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Home My WebLink About06-4000 " II MICHAEL J. DZEZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - ~1laJ CIVIL CONNIE S. DZEZINSKI, 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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. 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 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 " II MICHAEL J. DZEZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 _ ~Hnl CIVIL CONNIE S. DZEZINSKI, Defendant CIVIL ACTION-LAW IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff, Michael J. Dzezinski, is an adult individual residing at 39 Eastwick Lane, Carlisle, Cumberland County, Pennsylvania, 17013-7683. 2. Defendant, Connie S. Dzezinski, is an adult individual residing at 18 Kengrey Drive, Carlisle, Cumberland County, Pennsylvania, 17013-7442. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 10, 1998 in Key West, Monroe County, Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. , II WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER 11J/J i J I. "^ /" MiCh~ ~ E\qUire 1.0. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff mas\Domestic\Dzezinskl\divorce.comp II . MICHAEL J. DZEZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v, NO. 2006- CIVIL CONNIE S. DZEZINSKI, Defendant CIVIL ACTION-LAW IN DIVORCE VERIFICATION 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.SA S 4904, relating to unsworn falsification to authorities. Date: July I Z; , 2006 . - . Dzezinski ,~ "' ~ ~ ~ w ~ ~ '- ~ ~ '0\ l. ~ ~ ~ '\ ~ \. ~,\ . ~~ ~~ ~ ~ "'.- ,.... ,"j ~ [" i ~'rl :~ c.~ i-"1-.1 .."'1 II V. CONNIE S. DZEZINSKI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 4000 CIVIL CIVIL ACTION-LAW IN DIVORCE MICHAEL J. DZEZINSKI, Plaintiff ACCEPTANCE OF SERVICE I II II of the Divorce Complaint in the above-captioned case. II I I I AND NOW, this t?{O 'lAday of July, 2006, I, Connie S. Dzezinski accept service ~~~. Connie S. Dzezi t...:l r'.~" i'.> 1"_' l..:_~' MICHAEL J. DZEZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006-4000 CIVIL ACTION - LA W CONNIE S. DZEZINSKI, Defendant : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Defendant in the above matter, hereby intends to resume and hereafter use the previous name of Connie S. Negley and gives this written notice avowing her intention in accordance with applicable law. ~;!~~. Connie S. Dzezinski To be known as: ~?I* Connie S. Negley COMMONWEAL TH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND On the t2 ~ day of !1.p~ 2006, before me, a notary public, personally appeared Connie S. Negley (formerly known as Connie S. Dzezinski), known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto e'r hand and seat _".....-.v_ ()~ tr= NOTARIAL SEAl. Notary Public VALERIE F. GSELL. NotIryPublic 1:OMMGN :nuw......-n.,vANIA Carlisle Boro" Cumberland County NOTARIAL SEAl '" f""mmic:c:ion Expires October 9, 2010 VAlStE F. GSEU.. NotIry Puelic CarlIle 101O., CtInbnnd ~ CoI......, 0cIaber 9. 2010 c>r... (") f'o.:) c = 0 = ('":) -:.:z <" Q"'\ -0 ,,"- ~ ~ n'--:t~~r (/) :r! .. 0 ~i!' r"I'1 -0 m:D ,..... '""" -0 l"\.) -om c.n :nO Ei' 0 ~( ~;1c) (/Il )ll ~~.'.' v -r-"fj ~ -.-~ {~?6 ~~ p. r" ;:5 rll '-- l"\.) Z ,...( =2 "'-.) 55 0 -< :-,;~:\".Jl ~..},." ''\ ...... ............."'...~.._._. .. ~'.. .,,"..:..~l'\.,~ .......,>.VJY21.Mil'1 '10 Hf.JA.tWMOf1MO:) :.._....~ ~~:;~~ JI~!~~TO~, . .~ . .'f)'.i''!...., ,J.J.~" ~~I~~J..." , '))~'ll'~ 01'';';'.''.m>l;; ,',IoM ~lhi:) I rr,i\' ,} ""'.',"'r'[' "".".,,:; ,.......J:;--, ..j ...l I ... .'1"' ..." vv ~~. -J\,fi'ii'J!P"".". '". ,1-7- .._. _,..'_' ...., ..,__............._. . _....._.~_h._......_'. ......... .t;~'~i.. , ~: ... II MICHAEL J. DZEZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 - 4000 CIVIL CIVIL ACTION-LAW IN DIVORCE V. CONNIE S. DZEZINSKI, Defendant 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: Defendant signed an Acceptance of Service form on July 20, 2006. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on October 27,2006; and Defendant on October 27,2006. B. (1) date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER ffmllv Michael A. Scherer, Esquire 0 ""-' C c::.:> 0 = ;;-~" cr-. -0 0 --l c") :r:~ -~. r-np G,,,, }3 ~2J 0 '..:~ (J) -0 -Y. ""1". ~~F; ~~2 (.....) ;~~ln :2 CJl ~ -< II MICHAEL J. DZEZINSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CONNIE S. DZEZINSKI, Defendant NO. 2006 - 4000 CIVIL ACTION-LAW IN DIVORCE CIVIL PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 te) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 14, 2006. 2. An Acceptance of Service was signed on July 20, 2006. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: Octobero?? ,2006 ~eZir,slti · .---- ,'" . .' 0 ,....., 0 c::, s:; = 11 0"'\ "" :r-n 0 ('"'"';, ['11- -l c::: W "~rJ1 \ t :0 c;-; 0 (-'UJ (~1 .:.::! .-f -0 -;--, ., ---. ~:". -,,';C) ;~m (...,) ~ (.n .IJ -< MICHAEL J. DZEZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-4000 CIVIL ACTION - LAW CONNIE S. DZEZINSKI, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 14, 2006. 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 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. section 4904, relating to unsworn falsification to authorities. ,"7 Date: ~~'D-:; 7 -ob ~~~ Connie S. (Dzezinski) Neg ey, efendant () ~ "1:1!~; EPC~ ~"-;:.~- -"'.... /"-'" .i:~ _ ;J~: ;~-- ->t; =2 ~ ~ o ('J --I c..> o 2::la ~ ~ -~ :C..,..., n1-'.J 1""-' -001 ."DC; ;~j :~~IS~ ;-j .J:;>. '-:jJ -< - - a f'\.~ MICHAEL J. DZEZINSKI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA V. : NO. 2006-4000 CIVIL ACTION - LAW CONNIE S. DZEZINSKI, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Date: 10 - ;;;7--cYt ~ (") ~ ~, \J'T' fn? :" :-:: . ~~~! ~\- [~~ '-J;: .- i2: (~ ~-~~; ~ -.. l':> = = c::r> <=) c-;; --l W o o 1/ ~ 1"11 ::!J I -Ot~..{ f~~ ~~;n ?n -< o N ;t;'+i;t; ;t; ;t; ;t; ;t;~~ ~ ;t;~~ ;t;~;t;~ ~ ;t;~~;t; ~;t; ~~;t;~~~~ ~~~;t;~~~~~;t;;t;;t;;t;;t;~;t;;t;;t;;t;~~;t;;t;;t; ;t; ;t;;t;;t;;t;;t;;t;;t;~ ;t; ;t; IN THE COURT OF COMMON PLEAS ~ ;t; OF CUMBERLAND COUNTY ~ ;t; ;t; STATE OF PENNA. MICHAEL J. DZEZINSKI, Plaintiff No. 2006 - 4000 CIVIL VERSUS CONNIE S. DZEZINSKI, Defendant DECREE IN DIVORCE AND NOW, lJ~ z-~ , 2-enJ~ , IT IS ORDERED AND DECREED THAT MICHAEL J. DZEZINSKI , PLAINTIFF, AND CONNIE S. DZEZINSKI , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD I N THIS ACTION FOR WHICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; None. ;t; ;t; ;t; ;t; ;t; ;t; ;t; J. ;t; ;t; ;t; ;t; ;t; ;t; ;t; PROTHONOTARY ;t; + ;t; ;t; ~~~ ~~ ~~~~~ ~~~~~~~~ ~~~~~~~~~~~~~~~~~~ ~~~~~ ~~~~~~~~ + + ~ p. ~ ~'~ ~~ t961'? -J/ ~? r-7-~~/~ cfJ{J.1-)/ .,~"... 't