HomeMy WebLinkAbout06-0870
VIKTOR SHLUHARCHUK,
PLAINTIFF
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V.
;NO. O~ - f7b
C,utL1EfU:r\
OLENASHLUHARCHU~
DEFENDANT
: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 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 grounds 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 Dauphin County Courthouse, Front and Market Streets,
Harrisburg, Pennsylvania 17101. You are advised that this list is kept as a convenience to you
and you are not bound to choose a counselor from the list. All necessary arrangements and the
cost of counseling sessions are to be borne by the parties.
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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
8 Irvine Row
Carlisle, P A 17013
Phone (717) 243-9400
Toll-Free (800) 822-5288
v,
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYL VANIA
;NO. 0(" - f70 CWJ .--c--.
VIKTOR SHLUHARCHUK,
PLAINTIFF
OLENA SHLUHARCHUK,
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
NOTICE OF A V AILABIUTY OF COUNSELING
TO THE WITHIN NAMED DEFENDANT:
You have been named as the Defendant in a divorce proceeding filed in the Court
of Common Pleas of Cumberland County, Pennsylvania. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, as amended, you may request that the
Court require you and your spouse to attend marriage counseling prior to a Divorce Decree being
handed down by the Court. A list of professional marriage counselors is available at the Office
of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are
not bound to choose a counselor from the list All necessary arrangements and the cost of
counseling services 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.
V.
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO. {)/, - J?o
VIKTOR SHLUHARCHUK,
PLAINTIFF
OLENASHLUHARCHUK,
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
COMPLAINT
COUNT I - Divorce 3301(c) or 3301(d)
I. PlaintiffViktor Shluharchuk, is an adult individual residing at 1488 Timber Brook
Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. Defendant Olena Shluharchuk, is an adult individual residing at 55 Village Court,
Mechanicsburg, Cumberland County, Pennsylvania, 17050.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania and have resided therein for a period in excess of six (6) months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 21,1997, in Korosten, Ukraine.
5. Plaintiff avers that the ground upon which this action is based is that the marriage is
irretrievably broken.
6. There has been no prior action of divorce between the parties in this or any other
jurisdiction.
7. The Defendant is not a member of the Armed Services of the United States of
America.
8. Plaintiffhas 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.
9. Plaintiff and Defendant have lived separate and apart for a period in excess of four
months.
10. There are two children of this marriage, namely; a son, Vladimir Shluharchuk born
May 13, 1999, and a son, Alexander born June 14,2005.
WHEREFORE, the Plaintiffrequests this Honorable Court to enter a Decree of Divorce.
Respectfully submitted,
HEINHAUR&_~''i/
(./<~/ /' /
-By: /-::>." /< - /
/:Jbsepl(.A( Curcillo, III
~// Su$tf~eJ~'6ui1.LD. #44060
V 3964 L>exington Street
/
Harylsburg, PA 17109
(7~7) 651-9J00
Attotneyfor Plaintiff
DATED: 1/;jlt:
VERIFICATION
I, Viktor Shluharchuk, have read the foregoing Document and hereby affirm and
verify that it is true and correct to the best of my personal knowledge, information and belief I
verify that all of the statements made in the foregoing are true and correct and that false statements
made therein may subject me to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn
falsification to authorities.
/~
Viktor Shluharchuk
DATE:
p/f9'/o6
VIKTOR SHLUHARCHUK,
PLAINTIFF
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V.
:NO.
OLENASHLUHARCHU~
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this -fl day of h (;; ,2006, I, Joseph A. Curcillo, III, hereby
certify that I have served the foregoing Complaint in Divorce by mailing a true and correct copy by
United States first class mail, certified mail return receipt requested, postage prepaid, addressed as
follows:
Ms. Olena Shluharchuk
55 Village Court
Mechanicsburg, P A 17050
Respectfully submitted,
BEIN~~UR
../" //
// // ,.... ~-
'By:" ..- -/</// //
/ /JpiepI;.A:C;.uicillo, III
j/' SUPj:tm9,Court LD. #44060
39%4J;oexmgton Street
Hilrrisburg, P A 17109
(717) 651-9100
Attorney for Plaintiff
DATED: 9 kb ()~
..l.Q.
1: ~ ~
_ -1:. Vi
~ € CY
~ ~ ;:J
+- \
.~C:). t
C) --t-
~
t-
oB
-On
-n :--;t
r"-~ ;n
c;:; -n
-
0) "
~,~.,,\
";"\
" ~'"rl
(,:! ~-\
, :.:9
.;; .0:::,.
MATRIMONIAL SEITLEMENT AGREEMENT
,
THIS AGREEMENT, made this 2 day of
;()i; vPltrk'?_
, 2005, by
and between Viktor Shluharchuk, of 1488 Timber Brook Drive, Mechanicsburg, Cumberland
County, Pennsylvania 17050 ("Husband") and Olena Shluharchuk, of 1488 Timber Brook Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17050 ("Wife").
RECITALS
A. The parties hereto, being Husband and Wife, were lawfully married on June 21,
1997 in Korosten, Ukraine.
B. Differences have arisen between Husband and Wife in consequence of which they
have begun to live separate and apart from each other.
C. Husband and Wife acknowledge that they both have consulted their attorneys and
have been advised by their attorneys of all of their rights and duties or have had the opportunity to
consult independent legal counsel and have wilfully, knowingly and voluntarily waived the right to
consult an attorney.
WITNESSETH
NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings
herein contained, the parties, each INTENDING TO BE LEGALLY BOUND, agree as follows:
1. Recitals. The Recitals set forth above are incorporated herein by reference.
2. Divorce. It is specifically understood and agreed by and between the parties, and each
party does hereby warrant and represent to the other that, as defined in the Pennsylvania Divorce Code,
their marriage is irretrievably broken. Husband has not, as of this writing filed an action in the Court of
Common Pleas, Cumberland, Pennsylvania. However, when such a pleading is filed and a divorce action
is commenced, the parties agree to take all legal steps (including the timely and prompt submission of all
documents and the taking of all actions) necessary to assure that a divorce pursuantto 23 Pa. C.S.A. S
3301(d) of the Divorce Code is entered as soon as possible. This Agreement and any ancillary or
supplemental agreements shall be incorporated by reference and merged into the proposed Divorce Decree
presented to the Court. Except as otherwise provided for in this Agreement, this Agreement shall remain
in full force and effect even if no final decree in divorce is entered.
Husband and Wife shall at all times hereafter have the right to live separate and apart from
each other and to reside from time to time at such place or places as they shall respectively deem fit, free
from any control, restraint or interference whatsoever by the other. Neither party shall molest the other in
any way whatsoever nor endeavor to compel the other to cohabit or dwell with him or her by any legal or
other proceedings. The foregoing provision shall not be taken to be an admission on the part of either
Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart.
3. Marital Propertv.
(a) Personal Property Division Husband and Wife acknowledge that they have divided
all personal property brought to the marriage and all personal property acquired during the marriage to their
mutual satisfaction. Husband hereby relinquishes all right, title and interest in Wife's personal property
currently in her possession, and Wife hereby relinquishes all right, title and interest in Husband's personal
property currently in his possession, except as provided herein to the contrary.
(b) Real Prooertv Division. The parties are the joint owners of real property with
improvements known as 1488 Timber BrookDrive, Mechanicsburg, Pennsylvania. The parties have
agreed that Wife shall execute, upon signing this Agreement, a Quit-claim Deed to Husband for purposes
of his acquiring sole ownership interest in said real property. Such Deed may be recorded by Husband
promptly after execution hereof. In addition, Husband shall pay to Wife the sum of Three Thousand
($3,000.00) Dollars in two separate payments of One Thousand ($1 ,000.00) Dollars each and Ten (l 0)
consecutive Monthly payments of One Hundred Dollars each. The wife may waive any or all of these
payments as may be agreed by the parties. Such a waiver will reduce the amount owed under this
paragraph by an amount equal to the waived payment
4. Debts and Obligations.
(a) Individual debts/obligations. Husband shall retain his IRA. Each ofthe parties shall
assume all debts and obligations presently in their individual names and shall indemnitY, defend and hold
the other harmless from said debts and obligations, whether incurred prior to, during, or subsequent to the
marriage. This shall include all personal, individual credit cards and personal individual loans by either
party. Each party hereby agrees to pay and hereby agrees to hold the other harmless from any and all
personal debts and obligations incurred by him or her on or after the date of separation, which is as of
September 1,2005. If any claim, action or proceeding is thereafter brought seeking to hold the other party
liable on account of any such debts and obligations, such party will at his or her sole expense defend the
other party against any such claim, action or proceeding, whether ornot well-founded, and indemnitY the
other party against any loss resulting therefrom.
3
(b) Joint debts/obligations.
(l) Wife agrees to obtain a loan in an amount sufficient to pay off the current
loan owed on the 2002 Nissan Altima and relieve Husband of all
obligations pertaining thereto. Wife expressly agrees to indemnitY, defend
and hold Husband harmless from any and all liability, direct or indirect,
including attorneys' fees and costs, which may arise in connection with
such obligations.
(2) Husband and Wife represent that there is a Mortgage and a Home Equity
Loan incurred during the marriage encumbering 1488 Timber Brook
Drive. Pursuant to section 3 (b) above, Wife is executing a Quit-claim
Deed to Husband. Consistent with the transfer of ownership, such
Mortgage and Home Equity Loans shall be assumed by Husband.
Husband expressly agrees to indemnitY, defend and hold Wife harmless
from any and all liability, direct or indirect, including attorneys' fees and
costs, which may arise in connection with such obligations.
(3) Husband and Wife represent that there are no joint debts or other debts
incurred by either ofthem from the date of separation, which is as of
September 1,2005, currently outstanding with respect to which the other
4
party may incur any liability now or in the future. Each party hereby
expressly agrees to indemnitY, defend and hold harmless the other from
any and all liability, director indirect, including attorneys' fees and costs,
which may arise in connection with an obligation, joint or otherwise, for
which the party has agreed hereunder to bear sole or partial responsibility,
or which the party has failed to disclose and provide for herein.
5. Legal Fees. Each party agrees thatthey shall be responsible for their own legal and other fees
incurred by them in connection with this domestic relations matter unless otherwise specified herein or
otherwise agreed to by them.
6. Other Writings. Each of the parties hereto agrees to promptly execute any and all documents,
consents, waivers, bills of sale, tax returns or other writings reasonably necessary to carry out the intent of
this Agreement.
7. Further Debt.
(a) Wife shall not contract or incur any debt or liability for which Husband or his property
or estate might be responsible and shall indemnitY and save harmless Husband from any and all claims or
demands, including attorneys' fees and costs, made against him by reason of debts or obligations incurred
by her.
(b) Husband shall not contract or incur any debt or liability for which Wife or her property
or estate might be responsible and shall indemnitY and save harmless Wife from any and aU claims or
demands, including attorneys' fees and costs, made against her by reason of debts or obligations incurred
5
by him.
8. Mutual Release. Except as otherwise provided herein and so long as this Agreement
is not canceled by subsequent agreement, the parties hereby release and discharge, absolutely and forever,
each other from any and all rights, claims and demands, past, present and future, resulting from the marriage
relationship, specifically from the following: alimony pendente lite; alimony; spousal support; division of
property; claims or rights of dower and right to live in the House; right to act as executor or administrator
in the other's estate; rights as devisee or legatee in the Last Will and Testament ofthe other; any claim or
right as beneficiary in any life insurance policy of the other unless specifically named otherwise or as
required herein; and any claim or right in the distributive share or intestate share ofthe other party's estate,
all unless specified to the contrary herein or in a subsequent writing signed by the parties hereto.
9. Tax Return. After the execution ofthis Agreement, the parties shall file separate individual
income tax returns. Each party shall be solely liable for any and all of their own tax liability and shall
indemnitY, defend and hold the other harmless from and against any such liability.
10. MedicallHealth Insurance. Upon execution hereof, each party shall be responsible for their
own medicallhealth insurance and the maintenance thereof, if any.
11. Entire Agreement This Agreement constitutes the entire understanding between the parties,
and there are no covenants, conditions, representations or agreements, oral or written, of any nature
whatsoever, other than those herein contained.
12. Legallv Binding. It is the intent of the parties hereto to be legally bound hereby, and this
Agreement shall bind the parties hereto and their respective heirs, executors, administrators and assigns.
13. Full Disclosure. Each party asserts that she or he has fully and completely disclosed all the
6
real and personal property of whatsoever nature and wheresoever located belonging in any way to each
of them; of all debts and encumbrances incurred in any manner whatsoever by each of them; of all sources
and amounts of income received orreceivable by each party; and of every other fact relating in any way
to the subject matterofthis Agreement These disclosures are part ofthe consideration made by each
party for entering into this Agreement.
14. Costs to Enforce. In the event that either party defaults in the performance of any duties or
obligations required by the terms of this Agreement, and legal proceedings are commenced to enforce such
duty or obligations, the party found to be in default shall be liable for all expenses, including reasonable
attorneys' fees, incurred as a result of such proceedings.
IS. Agreement VoluntarY and Clearlv Understood Each party to this Agreement acknowledges
and declares that he or she respectively:
(a) Is fully and completely informed as to the facts relating to the subject matter of this
Agreement and as to the rights and liabilities of both parties;
(b) Enters into this Agreement voluntarily after receiving the advice of independent
counselor, having been advised to consult independent counsel, has knowingly and voluntarily chosen to
forego such consultation;
(c) Has given careful and mature thought to the making of this Agreement;
(d) Has carefully read each provision ofthis Agreement; and
7
(e) Fully and completely understands each provision of this Agreement, both as to the
subj ect matter and legal affect.
16. Amendment or Modification 1bis Agreement may be amended or modified only by a written
instrument signed by both parties.
17. Applicable Law. 1bis Agreement shall be govemed, construed and enforced under the statute
and case law of the Commonwealth of Pennsylvania.
18. Counterparts. This Agreement may be executed in separate counterparts, each counterpart
deemed an original and when combined, represents the legal binding intent of the parties hereto.
19. Severability. If any part of this Agreement is determined to be invalid by a court of competent
jurisdiction, such determination shall not invalidate the entire document but shall apply only to that phrase,
sentence, paragraph or section. The remainder ofthe sentence, paragraph, section and Agreement shall
continue in full force and effect
IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year
first above written:
Wp:NESS:
/
\
"-'---. /
HUSBAND:
/~~
Viktor Shluharchuk
WIFE:
tJtuuz-
cfUttdt:a-i~
Olena Shluharchuk
8
COMMONWEALTH OF PENNSYLVANIA
" ' : SS.:
COUNTY OF CUMBEKLAHO -I:j(:U-y2/4~J
1/kl
On this, theL day of ;L,'-t;LL. J Yii~l.r.-/ ,2005, before me, a Notary Public, the
undersigned officer, personally appeared Viktor Shluharchuk, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument and acknowledged that he executed the
same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
W' ~
fC:-{
1IAJ_ cZ}'. ~~L--
Notary Public ;
My Commission Expires:
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ANNE E. HOUSER, Notary Public
Lower Paxton Twp., Dauphin County
My Commission Expires September 25, 2007
COMMONWEALTH OF PENNSYL VANIA
. SS.:
COUNTY OF (;'T IMBER I. ^ pl& ~.).'i~'c;/'(@:
On this, the /;'fIJ-dayof ~<[ JJL!tI'.~ ,2005, before me, a Notary Public, the
undersigned officer, personally appeared Olena SWuharchuk, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument and acknowledged that she executed the
same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
(;: KL. E ~AAJJ
Notary Public
My Commission Expires:
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
ANNE E. HOUSER, Notary Public
Lower Paxton Twp., Dauphin County
Mv Commission Expires September 25, 2007
(2
,-~
I
-'
(,,)
L
()
-n
::;:J
r,'i
... ,~
~ OVij'1 \'}ii\ .
CUSTODY AND SUPPORT AGREEMENT
THIS CUSTODY AND SUPPORT AGREEMENT, is made this ~ day of
, 2005 by and between Viktor Shluharchuk, of 1488 Timber Brook Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050 ("Husband") and Olena
Shluharchuk, of 1488 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania,
17050 ("Wife").
RECITALS
WHEREAS, The parties have entered into a separation Agreement, and it is their
desire to live separate and apart; and
WHEREAS, the parties have minor children, namely, Vladimir, born May 13,
1999, and Alexander, born June 14,2005; and
WHEREAS, the parties desire, in the best interests and welfare of their children,
to define herein the terms of their shared custody and support and make their Agreement the
Order of the Court.
WITNESSETH
NOW THEREFORE, the parties hereto, INTENDING TO BE LEGALLY
BOUND, hereby agree as follows:
1. Recitals. The Recitals above are incorporated herein by reference.
2. Child Custody. Father and Mother shall have shared legal custody of Vladimir
and Alexander, which may be modified only by written agreement of the parties hereto or
further Order of Court. Mother shall have primary physical custody.
"& ., ,,---
A Partial Custody. Father shall have periods of partial physical custody
at such times as agreed between the parties in the best interests and welfare of Vladimir and
Alexander.
B. Vacation. The parties agree to extended yearly partial custody periods
for a period of three (3) full weeks each, inclusive of weekends before and after, upon at least
thirty (30) days notice to the other party. Such period may be divided into as many as three
separate one week periods as the parties may agree.
C. Holidavs. Holidays shall be divided between the parties as they shall
agree after consultation with each other.
3. Changes in scheduling. Should Father be unable to exercise his scheduled
custody, he shall notitY Mother at least twenty-four (24) hours in advance unless an emergency
situation arises.
4. Effective date. This Custody and Support Agreement shall become effective
upon execution.
5. Changes and Adaptation. Father and Mother agree to cooperate in making
changes and adaptations to this Custody Agreement as and if they become necessary, having due
regard to the interests of Father, Mother and Child. The consent of either party to such changes
and adaptations shall not be unreasonably withheld. Any changes and adaptations shall be in
writing and signed by the parties hereto.
. ~ ,'" "'-
6. Support. Father shall continue to pay to Mother the sum of Two Hundred
($200.00) Dollars weekly as child support for The children. This sum may be increased or
decreased by agreement of the parties in writing signed by both parties and shall be evaluated
yearly by the parties during the month of June, giving due regard to Father's ability to pay such
sums.
7. Counterparts and Court Order. This document may be executed in separate
counterparts, which when combined form the intent of the parties. The parties hereto desire that
this Agreement and any subsequent agreements shall be incorporated by reference and merged
into the proposed Divorce Decree presented to the Court.
8. Applicable Law. This Agreement shall be governed, construed and enforced
under the laws of the Commonwealth of Pennsylvania.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement the
day and year first above written:
WITNESS;
MOTHER:
t
/ ..~ /
. / ,/'
. >/. .
,?/
1Jt:uw. dULtdcu.dutd-
Olena Shluharchuk
.------
WITNESS,,'/ //,
.- ,/ r
..// / /,/
" .//'" ,/.'
(. / .. //
. ./ ./"'
/
FATHER:
~c.
Viktor Shluharchuk
... ..'- w
COMMONWEALTH OF PENNSYLVANIA:
COUNTY of'1'Jo..'''''fk.A./t\..-
On this, the 'il'~?- day of ')l~iJ..UYJ{lio.Vu ,2005, before me, a Notary Public,
the undersigned officer, personally appeared Olena Shluharchuk, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within instrument and acknowledged
that she executed the same for the purposes herein contained.
SS.:
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
(1~-L Q~V ~
Notary Public /
My Commission Expires:
(SEAL)
.-0.~~~5~~~'.L.::~.l...E~.:~Y!2~~~-~!"~. Y L V ~~~!\_,
I i~Ci-/P'" ~~L/';_
A.W..JE ~:-j:!: \;' :~;ubiic
\ ~()wer p~)(\.,,'~ ',; :,,/,:n Coumy
My Commission Expires ;~,8plember 25,2007
....._----_..,---'- "
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF J:)CUAfJJt.-U/v : SS.:
)<.1, J
On this, the L day of I~Li/l'I....lcL~ ,2005, before me, a Notary Public,
the undersigned officer, personally appeared Viktor Shluharchuk, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the within instrument and
acknowledged that he executed the same for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
UAJ- C~ 9d~d-L~
Notary Public
My Commission Expires:
(SEAL)
'~9...t-.!.~.p~:.~~~'-:~:I!'l::::.c PF~NNS yt.v r\N ,"_
!'JCT ARIAL SEA~--~-'
'\\~':E_ ,_ i-10i:"q:r; i',Jofary PLblic
-,,(,,/,<("!, i1x1J_ ;'I/',/-. i)a~.'f)hin Counry
L~Y Cl.)f;:rnissior i::~:plres Sepiember 25 2007
-..-.....'-..-.----.-.----. '
~>:'J ,1
,~~..., ':;"i,
C'-..
(,-:
-;::\
,\,-;,
--
--
J:
c...)
. .
-------
(Jl
i ri
(,) z
~ ~3
~~Il
;6'
cr
2
~
'"
o
~
Ii'
3
!!
o'
'"
I!-
3
'"
g
~
~
~
~
*
--.J
CJ
CJ
In
ru
In
--.J
CJ
CJ
CJ
CJ
"...
W
In
CJ
In
"...
--.J
ru
rr
.
C~'L-\ ,VILd-+ L
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2. and 3. Also complete
~em 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
()\mQ 31 \ uh:1Jelluk
55 V II IQq{ CL:w1t-
f,'QL~)"'(l.f\ lc,Sbu..rx-
R:1 IlctD
.
ot..- P70 {!/~,L
6+
I"
.:J C:i/LLJ/ c..L
.
. . .
A. Signature
o Agent
o Addressee
B. Received by (Printed Name) I C. Dale of DeIlY"')'
D. Is delivery address different from item 11 0 Yes
If YES, enter delivery address be(ow: 0 No
x
~iceType
CertifIed Mall Mall
Registered II ~Receipt for Merchandise
o Insured Mall ~~~~~: '
4. Restricted Denvel)'? (Extra Fee) 0 Yes
2. Article Number
(Transfer from setvIo
PS Form 3811, February 2004
'"
7005 2570 0001 3505 1726
102595-02-M-1540 :
~~o i
ff--=:; S ~
::::Pl
.D ;;
E-~Y"
;=
!-~.
'" 0
~ ~1!
~ ~ I [t
= m ~
~:c
im
~ i:> 3 ii
= ",Ill
H
~-
if
f
~
~
0.
~.
"
, ~,',.
',:::'-'-
.
l
It
o
~
o
. . .
0)>(1)"'0;:;:0
~::t0 :].(1) 0
:J~g:a.33
_:Tel.'<~'2.
~g:~g:::;;~
- Eii"al ":0(1)
aoo::JCD;:+
'"am!!l~H
:::;; (DaCfJ
~O~~3..:-'-
~ 9=3 Q.o!"
(I) CP_J>> d)m
" cr~Q.="
CDQ)IJ)a.<a.
!1.~~ j!!i"
tit_dorn)>
'g:o:Jg.~
(D,<g.~.(')
3g"[0
!!'.' iil. 3
iJ < "2.
-. CD ~
ill il "
-" "
<';f.., "'-
''a'P ~ pl >< :>
"'l~! ~:t-
In ~<.!!
CD 8. "C;
~ Ql f,.. 0" .)il
...o.~,<
~i ~1 ~,
~~ ~.i[ ~
~ ~ K.~
III if ;:i.~
Ii; ~
o ~ '"
. 3
.. ~ 0
00 ~ 00
~ ~ a ~~
~ a. \1l
~. ~ ;a
-< ~
~
Domestic Return Receipt
(J)
m
z
o
m
??
"
o
;;:
1J
e-
m
n::
:t
C;;
~
"
::!
o
<:
"
o
~
'"
;;J
~
'"
'"
'"
"
::;
o
<:
o
<:
"
~
~
""
.n
ru
r-
r'l
U.S. Postal Service,.
CERTIFIED MAIL. RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
LJ1
CJ
'LJ1
Tn
Postage $
r'l
CJ
CJ
CJ
Certified Fee
Postmark
H'M
Return Receipt Fee
(Endorsement Required)
o Restricted Delivery Fee
["- (Endorsement ReqUired)
LJ1
ru
911610Lfl
Total Postage & Fees $
LJ1
o Sent To
CJ
r-
sfniBfAjifi,io::n.....nn...--n-n.--nn.......-n...----___..__n_.......n_hUn
or PO Box No.
ciiY~-State,-zip+;r-.--------_n---n __h__n.__..n___ __un_..._______..___________
PS Form 3800, June 2002 See Reverse for InstructIons
C) r<'J
C-'l ,")
( , -n
,:f"
"-;-1 , Cn. :-:;-J
c: ...1...
["n
I
-.J , ~
J '" d
<')
i ~-n
, ':"~
J ( ,.) ~lJ
C .<
I
V.
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 06-870 CIVIL TERM
VIKTOR SHLUHARCHUK,
PLAINTIFF
OLENA SHLUHARCHUK,
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
AFFIDAVIT OF CONSENT
L A complaint in divorce under Section 3301(c) or (d) of the Divorce Code was signed on
February 9,2006 and filed on and is time stamped February 13, 2006. A time-stamped copy was
served on plaintiff.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property. Lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
I veritY 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. Cons. Stat. S 4904 relating to unsworn
falsification to authorities.
Date:
5'j;W/P6
",~
Viktor Shluharchuk
~~) ;--...."1
c-::> ~
,~ '.-.'
,-'-'...... -n
c_ :::1
i~ ~l
-.J
. )
(,,>) :~S
,,', .<
VIKTOR SHLUHARCHUK,
PLAINTIFF
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V.
:NO. 06-870 CIVIL TERM
OLENASHLUHARCHU~
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 330HC) or CD) 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{ 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 veritY 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.
Date:
5/tIU?/PtJ
f/.~
Viktor Shluharchuk
n
c-
:"ll
:-;:1
nl
I
-J
(/.J
U",
V.
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYL VANIA
:NO. 06-870 CIVIL TERM
VIKTOR SHLUHARCHUK.
PLAINTIFF
OLENA SHLUHARCHUK,
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
AFFIDAVIT OF CONSENT
L A complaint in divorce under Section 3301(c) or (d) of the Divorce Code was signed on
February 9, 2006, and filed on and is time stamped February 13,2006. A time-stamped copy was
served on plaintiff.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property. Lawyer's
fees or expenses in do not claim them before a divorce is granted.
I veritY 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. Cons. Stat. 94904 relating to unsworn
falsification to authorities.
Date: 1J1ew ell, ~6
t')(i2aa,
Olena Shluharchuk
------~.
_.._---~~
(.')
cr:
';=::
~
VIKTOR SHLUHARCHUK,
PLAINTIFF
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V.
:NO. 06-870 CIVIL TERM
OLENASHLUHARCHUK,
DEFENDANT
:CIVIL ACTION - LAW
:IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 330HC) OR (0) OF THE DIVORCE CODE
I. 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 in 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 veritY 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.
Date: 1!J::uj cV, JJJo6
(j
r)
'::-:-
()
-T}
--,
ri'12J
~
~~~-':
(,.)
(j,
, .
VIKTOR SHLUHARCHUK,
PLAINTIFF
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
V.
:NO. 06-870 CIVIL TERM
OLENASHLUHARCHU~
DEFENDANT
: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:
I. Ground for divorce: irretrievable breakdown under 3301 (c) of the Divorce Code.
2. Date and manner of service of the Complaint: United States First Class Certified Mail,
Return Receipt Requested - February 17,2006.
3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce
Code: by Plaintiff: May 20, 2006; by Defendant: May 21, 2006.
4. Date Plaintiff's Waiver of Notice in 9330I(c) Divorce was filed with Prothonotary:
Contemporaneously with this Praecipe.
Date Defendant's Waiver of Notice in 93301(c) Divorce was filed with Prothonotary:
Contemporaneously with this Praecipe.
5. Related claims pending: Matrimonial Settlement Agreement and Custody and Support
Agreement between the parties dated November 8, 2005, to be incorporated by reference and
merged into the Divorce Decree.
I .
Date: OS/25/06
:::?)
:~J
f11
-J
(N
(.::
iti
iti
iti
iti
iti
iti
itiiti itiiti
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
VIKTOR SHLUHARCHUK
No.
06-870 CIVIL
VERSUS
OT.F.NA !=;HT.TJHA1U'HTJK
DECREE IN
DIVORCE
AND NOW",-
~\J\AJ) If ~~ IT IS ORDERED AND
DECREED THAT
VIKTOR SHLUHARCHUK , PLAI NTI FF,
AND
OLENA GIILUIIARCIIUK
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT
YET BEEN ENTERED;
'UQW/_
J.
By TH
PROTHONOTARY
itiiti
itiiti
itiitiitiiti~itiiti~iti~itiiti itiitiitiiti ~ itiiti~~~itiiti~iti~iti~~~~
.~~ ~ ~ ?fl-;/-?
~ .~ ~ ~ ~ ;:'fl '#-6/-1/
. .
.
~
".-,"
. ".... .a
t;~ .. ""',. ,1\'~"~\,..1IIlI.} .,