic Return Receipt tozsss-oz-M-t Sao A. B. Received by (Printed Name) ~ C. Date of Delivery ~i1`, :; ,t,t.: D. Is delivery atldress different from ~aem 1? ~ Vas If YES, enter delivery address below: ^ No 3. Se ice Type f~Certified Mail ^ E><press Mail Registered ^ Retum Receipt for Merchandise ^ Insured Mail ~ C.O.D. 4. Restricted Delivery? (Exha Fee) ^ Yes ' ^ Agent Respectfully Submitted: J e Adams, Esquire I. . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF ~~ ~ u~ rJ ~ cs~ . ..--11 n S -ri n~ ~=, _ _rr,. -nr~ _. ~r >l _' cn :< ra MELISSA K. WISNIEWSKI, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. OS - 4865 Civil Term ROBERT A. WISNIEWSKI, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this November 8, 2005, I, Jane Adams, Esquire, hereby certify that on November 7, 2005, a certified true copy of the ORDER SETTING A CUSTODY HEARING was served, via certified mail, return receipt requested, addressed to: Robert A. Wisniewski 4129 Penn Ave, 2nd Floor Sinking Spring, Pa. 17608 DEFENDANT ^ 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 Atltlressed to: ROBERT A tAISNIEWSKI 4129 PENN AVE 2nd floor SINKING PRINGS PA 17608 A. B. Re'raified M' (Pdrtled Name) O Agent D. Is delivery adtlress different from item 17 ^ Yes If YES, enter delivery address below: ^ No r. 3. Se ice Type Certified Mail ^ Express Mail egistared ^ Return Receipt for Merchandise Insured Mail ^ C.O.D. 4. Restricted Delivery? (E#ra FeeJ ^ Yes 2. Article Number 7003 1010 004 7818 6923 (transfer from service label ~. PS FOrm 3811, February2004 Odates3ta Return Receipt~~. a : ~. ... ~~';,: mzaee-oz-m-tsao' Respectfully Sub (~lti.~- J e Adams, Esquire . No. 79465 64 South Pitt Street Cazlisle, Pa. 17013 (717)245-8508 ATTORNEY FOR PLAINTIFF r~ ~ ~ "' i't x"r .-~ ~ Res.% T ~}'}~ ~~ r.. j 1? ~t ~~ O ~ -a-,- ° ;C .H'.._ c K~ DEC 0 7 2005 MELISSA K. WISNIEWSKI, Plaintiff vs. ROBERT A. WISNIEWSKI, Defendant g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OS-4865 CIVIL ACTION -LAW IN CUSTODY ORDER Ct day of December, 2005, the Conciliator being advised that AND NOW, this ~~ the parties have reached an agreement, the Conciliator relinquishes jurisdicfion. Hubert X. ilroy, Esquire Custody onciliator t .', :, ~ ~ ~ . , NAROLD E. IRYVIN, 111, EEgUIRE ATTORNEY ID N0.29920 sa EOUTN PITT STREET CARLISLE PA 17013 (717)243.6090 ATTORNEY FOR DEFENDANT MELISSA K. WISNIEWSKI, Plaintiff v. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2005 - 4865 CIVIL TERM IN CUSTODY STIPULATION AND AGREEMENT ~cEk~~t.. THIS STIPULATION AND AGREEMENT entered into this _ ~~~day of tdC'.~r, 2005, by and between ROBERT A. WISNIEWSKI (hereinafter referred to as "Father") and MELISSA K. WISNIEWSKI (hereinafter referred to as "Mother"). NOW THlS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of two minor children, namely, Robert Allen Wisniewski (born June 14, 2002, age 3) and Logan Alexander Wisniewski (born April 27, 2004, age 1); and WHEREAS, the parties wish to enter into an agreement relative to the custody, partial custody and visitation of the children. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The Mother and Father shall have joint legal custody of the children. 2. The Mother shall have primary physical custody of the children. 3. The Father shall have visitation and partial custody of the children at such unscheduled times as the parties may mutually agreed and during the following scheduled times: A. Every weekend, from Friday evening through Sunday at 6:00 p.m.; B. Every other holiday of the following holidays (beginning with Thanksgiving, 2005): 1.) New Year' Day (December 30 through January 1); 2.) Easter (Good Friday through Sunday); 3.) Memorial Day Weekend; 4.) Independence Day Weekend; 5.) Labor Day Weekend; 6.) Thanksgiving (Thursday morning through Sunday at 6:00 p.m.); 7.) Christmas (Christmas Eve through December 27 at 6:00 p.m.); and 4. Father shall always have the children on Father's Day and Mother shall always have the children on Mother's Day. 5. The parties shall share transportation with the party teginning his or her custody time picking up the child. 6. Each party shall give two weeks notice to the other party of any long distance travel with the children, providing the phone number and address of the location to which they are traveling. In emergency situations when advance notice is not possible, the traveling party shall notify the other party as soon as possible after leaving with the children. 7. The parties agree that they shall have reasonable telephone contact with the children while the children are in the other's custody. 8. Both parties agree to keep each other advised immediately relative to any emergencies concerning the children and shall further take any necessary steps to insure that the health, welfare and well being of the children is protected. 9. The parties shall do nothing that may estrange the children from the other parent or hinder the natural development of the children's love or affection for the other parent. 10. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the: same formality of this agreement. 11. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 12. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, Pennsylvania, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor children and shall retain suclh jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. /. _ ~ ~ (SEAL) OBERT A. WISNIEWSKI ~~~-+?aa rl~.~I'~iC~~~1~1~-!_~ (SEAL) LISSA K. WISNIEWSKI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: 'T~c e+.u.~-- On this, the ~ day of-keer, 2005, before, the undersigned officer, appeared ROBERT A. WISNIEWSKI, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that he executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set phy hind and official seal. l/~-''" " " `l7 (SEAL) NorHH;a~str:__ Notary Public HAROLDS IRWIN ;; IVU~A'' PUBLIC ,~Nll." BDRpUGh WUNn G~ t cRLAND COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On this, the day of~,'2005, before, the undersigned officer, appeared MELISSA K. WISNIEWSKI, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument, and acknowledged that she executed this agreement for the purposes therein contained. IN WITNESS WHEREOF, I hereunto~setv~y hand an9~ffigial seal. Public COMMONWEALTH_OF PENNSYLVANIA EAL) Notarial Seal lane Adams, Notary Public Carlisle Boro, Cumberland County My Commission Expires Sept. 6, 2008 C p .~ , -O C7 ~ v - l ; .; ~D i.7 ~ "> -c-_. -~-1., ^~ ~ 'tt ~ -,:~ Y Cj N ~? rn i MELISSA K. WISNIEWSKI~ : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW NO. 2005 - 4865 CIVIL TERM ROBERT A. WISNIEWSKI, Defendant : IN CUSTODY AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about September 19, 2005. Service of the complaint was made by certified mail on September 22, 2005 (see affidavit 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 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. I verify that the statements made in this affidavit 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. .~ December 22, 2005 ~~ ~~~~ ROBERT A. WISN~EWSKI „ c r`~ ~'' -~ niP -nm ~ ~~ , ~~. ' N ; ~~~ `~ C~ O _~, MELISSA K. WISNIEWSKI, Plaintiff v. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY„PENNSYLVANIA CIVIL ACTION -LAW NO. 2005 - 4865 CIVIL TIERM :IN CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $ECTION SSO'I (C1 OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. ~~ ^] O <„ -n _ ~ n m~ n~ -^ m ;7Ci N _~1 1 q~ ~ ;~?i _ .~ i_ N Ljm ,-- • • :t % ~ °D a -< 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 off 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~,l _. December ~' , 2005 ,~~,C~ ~P< ~ OBERT A. WISNIEWSk;I • DE~~ ~ I °L00~ ~,~ ~~ ~/ HAROLD E. IRWIN, 111, EEgU1RE ATTORNEY ID NO. 29920 84 EOUTN PITT STRRET CARLIELC PA 17013 (717)249.6090 ATTORNEY FOR DEFENDANT MELISSA K. WISNIEWSKI, : IN THE COURT OF COMIMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~, :CIVIL ACTION -LAW NO. 2005 - 4865 CIVIL TERM ROBERT A. WISNIEWSKI, Defendant : IN CUSTODY ORDER OF COURT NOW, this ~~day of ~F""'"' , 200~upon presentation and consideration of the attached Stipulation and upon agreement of the parties, it is~ hereby ordered and ___._ decreed that the attached agreement is made an Order of C:ourf` /BY THE ,- ~_~ _- . __ %~~1 J. ~~~''t~r'~ J`. ;r? S I =~ a~~ Z~ ~~~! S~Q~ 1v ., ,iid ?Nl :~D !AN 0 6 LU06 MELISSA K. WISNIEWSHI, Plaintiff vs. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OS-4865 CIVIL ACTION -LAW IN CUSTODY ORDER // ~y AND NOW, this (~ day of January, 2006, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. ert X. Gilroy, Esquire Custody Conciliator ~~ _ ~; -_ ~~: ~': ~ : ;,, -;~ ~.~_. , _-_~.,, . ~. _;~ ;_: ~ _ --s r) ~= ~ ~ c-' _ MELISSA K. WISNIEWSKI~ : IN THE COURT OF COMMON PLEAS Plainti :CUMBERLAND COUNTY, PENNSYLVANIA vs. I No. OS - 4865 Civil Term ROBERT A. WISNIEWSKI, ~ ACTION IN DIVORCE AFFIDAVIT OF CONSENT l . A complaint in divorce hmder section 3301(c) of the Divorce Code was filed on September 19, 2005. 2. The manage of Plainti f and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the omplaint. the decree. I consent to the entry ot[ a final decree of divorce after service of notice of intention to request entry of I verify that the statements ade in this affidavit are true and corcect. I also understand that false statements herein aze made subject the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. Date: ~1 y/~~ 1. [consent to entry of a 2. i understand that i may if 1 do not claim them before a divo 3. 1 understand that I will the decree will be sent to me imme r ~f d .f ~ ~/~~k`if.Gi~GL~~/~~,. MehssaK. W~sn v4sld Plaintiff decree of divorce without notice. s rights concerning alimony, division oY property, lawyer's fees or expenses is granted. be divorced until a divorce decree is entered by the Court and that a copy of ly after it is Fled with the Prothonotary. 1 verify that the statements ade in this affidavit are true and corcect. I understand that false statements herein are made subject to the penalt es of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ~/~ 1~ v. Melissa K. Wisniewslci, Plaintiff i'7 "'7 f ~ 7,-. (.t _~;. :... J ~ . 11 CT: :..+r., MELISSA K. WISNIEWSKI, Plaintiff vs. ROBERT A. WISNIEWSKI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. OS - 4865 Civil Term ACTION IN DNORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please 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 the service of the Complaint: Via certified mail, restricted- delivery, delivered on: September 22, 2005. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: February 9, 2006. By Defendant: December 22, 2005. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 22, 2005. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: February 14, 2006. Respectfully Submitte Date: '~ . a 1 , ~ r(~ J Adams, Esquire " \ I . No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717)245-8508 Attorney for Plaintiff ~( _~_ ~? ~^ ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT`' STATE OF ~ PENNA. p ~. ,. ~" ° -_ Melissa K. Wisniewski, Plaintiff VERSUS Robert A. Wisniewski, Defendant N O No. OS - 4865 Civil Term DECREE 1N DIVORCE ~ cf.'o3P.N- AND NOW, ~~~~ ~~ , ~~, IT IS ORDERED AND V pECREED THAT Mel1SSa K_W1SmeWSki ~ PLAINTIFF, AND RObert A. W1SllICWSk1 ~ 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. THONOTARY I %y/(yy/ v~/ Y~ ~ j ~r~v73z?/ - ~' ~J ; y" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA (Y~ I~~_~5a ~• (,v1~nr~ew5ki Plaintiff Vs File No. U 5 ° y $(.o_~ IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /defendant in the above matter, [select one by marking "x"J prior to the entry of a Final Decree in Divorce, or X after the entry of aFinai Decree in Divorce dated b~ -~$-~~ hereby elects to resume the prior surname of ~ p 2 e ,and gives this written notice avowing his /her intention pursuant to the p visions of ~4 P.S. 704. Date: pS -a`J- d ~ . c Si a e Si afore of n e eing re umed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF C'uwtber Jx,,,,,1) On the ZS'~ day of rn ~.,~,, , 200 7 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged. that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ~~~ ~ PUDLIQ t-.~.~,ycc.- C~ ~•e.P,~.~ ~CO~I~SSION E%PIRE8~ANINRY4a2010~ Pro onotary or Notary Public ~ _r,, , _ - ~~ :~ --a ~ .. -~: nz s,,a : , ~- CJ! } _- . ~~ l .~ i. .._..E r.i ~ ~V ''~^ .Feiss .}F4'`:-'r,' ~4~ e,.,.. ,....~~...~..,..~ ..e.,s .