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Home My WebLink About02-2749ANDREA L. KOVACH, Plaintiff LAWRENCE V. KOVACH, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. : : 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 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 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 Courthouse, Carlisle, Pennsylvania. 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, PA 17013 (717) 249-3166 ANDREA L. KOVACH, : Plaintiff : : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. t2~2-~27t/~ LAWRENCE V. KOVACH, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Andrea L. Kovach, by and through her counsel, Killian & Gephart, who represents as follows: 1. Plaintiff, ANDREA L. KOVACH, is an adult individual, who currently resides at 2198 Gleim Court, Enola, Cumberland County, Pennsylvania. Her date of birth is January 31, 1971, and her Social Security Number is 202-46-5829. 2. Defendant, LAWRENCE V. KOVACH, is an adult individual who currently resides at 2501 South Fourth Street, Steelton, Dauphin County, Pennsylvania. His date of birth is June 11, 1960, and his Social Security Number is 165-56-0964. 3. Plaintiff avers that she has been a bonafide resident in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 4, 1992, in Harrisburg, Pennsylvania. o namely: 6. Plaintiff avers that there is one child of the parties under the age of 18, COURTNEY PAIGE KOVACH. 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. 7. There have been no other prior actions of divorce or annulment filed by either of the parties hereto. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant. Dated: Respectfully submitted, KILLIAN & GEPHART (717) 232-1851 Attorney I.D. #53148 Attomeys for Plaintiff VERIFICATION I hereby verify that the statements of fact made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subj eot to the penalties contained in 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. ANDREA L. KOVACH, Plaintiff Vo LAWRENCE V. KOVACH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2749 Civil Term CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(e~ OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. ° 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. 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 tree 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. Dated: November 4, 2002 ANDREA L. KOVACH, · IN THE COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 02-2749 Civil Term LAWRENCE V. KOVACH, · CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 5, 2002. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Com- plaint. 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.A. Section 4904 relating to unsworn falsification to authorities. Dated: November 4, 2002 ANDREA L. KOVACH, Plaintiff go LAWRENCE V. KOVACH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2749 Civil Term CIVIL ACTION - LAW IN DIVORCE 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. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. o 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.A. Section 4904 relating to unsworn falsification to authorities. Dated: October 18, 2002 ea L. Kovach ANDREA L. KOVACH, Plaintiff LAWRENCE V. KOVACH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2749 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 5, 2002. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Com- plaint. 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.A. Section 4904 relating to unsworn falsification to authorities. Dated: October 18, 2002 Andrea L. Kovach ANDREA L. KOVACH, · IN THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COI_FNTY, PENNSYLVANIA v. : NO. 02-2749 Civil Temx LAWRENCE V. KOVACH, : CIVIL ACTION - LAW Defendant · IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, LAWRENCE V. KOVACH, Defendant herein, do hereby swear and affirm that I accepted service of a tree and correct copy of the Complaint in Divorce on: ~//6]/"/C 7 ,2002. ANDREA L. KOVACH, · IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02-2749 Civil Term : LAWRENCE V. KOVACH, : CIVIL ACTION - LAW Defendant · IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following infi)rmation, 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 of service of the Complaint: June 7, 20(}2, as evidenced by the Affidavit of Acceptance of Service, which is being filed contemporaneously herewith. 3. Date of execution of the Affidavits of Consent required by Section 3301 (c) of the Divorce Code: by ANDREA L. KOVACH, Plaintiff, on October 18, 2002; by LAWRENCE V. KOVACH, Defendant, on November 4, 2(}02; which are being filed contemporaneously herewith. 5. Date of execution of Waivers of Notice of Intention to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code: by AiNDREA L. KOVACH, Plaintiff, on October 18, 2002; by LAWRENCE V. KOVACH, Defendant, on November 4, 2002; which are being filed contemporaneously herewith. Dated: November 5, 2002 Respectfully submitted, 218 Pine Street P. O. Box 886 Harrisburg, PA 17108 (717) 232-.1851 Attorney I. D. #53148 Attomeys for Plaintiff CERTIFICATE OF SERVICE I do certify that I served a tree and correct copy of'the within Praecipe to Transmit Record, and related documents, upon the following by depositing a copy of same in the United States mail, postage prepaid, addressed as follows: Mr. Lawrence V. Kovach 2501 South Fourth Street Steelton, PA 17113 Dated: Peggy Hile,"'~ecretary to J. PAUL HELVY, ESQ. Killian & Gephart, LLP 218 Pine Street P. O. Box 886 Harrisburg,, PA 17108-0886 (717) 232-11851 ANDREA L. KOVACH, VERSUS LAWRENCE V. KOVACH, Defendant IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. Plaintiff NO. 02-2749 Civil Term AND NOW, DECREED THAT AND Decree IN DIVORCE NOVEMBER I~' ,2002 ANDREA L. KOVACH LAWRENCE V. KOVACH , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOI.LOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD IN THiS ACTION FOR WhiCH A FINAL ORDER HAS NOT YEt BEEN ENTERED; NONE. ATTEST:~ Jo PROTHONOTARY