HomeMy WebLinkAbout05-5963
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
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Plaintiff .
: No)l<l- oS-59 &<3 CivilTerm
v.
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HA VE 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 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OF ANNULMENT IS
GRANTED, YOU !VIA Y 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
2 Liberty A venue
Carlisle:P A 17013
(717) 249-3166
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Plaintiff
IN THE COURT OF COMMON PLEAS
clJMBERALND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
DIVORCE
Defendant
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NOTICE OF AVAILABILITY OF COUNSELING
No.
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302( d) of the Divorce Code, you may request that the Court require
you and your spouse to attend marriage counseling prior to a divorce being handed down by the
Court. A list of professional marriage counselors is available at the Domestic Relations Office,
13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a
convenience to you and you are not bound to choose a counselor from this list. All necessary
arrangements and the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
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Plaintiff '\
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
v.
No. OS
CIVIL TERM
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Defendant -'1j: IN DIVORCE
COMPLAINT UNDER &330](c) or Cd) OF THE DIVORCE CODE
1. Plaintiff is _Lu {' /1", k. R \ Ii -I, k M ~~ who currently resides at
]~ 1<,0: \ i' CO rJ f\ JI( , 6\ ~ revY'..cu1dO---II'\)P pCJ/
Cumberland County, Pennsylvania.
2. Defendant is Rr"r.. (\S;{\~ 0-t k.(jIN~~, who currently resides at
/0..1::; t. \f\Cl'.v\S\-Sh"r'I6IY\u!/"s1(,{,,!1) j p~ J)(i(J .
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint
4. Plaintiff and Defendant were married on JUf\t J)\ I~ 9d.
at
5. The marriage is irretrievably broken, and the parties separated on
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6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best ofhis/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
given in Paragraph 2 above.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
Date
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Plaintiff, Pro Se
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l \J R le., Q v + t (j) w:Ji::\ , verity that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 Pa. c.s. 94904.
Date:
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Plaintiff, Pro Se
Assisted by:
MIDPENN LEGAL SERVICES
PRO SE DIVORCE CLINIC
(717) 243-9400
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Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
v.
: NO. OS
CIVIL TER.l\1
Defendant : DIVORCE
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PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow,
paupens.
J-.uR \~ K. ?,).+kowsk.,', Plaintiff, to proceed in forma
I, Valerie 1. Faden, attorney for the party proceeding in forma Qill!.peris, certify that I
believe the party is tmable to pay the costs and that I am providing free legal services to the
party.
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Valerie J.
Attorney for Plaintiff
2807 Market Street
Camp Hill, PA 17011
(717) 920-9461
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IN THE COURT OF COMMON PLEAS OF CUMBERLA.,.1\TD COUNTY,
PENNSYL VANIA
Lvdi, ,~~,A/:: OWs/(,
PLAINTIFF
NO. OS, 59bJ
CICJlC/~
CIVIL ACTION. LA-<V
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DEFENDANT
IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. Checyeither (a) or (b):
/
tz(/ (a) I do not oppose the entry of a divorce decree.
o (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both).
o (i) The parties to this action have not lived separate and apart for a
period of at least two years.
o (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
~a) I do not wish to make any claims for economic relief. I understand that I may
lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim
them before a di vorce is granted.
o (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
.1 understand that in addition to checking (b) above, I must also file all of my economic
claims with the Prothonotary in writing and serve them on the other party. If I fail to do so
,
before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree
may be entered without further delay.
I
I verify that the statements made in this counter-affidavit are true and correct. I
I
understand that false statements herein are made subject to the penalties of l8 Pa. C.S. 94904
relating to unsworn falsification to authorities.
DATE:
DEFENDANT
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE
DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC
RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNsn v A,"\!IA
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No. * CIVIL TERM
v.
Si'al'\ L ~v-t kctJik,'
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, DEFENDANT, accepted service ofa true and correct copy of the
Complaint in Divorce under section 3301 (cl of the Divorce Code on the date written below.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904,
relating to unsworn falsification to authorities.
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Date
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, Defendant
Plaintiff () )/
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IN THE COURT OF COMMON PLEAS OF
CCMBERLAND COUNTY PENNSYLVANIA
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No..@:J'. CIVIL TER\1
v.
:g {'leLf",. S' Rut-k:()Wlk\'
Defendant
IN DrvORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter affidavit within twenty days after this affidavit has been served on you or the
statements will be admitted,
PLAINTIFF'S AFFIDAVIT UNDER
S3301 (d) OF THE DIVORCE CODE
1. The parties to this action separated on ,.)"Q .(\. 6 d-
to live separate and apart for a period of two years,
and continued
2. The marriage is irretrievably broken.
3, I understand that I may lose rights concerning alimony, division of marital property,
lawyer's fees, or expenses if I do not claim them before a Divorce is granted.
1, L" "\('\ k, R j J, kuJ;;~erify that the statements made in this Affidavit are
true and correct to the best of my knowledge, information, and belief. I understand that
false statements made herein are subject to the penalties for unsworn falsification to
authorities as provided in 18 P.S. Section 4904.
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'Plaintiff, Pro Se
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PLAINTIFF,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYL VANIA
LURELl K. RUTKOWSKI,
NO: 05-5963
VS.
CIVIL ACTION - LAW
BRIAN S. RUTKOWSKI,
DEFENDANT
IN DIVORCE
AFFIDA VIT OF SERVICE
I, Brian S. Rutkowski, Defendant in the above-captioned matter accept and acknowledge
service of the Notice of Intention to Request Entry of Section 3301(d) Divorce Decree and
Counter-affidavit Under Section 3301(d) ofthe Divorce Code and that this Affidavit may be
used for filing with the Court of Common Pleas of Cumberland County, Pennsylvania, verifying
that service was made on the date below.
I, Brian S. Rutkowski, verify that the statements made in this Affidavit of Service are true
and correct. I understand that false statements herein are made subject to the penalties 18
Pa.C.S. Ii 4904, relating to unsworn falsification to authorities.
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BRIAN S. RUTKOWSKI
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PLAINTIFF,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
LURELI K. RUTKOWSKI,
NO: 05-5963
VS.
CIVIL ACTION - LAW
BRIAN S. RUTKOWSKI,
DEFENDANT
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY
OF SECTION 3301(d) DIVORCE DECREE
TO: BRIAN S. RUTKOWSKI, Defendant
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the Plaintiff's 3301 (d) affidavit. Therefore, the Plaintiff can request the
Court to enter a final decree in divorce 20 days after the date you receive this Notice.
Tfyou do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-aftidavit by within 20 days after the date you receive this
Notice, the court can enter a final decree in divorce. A counter-affidavit which you may file with
the prothonotary of the court is attached to this notice.
Unless you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief. The filing of the form counter-affidavit alone does not protect
your economic claims,
YOU SHOULD TAKE TIllS 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 BEWW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
32 South Bedford Street
Carlisle, PAl 70 13
(717) 249-3166
1-800-990-9108
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LURELI K. RUTKOWSKI,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
PLAINTIFF,
No. 05-5963
vs.
CIVIL ACTION - LAW
BRIAN S. RUTKOWSKI,
DEFENDANT
IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
I. Check either (a) or (b):
Q (a) I do not oppose the entry of a divorce decree.
Q (b) I oppose the entry ofa divorce decree because (Check (i), (ii) or both):
Q (i) The parties to this action have not lived separate and apart for a
period of at least two years.
Q (ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
Q (a) I do not wish to make any claims for economic relief. 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.
Q (b) I wish to claim economic relief which may include alimony, division of property,
lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also tile all of my economic
claims with the Prothonotary in writing and serve them on the other party. If! fail to do so
before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree
may be entered without further delay.
I verify that the statements made in this counter-affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 1i4904
relating to unsworn falsification to authorities.
DATE:
DEFENDANT
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE
AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU
SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
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LURELI K. RUTKOWSKI,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYL VANIA
PLAINTIFF,
NO. 05-5963
vs.
BRIAN S. RUTKOWSKI,
DEFENDANT
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
1. Grounds for divorce: the marriage is irretrievably broken and the parties have
lived separate and apart since January 2002.
2. Date and manner of service of Complaint and Affidavit: Acceptance of Service
executed by Defendant and filed on December 14, 2005.
3. Date of Service of the Notice ofIntention to Request Entry of Section 3301(d)
Divorce Decree and Counter Affidavit: Affidavit of Service executed by Defendant on February
23,2006.
4. Related claims pending: There are no claims pending.
DATE: ~/ "7; ~~t1(P
Valerie 1. Fad
I.D. # 87442
2807 Market St.
CampHilI,PA 17011
(717) 920-9460
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
Lureli.K.
RutkowRki
No.
05 5963
Civi 1
Plaintiff
VERSUS
Brian S.
Rutkowski
Defendant
DECREE IN
DIVORCE
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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?7>Ob, IT IS ORDERED AND
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AND NOW,
Lureli K. Rutkowski
DECREED THAT
, PLAINTIFF,
Brian S.
AND
RutkowRki
, DEFENDANT,
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;
There are no claims pending.
ATT
PROTHONOTARY
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