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HomeMy WebLinkAbout06-4109 . SAIDIS, FLOWER &. UNDSAY AI..~_..~.~ 26 West High Strt!et Carlisle. PA PAUL J. KARAGIANNIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ~- 'frDq ~ IN DIVORCE v. ANASTASIA V. KARAGIANNIS, Defendant NOTICE TO DEFEND 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 wamed 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-91 08 Carol J. Lindsa . Es Attomey Id. 93 26 West High reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff - SAlOIS, FLOWER & UNDSAY .... u_.,......lAW 26 West High Street Carlislc:,PA PAUL J. KARAGIANNIS, Plaintiff .IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW -r NO. O{,.'{ltJ'l ~ f<<- v. ANASTASIA V. KARAGIANNIS, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 Ie) or Cd) OF THE DIVORCE CODE 1. The Plaintiff is Paul J. Karagiannis, an adult individual residing at 803 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Anastasia V. Karagiannis, an adult individual residing at 29 Stone hedge Lane, Mechanicsburg, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 5, 2003 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. SAIDIS, FLOWER & LINDSAY JU._ ~ilRN 26 West High Street CarUsle, PA II I WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with ~3301 of the Pennsylvania Divorce Code. Dated: Respectfully submitted, 7/13/01 Carol J. Linds , Attorney Id. 69 26 West High reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS FLOWER'&. LINDSAY AlI....._.~..A'W 26 West High Street Carlisle,PA II VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. CoSo ~904. relating to unsworn falsifications to authorities. Date: 1-' 3-0(, 'JUL 19_ QR'? "- ~~j ~ ~ - ~ 1~'~; (1 -1\ ~-? \\~\ , ,'.....J c:.:.i ~ 0- ~ C;} (~ ';~~ c::~ SAIDIS, FLOWER & UNDSAY ..... .~.~ 26 West High Street Carlisle. PA II PAUL J. KARAGIANNIS, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. .')~-4(,)~ Dlr4 leA IN DIVORCE ANASTASIA V. KARAGIANNIS, Defendant ACCEPTANCE OF SERVICE I, Robert B. Lieberman, Esquire, counsel for Defendant, accept service of the Divorce Complaint in the above-captioned matter and certify that I am authorized to do so. ~ I. '1-"Cl(. Date Respectfully sUbm~ o It )?~.__. .. f ~Lieberman, Esquire 500 North Third Street, 12th Floor P. O. Box 1004 Harrisburg, PA 17108-1004 ~ g ~ ~ ;;:t ~~ :g; I; "'t)(V, 'Z,':r" G') - "P~ ZC' U\ (") m;P,; =:C. :'1 ~f; -0 (::>~ J:>r; ~ :;;&tf'\ ~~ I":'? S ~ 0 ~ :;:- SAIDIS, FLOWER &. LINDSAY ~~folAW 26 West High Street Carlisle, PA PAUL J. KARAGIANNIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.06--ke9 v. ANASTASIA V. KARAGIANNIS, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301(c) of the Divorce Code was filed July 20, 2006 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 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 unsworn falsification to authorities. Date: / / - /R... 06 /?aJ~ -;:L~.. Paul J. K giannis' PLAINTIFF'S 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 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 unsworn falsification to authorities. Date: /J -fIr- 06 ~ / ~~;nM' P'aul J. Kcffagiannis MOV , lltd o ~; ",- r-:l ,-""x- r::::;) 0..... c:-~J ..-,~ N -';.:~ (.::) -n -\ :c -r1 ,np _(1 r-n :', c; -~--~~ (~) .~._: '~!', "~ ~-,\ 7:~\ -~,~cn :::.\ ;; ~< <-:? 1') Cf.) PAUL A. KARAGIANNIS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : NO. 06-4109 CIVIL TERM ANAST ASIA V. KARAGIANNIS, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) ofthe Divorce Code was filed on July 20, 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. ~4904 relating to unsworn falsification to authorities. DATED: II. 14 .0" ffllJ] },1tJ4jz ;I d:ar~.it1.lA U-f ~ Anastasia V. Karagiannis, Defendant r-:> (.~....) ;;.:,:~::J: c)....... o -'1'1 .-\ ~.~ N _J ---.:.... (~,'-'; ') :::::~ :f.J ;..<: C:l N PAUL A. KARAGIANNIS, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 06-4109 CIVIL TERM ANAST ASIA V. KARAGIANNIS, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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 Waiver of Notice 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. DATED: /1.1.6 .., YiahIa6/' Anastasia V. Karagiannis, Defendant tU5 :-.il :::3 r-.0 -....J -;"l .-:.:-) r-"",.:- j . -.~.l .'1>~ C'-J :.:< SAIDIS, FLOWER & LINDSAY A:I"IOIINm-AToIAW 26 West High Street Carlisle, PA PAUL J. KARAGIANNIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-4eS L/-I oq IN DIVORCE v. ANASTASIA V. KARAGIANNIS, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's attorney accepted service of the Complaint on August 1, 2006. An Acceptance of Service was filed with the Court on August 15, 2006. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: November 18, 2006 and filed with the Prothonotary on November 21, 2006. By Defendant: November 20, 2006 and filed with the Prothonotary on November 27,2006. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: November 18, 2006 and filed with the Prothonotary on November 21, 2006. By Defendant: November 20, 2006 and filed with the Prothonotary on November 27,2006. Carol J. Lindsay, Es'quir Supreme Court ID o. 26 West High Street Carlisle, PA 17013 717-243-6222 C) s;;. ""'- r--' ".r-'~1 g -<'.:.: r"~~ ~ --,,. -.;..i.. , , .....-A."I .. ,.,-~: \ -..'-" C:1 (.,) ~..lJ =-< ;I; ;I; ;I; ;I; ;I; ;I; ;I; ;I; ;I; ;I; [f. [f. ;I; ;I;[f. '" '" [f. :Ii :Ii :Ii :Ii :Ii :Ii:li[f.:Ii:li:li;l;:Ii:li ;I;:Ii[f. :Ii ;I; ;I;[f. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. PAULJ. KARAGIANNIS No. 06-4109 VERSUS ~ ANASTASIA V. KARAGIANNIS :Ii [f. ;I; ;I; ;I; DECREE IN DIVORCE AND NOW, NO\le.~\ot.r PAUL J. KARAGIANNIS , l(){)b, IT IS ORDERED AND lB DECREED THAT , PLAI NTI FF, AND ANA~TA~TA V KARAGTANNTS , DEFEN DANT, 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; The terms ofthe Separation and Property Settlement Agreement dated August 14,2006 are incorporated, but not merged, into this Decree in Divorce. BYTH~1: W \ ATTEST' ~ \ \ J. ( ~iJPROTHONOTARY ;I;:ti :ti:li:li :Ii:ti:ti:li :Ii :Ii :Ii :ti:ti :ti:li:ti:ti:ti :ti:ti:ti:ti:ti :ti:ti:ti:ti :ti;l;:ti :ti:li;l;:ti:li ;to ;to ;to ;to ;to ;to ;to ;to ;to ;I; ~ ~ ~ "r-'~)/, %7- 'J- c/ 4;cry?? ~ 66p ~ 'X. ~ ~e/ / - . -. J- i ",. 't . . .