The URL can be used to link to this page

Home My WebLink About06-4925 , Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DAVID E. LEVASSEUR. v . ; NO.2006- 49). ~ C.lut I hI"'" CARRIE PRZELSKI, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO PLEAD 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 (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 fan 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. 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, Pennsylvania 717-249-3166 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.2006- '-/ q :2- ') DAVID E. LEVASSEUR, v Defendant : CIVIL AcrION - LAW : IN DIVORCE CARRIE PRZELSKI, COMPLAINT Plaintiff, David E. Levasseur, by his attorneys, Broujos & Gilroy, P.C., sets forth the fonowing: 1 Plaintiff, David E. Levasseur, is an adult individual who maintains 745 Dogwood Terrace as his legal residence, Bolling Springs, Cumberland County, Pennsylvania. 2 Defendant, Carrie Przelski, is an adult individual who maintains 573 Main Street as her legal residence, Cold Brook, New York. 3 Plaintiff and Defendant were married in Lawton, Oklahoma on December 3, 2001. 4 Plaintiff has continuously maintained a legal residence in the Commonwealth of Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of this action. 5 There have been no prior actions of divorce or for annulment between the parties. 6 The marriage is irretrievably broken. WHEREFORE, tbe Plaintiff requests your Honorable Court to enter a decree divorcing bim from the Defendant BROUJOS & GILROY, P.C. VERIFICATION I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. W{'L DAVID E. LEVASSEUR (') ~ 0 "'" c = -n ~ _e C" -4 < ,,"P :~~,,:': :r: ~ - c:: rnpl '\ -.l:\ z::r. en -om t> fi, ~~~: N :o? c..:> ':I _....' ':..~~J - ~ ~r:, -0 ";r:.-H oq, ~ J;..' . :J' ::40 ;:::.t.J Ben V " "'- 5c: ~: ~--l ~ Z ~ -'3 (Jl C> ~- ..,- -l::... } , I \ \ \ ;\ .,l \. 00 ~ c!, c VI '" q'> ~ d "<. -.;;, , r DAVID E. LEVASSEUR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 2006-4925 CIVIL ACTION-LAW CARRIE PRZELSKI, Defendant : IN DIVORCE ACKNOWLEDGMffiNT OF SERVICE I, CARRIE PRZELSKI, Defendant in the above divorce action, hereby acknowledge receipt and service of the Complaint in Divorce filed in the above matter along with the Notice to Plead on September \5 , 2006. \1:5 S~, $2)(, DATE c~2~~ floW€. tJt1('~ ~~"tllrGI) ^l>f)Il.~ '. C?T C,trA.<tlE ?4.~c.:. "\ CIIl'll "'I c, ". ~~)(' 'i (~ Irpo ( A~ 0QZ.2.f.- o ~ ;:r~ ~i, '~"? .- "7( (.tJ t r~i:' '.<~.,.~ !:'; (= '::'---"-" I....~. ' >.c: -;.- =2 f'--) = = <;;T" (/) r<i -0 N C7'\ o -n -' ft,F! -om 'nQ (.~ C) ":"'1"1 :I. ",1 i;;~o ;::;5 In "-4 5J ~ -0 :x N .. DAVID E. LEVASSEUR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 2006-4925 CIVIL ACTION-LAW CARRIE PRZELSKI, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on August 23, 2006. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about September 15, 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 of 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. ~4904 relating to unsworn falsification to authorities. Date: ~ "D~(. 9Sc- r''''' c::=> cO:::;> C"... d \-n c-; f'.) -r.; Cl -11 .-\ :c.... n'E '-CJ l._:.,~ -'.1}\...(' }lS,'; .,:? (":, ~~~ ("; ~ 'b :-<. -",.,~ !,',,.. (:? ,~. ' ",. , DAVID E. LEVASSEUR, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 2006-4925 CNIL ACTION-LAW CARRIE PRZELSKI, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was fIled on August 23, 2006. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about September 15, 2006. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the f'iling of the Complaint. 4. I consent to the entry of a f'mal decree of 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. ~904 relating to unsworn falsification to authorities. Date: ~~ 'fr(l) 7 ~/} 1 &~'; .' I ,'. i, . {let} ~ David E. Levasseur, Plaintiff r--..'l = C;::. --.J -r; rr-, c;o I -..J o 11 :::211 i11f-= -Orn ~.(J t-:' r"") 1 ~1j ~~~~: :;3~ ---l ?O -< CJ1 N 'd F:\FILESIDATAFILE\GeneraIlCurrent\12382\Levasseur Praecipe to Transmit Reeord.wpd Created: 9/20/04 0:06PM Revised: 2/6107 10:44AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES J.D. 29943 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff DAVID E. LEVASSEUR, Plaintiff IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYL VANIA v. NO. 2006-4925 CIVIL ACTION - LAW CARRIE PRZELSKI, Defendant 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 (X)3301(c) 03301(d)(I) of the Divorce Code. 2. Date and manner of service of the Complaint: September 15, 2006 by First Class Certified Mail, Return Receipt Requested. 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: February 4, 2007; by Defendant: December 8, 2006. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: __2) Date of service of the Plaintiff's affidavit upon the Defendant: 4. Related claims pending: None. 5. Complete either (a) (b). r (a) Date and ~nner of service of ths notics of intention to fils praecips to transmit record, a COpy Of Which is attachsd, Yebruary 6, 2007. (h) Date PISintiff's Wai?er of Notice was filed With the Prothonotary, Febraury 6, 2007. (h) Date Defendant.s Wai?er of Notice Was filed with the Prothonotary, December 21, 2006. DATE: February 6, 2007 oy, Esquire Plaintiff dorff Williams Otto Gilroy & Offices Street 17013 o C' t-' = C::;,) __J -T1 r"f"t co I --I - - (J1 0.; - 'f ;+. 'f 'f", ~ ~ ~ ~~ ~~ ~~ ~ ~~~~ ~ ~ ~~ ~~~ ~~~~~~ ~~~ ~ ~~~ ~~~ ~~~ ~~~'f~'f'f~ 'f IN THE COURT OF COMMON PLEAS ~ OFCUMBERLANDCOUNTY STATE OF PENNA. DAVID E. LEVASSEUR Plaintiff No. 2006-4925 VERSUS CARRIE PRZELSKI Defendant DECREE IN DIVORCE AND NOW, f e..~>t ~ o..~ 't l()()) , IT IS ORDERED AND \:) DECREED THAT DAVID E. LEVASSEUR , PLAI NTI FF, CARRIE PRZELSKI AND , 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; None of Record. ~ ~ ~ ~ ~ ~ 'f ~ 'f ;+. ~ ;+. 'f ~ ~ 'f ;+. ~ ;+. ~ ;+. ~ 'f :f.[of.:of.:f.:f. =+::f.:+;?' BY~\U~\ ATT E 5';' /f,..~~ J. C --~~ PROTHONOTARY ~ ~~~~~~'f~ 'f ~~~ ~ 'f~'f~ ~ 'f ~ 'f~~'f'f'f'f'f 'f~ 'f'f~ 'f'f'f'f'f'f'f~'f'f ~~~'f'f 'f 'f ~ 'f 'f ~ ~ 'f ~ 'f ~ ~ 'f ~ ~ ~ ~ ~ ~ 'f ~ ~ ~ 'f ~ 'f 'f 'f ~ 'f ~ ;+. ;+. ;+. ~ ,;:fit; ~ ~ ~~ ((/.~. e 4.,yr -it' t~ NP;; -.;:w LO' r1' (;' . .' ..