HomeMy WebLinkAbout05-5664CHAD J. PETROVICH, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
KIMBERLY A. PETROVICH, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
NOTICE TO DEFEND
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 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 at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990-9108
26 W. Tgh Street
Carl le, PA
CHAD J. PETROVICH,
Plaintiff
KIMBERLY A. PETROVICH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,, PENNSYLVANIA
No. OS- S'LLq e(U C Vl
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. The Plaintiff is Chad J. Petrovich, and adult individual residing at 109
North Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania.
2. The Defendant is Kimberly A. Petrovich, an adult individual residing at,
109 North Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing
of this Complaint.
4. The Plaintiff and Defendant were married on February 19, 2000 in
Cumberland County, Pennsylvania.
5. There are two minor children born of this marriage namely Autumn
Marie Petrovich, born March 29, 2001 and Christian Jaymz Petrovich, born June 29,
2004.
6. The parties separated on October 6, 2005.
26 W. Nigh Street
Carl le, PA
7. There have been no prior actions of divorce or for annulment between
the parties in this or in any other jurisdiction.
8. Neither Plaintiff nor Defendant is in the military or naval service of the
United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief
Act of the Congress of 1940 and its amendments.
9. The Plaintiff has been advised that counseling is available and that
he/she has the right to request that the court require the parties to participate in
counseling.
10. The marriage is irretrievably broken and no possibility of reconciliation
exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in
accordance with §3301 of the Pennsylvania Divorce Code.
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
0
Ma Matas, quire
Attorn Id. 84919
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Dated: 05 Counsel for Plaintiff
HU FLOWER
& L DS AY
AM YS•AT•LAW
26 W. igh Street
Ca isle, PA
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
1
Dates Chad J. Petrovich
FLOWER
26 W. `igh Street
Car sle, PA
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CHAD J. PETROVICH,
Plaintiff
KIMBERLY A. PETROVICH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. DS - Slero? ?tv1 ,??JLyr1
CIVIL ACTION - LAW
IN DIVORCE
COUNSELING AFFIDAVIT
1. I have been advised of the availability of marriage counseling and
understand that I may request that the Court require that my spouse and I participate in
counseling.
2. 1 understand that the Court maintains a list of marriage counselors in the
Domestic Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse
and I participate in counseling prior to a divorce decree being handed down by the
Court.
I understand that false statements herein are made subject to the penalties of 18
Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.
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Dated:
Chad J. Pdtrovich
IU FLOWER
& L DSAY
ATTO YS-AT-LAW
26 W. igh Street
Ca isle, PA
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3C W
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Curtis R. Long
Prothonotary
office of the i9rotbonotarp
?umberrat?b ?Courttp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
L95' - CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573