HomeMy WebLinkAbout05-5979
LISA B. SLOBODIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. (:) t;' - !:97?
CIVIL ACTION - LAW
C;u; L '--r 02-,
MARKIAN R. SLOBODIAN,
Defendant
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 of 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, One Courthouse Square, Carlisle,
Pennsylvania 17013-3387.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
LISA B. SLOBODIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 0[; - S9^1~
CIVIL ACTION - LAW
c; L> ~ L'--T~fl_lr11
MARKIAN R. SLOBODIAN,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes the Lisa B. Slobodian, pro se, and files the within
Complaint against the Defendant, averring as follows:
Divorce Under & 3301 Ie) and & 33011d) of the Divorce Code
1. Plaintiff is Lisa B. Slobodian, an adult individual who currently resides
at and has a mailing address of RR4, Box 4634, Duncannon, Perry County,
Pennsylvania 17020. Plaintiff has lived at said address since June 1, 2005.
2. Defendant is Markian R. Slobodian, an adult individual who currently
resides at 1704 Lincoln Drive, Camp Hill, Cumberland County, Pennsylvania 17055.
Defendant has lived at such address since 1987.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on May 26, 1979, in Paoli,
Pennsylvania and separated in August, 2001, and have lived separate and apart since
that time.
5. The Plaintiff and Defendant are both citizens of the United States of
America and are not members of the Armed Forces.
6. There have been no prior actions of divorce or for annulment between
the parties in this or any other jurisdiction.
7. The marriage is irretrievably broken.
8. Plaintiff understands that counseling is available and that Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree
of Divorce pursuant to Section 3301 (c) or Section 3301 (d) of the Pennsylvania Divorce
Code of 1980, as amended.
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.
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Lisa B. Slobodian
Dated: J/~~6'
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LISA B. SLOBODIAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5979 Civil Term
MARKIAN R. SLOBODIAN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Markian R. Slobodian, the Defendant in the above-captioned matter, do hereby
accept service of the Complaint In Divorce.
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Markian R. Slobodian
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LISA B. SLOBODIAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5979 Civil Term
MARKIAN R. SLOBODIAN,
Defendant
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.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
94904 relating to unsworn falsifications to authorities.
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Markian R. Slobodian, Defendant
Dated: 3ll. J. /0(,
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LISA B. SLOBODIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5979 Civil Term
MARKIAN R. SLOBODIAN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER ~ 33011C)
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.
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
94904 relating to unsworn falsifications to authorities.
~.: 4. SMuL
Lisa B. Slobodian, Plaintiff
Dated: .#'tUtd. -7.2, ~
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LISA B. SLOBODIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5979 Civil Term
MARKIAN R. SLOBODIAN,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on
November 17, 2005 and served on the Defendant on November 21, 2005. An
acceptance of service form was filed on November 28, 2005.
2. The marriage of 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.
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. 94904
relating to unsworn falsification to authorities.
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Lisa B. Slobodian, Plaintiff
DATE: /fpAd .2-7. ;zL04
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LISA B. SLOBODIAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5979 Civil Term
MARKIAN R. SLOBODIAN,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed on
November 17, 2005 and served on the Defendant on November 21, 2005. An
acceptance of service form was filed on November 28, 2005.
2. The marriage of 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.
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. 94904
relating to unsworn falsification to authorities.
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Markian R. Slobodian, Defendant
DATE: j / vi Db
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LISA B. SLOBODIAN,
Plaintiff
SS# 167-52-4445
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-5979 Civil Term
MARKIAN R. SLOBODIAN,
Defendant
SS# 144-56-5724
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)
3301(0)] of the Divorce Code. (Strike out inapplicable section).
2. Date of filing and manner of service of complaint: filed November 17,
2005, served by hand delivery upon Defendant on November 21, 2005. Acceptance of
Service was filed on November 28, 2005.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by
93301 (c) of the Divorce Code: by Plaintiff March 22, 2006; by
Defendant March 22, 2006.
(b)(1) Date of execution of the affidavit required by ~3301 (d) if the Divorce
Code: N/A; (2) Date of filing and service of the Plaintiff's affidavit upon the
respondent: N/A
4. Related claims pending. None.
5. (Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention to file Praecipe to
Transmit Record, a copy of which is attached: N/A.
(b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary:
March 27 , 2006.
Date Defendant's Waiver of Notice Divorce was filed with the Prothonotary:
March..21. ,2006.
Respectfully submitted,
Date:
4/6/06
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Lisa B. Slobodian, Plaintiff
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IN THE COURT OF COMMON PLEAS
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'f. ~ 'f ~ ~ ~ 'f OfOf'
OF CUMBERLAND COUNTY
STATE OF
PENNA,
LISA B.
SLOBODIAN,
Plaintiff
No.
05-5979 Civil Term
VERSUS
MARKIAN R.
SLOBODIAN,
Defendant
DECREE IN
DIVORCE
AND NOW,
,Ar-uL2-
, 2DD(;" ]T ]S ORDERED AND
DECREED THAT
LISA B.
, PLA]NT]FF,
SLOBODIAN
AND
MARKIAN R.
, DEFENDANT,
SLOBODIAN
ARE D]VORCED FROM THE BONDS OF MATR]MONY.
THE COURT RETA]NS JUR]SD]CT]ON OF THE FOLLOW]NG CLA]MS WHICH HAVE
BEEN RA]SED OF RECORD ]N TH]S ACT]ON FOR WHICH A F]NAL ORDER HAS NOT
YET BEEN ENTERED;
J.
T:a
,~;~
PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
i.'sa. e, SlDhool.c'av1
Plaintiff
File No. () [;' - ::'171 6i1,{ JiJ>'Y1
IN DIVORCE
Vs
)l/arkiaYl. R,5/obodt'a.V1
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,
or L after the entry of a Final Decree in Divorce dated~I'J fJ) 100fu ,
hereby elects to resume the prior surname of ---.Beck te.l , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P ,S. 704,
Date: 5/zJ"JooG rk';' ..4uL./,ftltJl'Hl/'.lu41
I I Signature
~d ~n";.M ifnt'741
Sign~e of name being resumed
,
COMMONWEA>LTH OF PI\NNSYL VANIA)
COUNTY oFCumbe.rlancl)
On the ~ day of 200.k, before me, the Prothonotary or the
notary public, personally appe the above affiant lmown to me to be the person whose
name is subscribed to the within doc=ent and aclmowledged that he / she executed the
foregoing for the purpose therein contained,
In Witness Whereof, I have hereunto set my hand hereunto se my h
seal.
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