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HomeMy WebLinkAbout06-0339CHERIE LYNN KUTA, AN THE COURT OF COMMON PLEAS OF PLAINTIFF, :CUMBERLAND COUNTY,PENNSYLVANIA :CIVIL ACTION - 3 j ,, , V. PETER JOSEPH KUTA, : CIVIL TERM DEFENDANT. : DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If yu 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 in 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 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 at Cumberland County, 1 Courthouse Square, 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 TO FIND OUTWHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166) CHERIE LYNN KUTA, :IN THE COURT OF COMMON PLEAS OF PLAINTIFF, :CUMBERLAND COUNTY,PENNSYLVANIA :CIVIL ACTION - ?, - 3-31? V. PETER JOSEPH KUTA, : CIVIL TERM DEFENDANT. : DIVORCE COMPLAINT IN DIVORCE Plaintiff is CHERIE LYNN KUTA who currently resides at 1528 Inverness Drive, Mechanicsburg, PA 17050 Defendant is PETER JOSEPH KUTA who currently resides at 1528 Inverness Drive, Mechanicsburg, PA 17050 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on September 8, 1990, in Graceton, Indiana County, Pennsylvania. 5 No children were born of this marriage. 6. Neither Plaintiff nor Defendant are in the military or naval service of United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between parties. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce Divorcing Plaintiff and Defendant and such other Orders as are just and appropriate. COUNT II EQUITABLE DISTRIBUTION 11. The averments of paragraphs 1-10 are incorporated herein by reference. 12. During the marriage the parties acquired marital property, assets and debts which Plaintiff requests the Court equitably distribute and assign. WHEREFORE, Plaintiff requests that this Court order equitable distribution of the marital property and assign debt. COUNT III ALIMONY 13. The averments of paragraphs 1-12 are incorporated herein by reference. 14. Plaintiff is entitled to alimony due to the length of the marriage and disparate earning capacities. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant, enter an Order equitably distributing marital property and awarding alimony and such other orders as may be just and appropriate. Respectfully submitted, . c r=te 2 Susan K. Pick d, Esquiye' Attorney ID No. 4309311 3344 Trindle Road Camp Hill, PA 17011 i (717) 612-1660 Date: Attorney for Plaintiff VERIFICATION I, CHERIE LYNN KUTA, verify that the statements made in the foregoing COMPLAINT in DIVORCE are true and correct to the best of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unworn falsification toauthorities. Date: /- g - Z i? LYE., Cherie Lynh Kota 16 i W r f 1 h i Curtis R. Long Prothonotary office of the Vrotbonotarp Cutnbertanb Cuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor - 33q CVIL TERM -OL ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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