The URL can be used to link to this page

Home My WebLink About06-45950 AVA M. GLAVAS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 04-4/5 925 DANIJEL GLAVAS, CIVIL ACTION -LAW Defendant : 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 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 AVA M. GLAVAS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA DANIJEL GLAVAS, : CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Ava M. Glavas, an adult individual residing at 527 North Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043. 2. Defendant is Danijel Glavas, an adult individual residing at 2400 North Second Street, Apt. 4, Harrisburg, Dauphin County, Pennsylvania 17110. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on May 8, 2004 in Enola, Cumberland County, Pennsylvania. 5. There are no minor children born of this marriage. 6. The parties separated on June 21, 2006. 7. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Ava M. Glavas, prays this Honorable Court to enter judgment: A. Awarding Plaintiffa decree in divorce; and B. Awarding other relief as the Court deems just and reasonable. Dated: 2006 40,avas, Av Pro 527 North Second Street Wormleysburg, PA 17043 AVA M. GLAVAS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06- YS"99 DANIJEL GLAVAS, : CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT REGARDING COUNSELING I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unworn falsification to authorities. Dated:_ XAr, 14 AVA M. GLAVAS AVA M. GLAVAS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. DANIJEL GLAVAS, : CIVIL ACTION -LAW Defendant : IN DIVORCE VERIFICATION I, Ava M. Glavas, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Dated: , 2006 kd' es? Ava M. Glavas S u • C! c ?m ?.a i Vd N a C? w cn C? C?J AVA M. GLAVAS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-4595 DANIJEL GLAVAS, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO RE-INSTATE TO THE PROTHONOTARY: Please re-instate the Complaint filed in the above-captioned matter. Dated: September ek% , 2006 va M. Glavas, Pro e 527 North Second Street Wormleysburg, PA 17043 "*7f 1 co ) ?a _ ? ?;? CTS W\. CnV),vc?S -P?L?"A-A ?? ?\\) vs. / 1/' C Cc-A In the Court of Common Pleas of Cumberland County, Pennsylvania No. OU _y 5 GtfE? Civil. 19 V AttaamT for Plaintiff No. Term, 19 vs. PRAECIPE Filed 19 Atty. -?j AVA M. GLAVAS, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plainitff, NO: 06-4595 V. CIVIL ACTION -LAW IN DIVORCE DANIJEL GLAVAS, Defendant. PRAECIPE TO RE-INSTATE TO THE PROTHONOTARY: Please re-instate the Complaint filed in the above-captioned matter. Dated: May _G_, 2008 ,fit# ?469 V a M. Glavas, Pro Se 527 North Second Street Wormleysburg, PA 17043 0 ci? T? c