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Home My WebLink About06-1771w FRIEDMAN & KING, P.C. Richard S. Friedman, Esquire ID #07176 600 N. Second Street Attorney for Plaintiff Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 Tel.: (717) 236-8000/Fax: (717) 236-8080 GEORGIOS D. KAKAZIOTIS, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. U1? - / y^j f l (vc C ??JLtr? RAMONA D. THOMAS, COMPLAINT IN DIVORCE Defendant 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, Cumberland County Courthouse, I Courthouse Square, Carlisle PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 submitted, & KING, P.C. By: 600'N. Second St„ 5th P. O. Box 984 Harrisburg, PA 17108 (717)236-8000 GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Utz - 1 "1'7/ l2 l COMPLAINT IN DIVORCE L 1. Plaintiff is Georgios D. Kakaziotis, who currently resides at 1003 Yverdon Dr., Camp Hill, Cumberland County, PA 17011. 2. Defendant is Ramona D. Thomas, who currently resides at 7079 Kuhn Rd., Greencastle, Franklin County PA 17225. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 20, 1999, in Martinsburg, West Virginia. 5. Plaintiff avers that there are no children of the parties under the age of eighteen (18). 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on January 1, 2006. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 4 Respectfully submitted, & KING, P.C. Date: 3 t 06 600 N. Second Street Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 RSF:ka VERIFICATION I, Georgios D. Kakaziotis, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Georq Georgios D. Kakaziotis Dated: -? I y I GI-1 C O c ? CZ-) GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 010- COMPLAINT IN DIVORCE ACCEPTANCE OF SERVICE I, Ramona D. Thomas, hereby acknowledge that I received a copy of the Divorce Complaint filed in the above matter on 312.8 O C i 1 ? ^1 a ona . Thomas -, ' , ° `; ' , . ?..-, _ _ -; GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1771 Civil COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 27, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. 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. § 4904 relating to unworn falsification to authorities. DATED: ( Z8 I 0 Zwa?zWl eorgios D. I ak iotis, Plaintiff 1 C.. 1 C C)- GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1771 Civil COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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. 4. 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. § 4904 relating to unworn falsification to authorities. Date: (o 12-R 10( Ge Dm 1 lie Georgios Kakaziotis, Plaintiff ?? r? C; F? -?: --a • -- r-? : `- r ' r 7 , r ?a. r-' ? l._. _.. ?.. ! <:; "-- ti, -. ?_,. =-c: GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1771 Civil COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 27, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. 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. § 4904 relating to unsworn falsification to authorities. DATED: / ?j O KJ2 b J o a D. Thomas, Defendant ? ti: ? ? J .? ... C ' ..}r; ?? w ?;? GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1771 Civil COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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. 4. 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. § 4904 relating to unworn falsification to autho Date: 6 2? D no al). omas, a endant -? _ n _I ` f' } Q - 1- ' _ _. ..W1 GEORGIOS D. KAKAZIOTIS, Plaintiff V. RAMONA D. THOMAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1771 Civil COMPLAINT 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: personal service upon Defendant on 3/28/06, Defendant signed Acceptance of Service on 3/28/06 which was filed with the Prothonotary 4/6/06 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff 6/28/06; by Defendant 6/28/06. 4. Related claims pending: There are no related claims pending. 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: (b) Date Plaintiffs Waiver of Notice was filed with th rothonotary: 6/30/06 Date Defendant's Waiver of Notice was filed e Prothonotary: 6/30/06 for ?., - "> ? `r, ?:; ?? .? <_ -' `? ? <;:: ,: ?, .. _ _ ._ `_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY d, STATE OF PENNA. GEORGIOS D. KAKAZIOTIS NO. 06-1771 Civil VERSUS RAMONA D. THOMAS DECREE IN DIVORCE AND NOW, IT IS ORDERED AND Georgios D. Kakaziotis DECREED THAT PLAINTIFF, Ramona D. Thomas AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,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; None BY THE CQURy: AT ST: ? J. "R!fROTHONOTARY 46p ?eV 167-? NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFFS JOHN P. MURRAY and KIMBERLY A. MURRAY, Husband and wife Plaintiffs VS. STANLEY GRIMWOOD, III, Individually and as agent for and t/d/b/a GRIMWOODS MASONRY, and its successor in Interest, GRIMWOODS MASONRY AND HARDSCAPES, INC., A Pennsylvania Corporation, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 06-1777 Civil Term CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Kindly mark this action settled, discontinued and ended with prejudice. / 2008 November 21 2008 N C. WOLF, ESQUIRE WOLF & WOLF 10 West High Street Carlisle, PA 17013 717-241-4436 SUPREME COURT ID #87380 Attorney for Plaintiff BARBARA SUMPLE-SULLIVAN, ESQUIRE 549 Bridge Street New Cumberland, PA 17070-1931 717-774-1445 SUPREME COURT ID #32317 Attorney for Defendant £" r^`.' .t _ ;7