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Home My WebLink About05-5846MICHAEL A. WICHROWSKI, Plaintiff V. KATHRYN M. WICHROWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-SPJ4L CIVIL TERM 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, 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, 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. 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 Street Carlisle, Pennsylvania 17013 (717) 249-3166 MICHAEL A. WICHROWSKI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005-.SPYL CIVIL TERM KATHRYN M. WICHROWSKI, CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Michael A. Wichrowski, an adult individual who currently resides at 4 North Pin Oak Drive, Boiling Springs, Cumberland County, Pennsylvania 17007-9405. 2. Defendant is Kathryn M. Wichrowski, an adult individual who currently resides at 3520 March Drive, Cumberland County, Camp Hill, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 26, 2005, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER mas\Domestic\W i ch rowski\d ivorce.com p Michael A. Scherer 1. D. # 61974 nn AAI- 4 C..h4. C+rec+ MICHAEL A. WICHROWSKI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005- CIVIL TERM KATHRYN M. WICHROWSKI, CIVIL ACTION-LAW Defendant IN DIVORCE VERIFICATION I verify that the statements made in this Divorce 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. Date: November. U9 , 2005 -1../^ MICHAEL A. WICHROWSKI c C V 5 D t- C? G } 4-? h? c? -n 1 i f 1'° r L MICHAEL A. WICHROWSKI, Plaintiff V. KATHRYN M. WICHROWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-5846 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT. ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce, Code was filed on November 10, 2006. 2. Service of the Divorce Complaint was made upon the Defendant by certified mail on November 17, 2005. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 1 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. 6. 1 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, 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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.A. §4904 relating to unswom falsification to authorities. Date: P6*c abV idno9k Ka ryn M. Wichrowski r-? P' o Z a Zan; a C !_r U Tl t1> O O .,C MICHAEL A. WICHROWSKI, Plaintiff V. KATHRYN M. WICHROWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-5846 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 10, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 5. 1 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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.A. §4904 relating to unsworn falsification to authorities. Date: May p?j , 2006 Wr w Michael A. Wichrowski a ? nc try ?c 7?`'Z/'?? r... t ?" S J ? ???> 3 ?? O ? MICHAEL A. WICHROWSKI, Plaintiff V. KATHRYN M. WICHROWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-5846 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail return receipt card. O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire DATE: May 2006 • CwO is Hems 1, 2,. and 3. Also complete Item 4 M Rsshk,Ked Delivery is decked. ¦ Rim your name and address on the reverse so that we can rW= the card to you. • A to the beck of the mailpiece, or on the front 0 space permits. 1. ArtkM AAdrsisedte: KATHERINE WICHROWSKI 3520 MARCH DR CAMP HILL PA 17011-5010 2. Mole Number -marewier nom awwicepaw PS Form 3 A. 1 a Awes C. Dabs of I I' 1 D. b address d•esa from ken 1? Yea If YES, enter delivery afters bebw: No *uVaRCG COM)L } 3. Service lyps :M Csalbd Mad 0 Epreea MW O Registered O Retwn Receipt forMerdmwrae O hwxW Mee ? C.O.D. 4. Restricted D;7e My" PboFeat m Yee 7004 2510 0003 1247 9908 cwq Domestic Re[" Reoeipt 1024.1640 3 ? rN ,n. S? Rp W rn MICHAEL A. WICHROWSKI, Plaintiff V. KATHRYN M. WICHROWSKI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005-5846 CIVIL TERM CIVIL ACTION-LAW IN 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 Section 3301(c)of the Divorce Code. 2. Date and manner of service of the Complaint: Service was made via U.S.P.S. Certified Mail on November 17, 2005. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on May 5, 2006; and Defendant on May 2, 2006. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: None. Respectfully submitted, O'BRIEN, BARIC & SCHERER 04&, Michael A. Scherer, Esquire ? o 0 'C7 Lr' ? ny? r ctt ;_TQ m x^ c? -: ? S m IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. t MICHAEL A. WICHROWSKI, Plaintiff No. 2005 - 5846 CIVIL VERSUS KATHRYN M. WICHROWSKI Defendant DECREE IN DIVORCE AND NOW, • /t (Fir V)PA IT IS ORDERED AND DECREED THAT MICHAEL A. WICHROWSKI PLAINTIFF, AND KATHRYN M. WICHROWSKI 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 ATTEST: J. I PROTHONOTARY 2 °/O. 0j S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT', PENNSYLVANIA Plaintiff Vs File No. ap tq5- 5 g q to ? at r (?(? ((,? ? ?,v 5 jL l INDIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, a p D or after the entry of a Final Decree in Divorce dated 160hereby elects to resume the prior surname of and gives this written notice avowing his / her intention pur t to the provisions of 54 P.S. 704. Date: ? -12.- D -7 V ll ?n 6h,_ Signature Signatmi of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 0 ,,.. J,. a,,g ) 6 N06?E On the fez day of 1200_9, 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. Prothonotaryy or Notary Public NOTARK SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 C`> } co ? x r• >