HomeMy WebLinkAbout06-6856Lindsay Gingrich Maclay, Esquire
Daley, Zucker & Gingrich
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Lmaclay@dzelaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TRESSIA M. PANKEWICZ
Plaintiff
V.
JOSEPH C. PANKEWICZ
Defendant
No. 2006 - (o f
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
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 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, High and Hanover Street, 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
DALEY, ZUCKER & GINGRICH, LLC
Date: 11 12A 10 (p By: I Ju4tn- lby"2>
Outprerne ay Gin r' M ay, Esq e
Co ID
# 7954
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Attorneys for Plaintiff
Lindsay Gingrich Maclay, Esquire
Daley, Zucker & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Lmaclay@dzglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TRESSIA PANKEWICZ, _ wlls?
Plaintiff No. I (Civil Term)
V.
CIVIL ACTION - LAW
JOSEPH C. PANKEWICZ,
Defendant IN DIVORCE
COMPLAINT UNDER & 3301(a)(6) OR & 3301(c) OR & 3301(d)
OF THE DIVORCE CODE
COUNT I DIVORCE
1. Plaintiff is Tressia Pankewicz, an adult individual who currently resides at 812
Pamelas Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Joseph C. Pankewicz, an adult individual who currently resides at
121 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Plaintiff and Defendant have been a bona fide resident(s) in the Commonwealth
for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on May 20, 1995 in Camp Hill, Cumberland
County, Pennsylvania.
5. The parties separated on or about November 11, 2006.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Plaintiff has been advised of the availability of marriage counseling and that the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling. Having been so advised, Plaintiff does not desire The Court to order counseling.
See Plaintiffs Affidavit attached hereto as Exhibit "A" and incorporated herein by reference.
8. Neither Plaintiff or Defendant is a member of the Armed Services of the United
States or any of its Allies.
9. The cause(s) of action and section(s) of Divorce Code under which Plaintiff is
proceeding are:
A. Section 3301(c). The marriage of the parties is irretrievably broken. After
ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to
file and Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an
Affidavit.
B. Section 3301(d). The marriage of the parties is irretrievably broken. The
Plaintiff and Defendant separated on or about November 11, 2006.
10. The parties may enter into a written agreement with regard to support, custody,
visitation of children, alimony and property division. In the event that such an agreement is
executed by the parties, Plaintiff desires that the agreement be approved by the Court and that
said agreement be incorporated, but not merged, in any Divorce Decree which may be entered
dissolving the marriage between the parties.
WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce,
divorcing Plaintiff and Defendant from the bonds of matrimony.
COUNT II
EQUITABLE DISTRIBUTION
11. Paragraphs 1 through 10 of this Complaint are incorporated herein by reference as
though set forth in full.
12. Plaintiff and Defendant have acquired property, both real and personal, during
their marriage which are subject to equitable distribution by the Court.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all
martial property.
COUNT III
ALIMONY
13. Paragraphs 1 through 12 of the Complaint are incorporated herein by reference as
though set forth in full.
14. Plaintiff has no adequate means of support for herself and is unable to support
herself through appropriate employment.
15. Plaintiff requires reasonable support to adequately maintain herself in accordance
with the standard of living established during the marriage.
WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony in
her favor.
COUNT IV
ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES
16. Paragraphs 1 through 15 of the Complaint are incorporated herein by reference as
though set forth in full.
17. Plaintiff lacks sufficient funds to support herself and pay Counsel fees and
expenses incidental to this action.
18. Defendant is full well and able to pay Plaintiff Alimony, Alimony Pendente Lite,
counsel fees and expenses incidental to this divorce action.
WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony
Pendente Lite, Plaintiff's counsel fees and the costs of this proceeding.
Respectfully submitted,
DALEY, ZUCKER & GINGRICH, LLC
DATE: 1112410 ? By:
hn 4Gih M lay, Esquire
. # 8795 4
1029 Scenery Drive
Harrisburg, Pennsylvania 17109
(717) 657-4795
Attorneys for Plaintiff
VERIFICATION
I, Tressia Pankewicz, 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.S §
4904, relating to unsworn falsification to authorities.
/ ressia kanlCewicz, P intiff
Dated: J 1121'11710
AFFIDAVIT
I, Tressia Pankewicz, being duly sworn according to law, depose and say:
(1) 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
Prothonotary's Office, which list is available to me upon request.
(3) Being so advised, I do not request 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.
Section 4904 relating to unsworn falsification to authorities.
Dated:
ressia Pank cz, Pla' tiff
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Lindsay Gingrich Maclay, Esquire
Daley, Zucker & Gingrich, LLC
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Imaclaya-dzglaw.com
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TRESSIA PANKEWICZ,
Plaintiff No. 2006-6856
V. CIVIL ACTION - LAW
JOSEPH C. PANKEWICZ,
Defendant (In Divorce)
ACCEPTANCE OF SERVICE
I, Joseph C. Pankewicz, Defendant in the above-captioned matter, hereby accept service of
the Complaint in Divorce, which was filed on November 30, 2006.
Dated: G d G
By: 0/
seph . Pankewicz, Defendant
Pro Se
121 Stanford Court
Mechanicsburg, Pennsylvania 17050
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT made and entered into this 18'h day of July, 2007 (year),
between Tressia M Pankewicz (Wife) residing at 812 Pamelas Lane. Mechanicsburg.
Pennsylvania 17050 and Joseph C Pankewicz (Husband) residing at 10171 Jonestown
Rd. Grantville. Pennsylvania 17028.
WHEREAS, Husband and Wife were married to each other on May-20,
1995(year) at Cam Hill. Pennsylvania.
WHEREAS, a permanent breakdown of the marriage has arisen between us and
we are now living separate and apart from each other, and
WHEREAS, children were born into our marriage as follows:
Child's Name
Lillian M Pankewicz
Nicholas J Pankewicz
Child's Birth Date
10/24/1996
01 /30/2002.
Child's Sex
Female
Male
(herein after "Children") and it is the further purpose of this Agreement to provide for the
future custody, control and support of said Children, and
WHEREAS, it is the desires and intentions of the parties to settle by agreement all
of the marital affairs with respect to property, financial matters and all issues relating to
their Children, including custody, visitation, and child support.
NOW, THEREFORE, in consideration of the premises and the mutual promises
and undertakings herein contained, and for other good and valuable consideration, the
parties agree to the following:
I. SEPARATION:
The parties agree to permanently live separate and apart from the other party, free
from any control, restraint, direct or indirect, by the other party, and in all respects to live
as if he or she were sole or unmarried.
II. DIVISION OF PROPERTY
1. Husband transfers to Wife as her sole and separate property the following:
1. 2000 Nissan Altima X
2. The property of 812 Pamelas Lane, Mechanicsburg, PA 17050.
3. All furniture, furnishings, household goods located at: 812 Pamelas Lane,
Mechanicsburg, PA 17050.
4. Wife's company savings which is valued at $ 35,000.
5. Wife's pension.
III. DIVISION OF DEBTS:
1. Wife shall pay the following debts and will not at any time hold Husband
responsible for them, and shall indemnify Husband from any liability on same:
1. Chase Auto account No. 10423209514407
IV. ALIMONY
1. Both parties hereby agree to waive any rights or claims that either may now have
or in the future to receive alimony, maintenance, or spousal support from each
other. Both parties understand the full import of this provision.
V. CHILD CUSTODY AND VISITATION
1) The parties shall have joint legal custody of the Children. Joint legal custody
means the right of both parents to control and to share in making decisions of importance in
the life of their Children, including educational, medical, and religious decisions. Each
parent shall have an equal right, to be exercised jointly with the other parent, to make all
major non emergency decisions affecting the Children's general well-being, including, but
not limited to, all decisions regarding their health, education and religion. The custodial
parent shall inform the non-custodial parent immediately of all medical and dental
appointments and problems pertaining to the Children. If the Children are sick and are
unable to attend school or other planned activities, the parent then having custody will
notify the other parent as soon as practicably possible. Each parent shall notify the other
parent of any medical, dental, optical, counseling and other appointments of the Children
with health care providers, sufficiently in advance thereof so that the other party can attend,
if he or she so chooses.
Pursuant to the terms of Pa.C.S. 5309, each parent shall be entitled to equal
access to all records and information pertaining to the Children, including, but not limited
to, the Children's school, medical, dentist, religious and other important records, the
residence address of the Children and the other parent. As soon as practical after the
receipt by a party, copies of the Children's school schedule, special events notifications,
reports cards, and similar items shall be provided to the other party. To the extent one (1)
parent has possession of any such records or information, that parent shall be required to
share same, or copies thereof, with the other parent within such reasonable time as to
make the records or information of reasonable use to the other parent. The custodial
parent shall provide copies of the Children's report cards and other reasonable papers
affecting the Children's education, medical condition or welfare.
Notwithstanding that both parents shall share legal custody, non-major decisions
involving the Children's day-to-day living shall be made by the parent then having
custody, consistent with the other provisions of this Stipulation.
2) Physical custody of the Children, as that term is defined in the Custody
Act, shall be primarily with the Mother, subject to Father's periods of partial custody at
such times as set forth below. Father shall have custody of the Children every other
weekend from Friday at 3:30 p.m. through Sunday at 6:00 p.m. Father's first weekend of
partial custody shall be December 1, 2006. Father shall also have custody of the Children
every Wednesday from 3:30 p.m. through 7:00 p.m. Father's periods of custody on
Wednesdays shall commence on November 30, 2006.
3) Transportation for custody purposes shall be divided by the parties as
equally as possible. The parent who is to receive custody at the time of the exchange is
to provide for transportation from the residence of the other parent. At all times, the
Children shall be secured in appropriate passenger restraints. No person transporting the
Children shall be under the influence of any alcoholic beverages while transporting the
Children.
4) The holiday schedule shall be at such times as the parties may agree.
s) Each party shall be entitled to two (2) weeks of uninterrupted vacation
time with the Children. For purposes of this Order, one (1) week shall be defined as nine
(9) consecutive days, which shall include the parties' regularly scheduled weekend of
custody. The party wishing to take a vacation with the Children shall provide the other
party with at least thirty (30) days advance written notice of their intention to utilize the
week of vacation. If both parties intend to utilize the same day or days, the first party
giving notice to the other party will be afforded their designated days.
6) In the event that either parent, during their respective scheduled periods of
custody, would need to leave the Children for a period of at least two (2) hours with a
non- family member, the custodial parent will first check with the non-custodial parent to
ascertain if the non custodial parent is available to watch the Children. In the event that
neither parent is able to watch the Children, the custodial parent will then be responsible
for obtaining the appropriate supervision for the Children.
7) In the event that either parry is more than thirty (30) minutes late of a
custody exchange, in the absence of a telephone call or other communication from the
parent transporting the Children, the other party may assume that the parent who is late
has chosen not to exercise that period of custody, the period will be forfeited, and the
other party will be free to make other plans with the Children.
8) To the extent possible, each party shall provide the other with at least
forty-eight (48) hours advance notice of school, sporting, or other extracurricular
activities. Both parties shall agree to honor and participate in the activities that the
Children wish to engage in. During the times that each of the parents has custody of the
Children, they will make certain that the Children attends any previously-scheduled
extracurricular activities. The parties are directed to be supportive of the activities and
will transport the Children to and from such activities and the preparations and practice
for the activities that are scheduled, in such times so that the Children are able to
participate in those events.
Neither parent, however, shall commit the Children to any activity unless the
Children definitely desire to attend that activity. Participation in activities which take
place during the school year is contingent upon the Children maintaining passing grades
in school.
Neither parent shall commit the Children to activities that fall on the other parent's
period of custody, without the consent of the other parent, which consent shall not be
unreasonably withheld. If the Children are involved in an activity which occurs curing
both parents' periods of custody, both parents shall cooperate in providing transportation
of the Children to the activity. However, the then-custodial parent shall not be required
to take the Children to that activity if the custodial parent and Children are out of town
during that activity, for a previously-schedules vacation.
In the event that the custodial parent is unable to deliver the Children to the
particular activity, the parent who has custody of the Children at that time shall notify the
non-custodial parent, who shall be entitled to pick up and deliver the Children to the
designated activity. The custodial parent shall make certain that the Children are ready
for pick-up in time sufficient to enable the Children to timely attend the activity.
Should the custodial parent elect not to take the Children to a defined activity
period for two (2) times, then the non-custodial parent shall have the right to assume that
he or she will be responsible for transporting the Children to that activity until
appropriate transportation is provided.
9) In the event that any of the Children are unable to attend school due to
illness or school closings or delays due to weather, etc., it is the responsibility of the
parent then having custody to arrange alternate care for that day and to notify the non-
custodial parent of the Children's illness.
10) In the event that either party is planning to take the Children out of this
Court's jurisdiction for an overnight trip, they must provide ten (10) days' advance
written notice and contact information for the locations at which the Children will be
staying.
11) Both parties are expected to use common sense in scheduling telephone
calls to talk to the Children. Both parties and/or their spousestsignificant others are herby
directed to refrain from preventing the parent who may be calling from talking to the
children, or preventing the Children from calling the other parent, provided that the
phone calls are not excessively frequent nor too long in duration that they disrupt the
Children's schedule, or interfere with the custodial parent's period of custody.
12) Each of the parties and any third party in the presence of the Children shall
take all measures deemed advisable to foster a feeling of affection between the Children
and the other party. Neither party shall do nor shall either parent permit any third person
to do or say anything which may estrange the Children from the other parent, their spouse
or relatives, or injure the Children's opinion of the other party or which may hamper the
free and natural development of the Children's love, affection and respect for the other
parent.
The parties shall not use the Children to convey verbal messages to the other
parent about custody situation or changes in the custody schedule.
13) In the event that a significant matter arises with respect to the medical,
education, or financial care of the Children such as a change in occupation, health
insurance, educational expenses, or residence of a party, those matters shall be discussed
with the other party before any change is made by either parent.
14) Each party shall confer with the other on all matters of importance
relating to the Children's health, maintenance, and education with a view towards
obtaining and following a harmonious policy in the Children's education and social
adjustments. Each party agrees to keep the other informed of his or her residence and
telephone number to facilitate communication concerning the welfare of the Children and
the custody situation. Each party shall supply the name, address, and phone numbers of
any persons in whose care the Children will be in for a period in excess of seventy-two
(72) hours, and for each person or entity which may provide daycare for the Children,
excluding current daycare providers, relatives, or public school institutions.
15) Emergency decisions regarding the Children shall be made by the parent
then having custody. However, in the event of any emergency or serious illness of the
Children at any time, any party then having custody of the Children shall immediately
communicate with the other party by telephone or any other means practical, informing
the other party of the nature of the illness or emergency, so the other parent can become
involved in the decision-making process as soon as practical.
The term "serious illness" as used herein shall mean any disability which confines
any of the Children to bed for a period in excess of seventy-two (72) hours and which
places the Children under the direction of a licensed physician.
16) The welfare and convenience of the children shall be the prime
consideration of the parties in any application of the provisions of the Stipulation and
Agreement. Both parents are directed to listen carefully and consider the wishes of the
Children in addressing the custodial schedule, any changes to the schedule, and any other
parenting issues.
17) The parties are free to modify the terms of this Stipulation and
Agreement, but in order to do so; the parties must be in complete agreement to any new
terms.
18) The parties agree to cooperate with one another in an effort to foster a
loving, meaningful relationship between the Children and each parent.
19) Any major, long-term modifications of this Stipulation and Agreement
need to be in writing, agreed to by both parties, and executed with the same formalities as
this Stipulation. Minor, short-term changes can be made orally, if agree upon by both
parties. In the even that either party is not in agreement with a purposed change, this
Stipulation and Agreement will control the custodial arrangement until such time as the
parties are able to agree.
20) This Stipulation, Agreement and/or Order supercedes all previous custody
Agreements and/or Orders.
21) In the event that either party breaches any provision of this Order, he or
she shall be responsible for any and all costs incurred to enforce the Order, including, but
not limited to, court cost and counsel fees of the other party. In the event of breach, the
other party shall have the right, at his or her election; to sue for damages for such breach
or to seek other and additional remedies as may be available to him or her.
VI. CHILD SUPPORT:
Subject to the power of the court to modify these terms, Husband shall pay to
Wife as and for child support, the sum of $1000 per month This sum shall be payable
in the amount of $250.00 on the Friday of each and every week commencing on March 1,
2007. Said sum shall continue until the Children shall have married, died, become self
supporting, or graduated from high school. Furthermore, if the parent obligated to pay
said support receives an increase in salary or income in the future, the amount of child
support shall increase proportionately. Said sum shall be reduced by $500 (or shall be
reduced proportionately) for each child to graduate from high school or otherwise
emancipated.
The parties agree that the Children should attempt to exhaust all avenues for
financial aid to enter into a college/university. After which time, each party agrees to
assist with expenses and financial responsibilities over and above aid that is received
from student grants, scholarships, or loans, in proportionate amounts, based on their
salaries.
The parties agree that the Husband will carry and maintain life insurance naming
the children as irrevocable beneficiaries. Said life insurance is in the amount of $ 250,000.
Furthermore, it is agreed that the Wife will carry and maintain adequate health,
dental, and hospitalization insurance of the Children's benefit.
VII. NECESSARY DOCUMENTS
The parties agree to execute and deliver to the other party any documents that may
be reasonably required to accomplish the intention of this instrument and shall do all other
necessary things to this end.
VIII. INCOME TAX
For the year 2007 the parties hereto shall file separate income tax returns. Each
party hereto shall receive the refund or pay additional taxes based on his or her separate
income.
The parties agree that the Wife may claim the federal dependency tax exemption for
the Children.
IX. SUBSEQUENT DISSOLUTION OF MARRIAGE
It is agreed that this Agreement may be offered into evidence by either party in any
dissolution of marriage proceeding, and if acceptable to the Court, this Agreement shall be
incorporated in the Final Judgment, this Agreement shall not be merged in it but shall
survive the Final Judgment and be binding on the parties for all times.
X. REPRESENTATION
The parties represent to each other.
(a) Each had the right to independent counsel. Each party fully understands
their legal rights and each is signing this Agreement freely and voluntarily,
intending to be bound by it.
(b) Each has made full disclosure to the other of his or her financial condition.
(c) Each understands and agrees that this Agreement is intended to be the full
and entire contract of the parties.
(d) Each agrees that this Agreement and each provision of it is expressly made
binding upon the heirs, assigns, executors, administrators, successors in
interest and representative of each party.
XI. WAIVER OF BREACH:
No waiver of any breach by any party of the terms of this Agreement shall be
deemed a waiver of any subsequent breach.
XII. ENFORCEMENT OF AGREEMENT:
Both parties agree that the Court granting the divorce, at the request of either party,
insert in the Final Judgment a reservation of jurisdiction for the purpose of compelling
either party to perform this Agreement, or any part thereof. The prevailing party shall be
entitled to attorney's fees in connection with such proceedings.
XIII. GOVERNING LAW:
This Agreement shall be interpreted and governed by the laws of the State of
Pennsylvania.
in the presence of:
nark `
ife's ig ure
3es for Wife
in the presence of
usbanI Signature
State of Pennsylvania
County of Cumberland
On ]before me, 02 Hwkak-'. personally
appeared Tressia M. Pankewicz and Joseph C. Pankewicz, personally proved to me on the
basis of satisfactory evidence to be the person(s) whose name(s) are subscribed to the
within instrument and acknowledged to me that they executed the same in their authorized
capacities, and that by their signatures on the instrument the person(s), or the entity upon
behalf of which the person(s) acted, executed the instrument.
WITNESS my hand and official seal.
Signature
Signature of Notary
M
LCHARRLES !:AR ?OF PENNSYLVANIA
IAL SEAL
8OLD, Notary public
Cumberland County
pires Dec, 3p, 2010
Aunt Known Croduced ID.
Type of ID DRW&1- doS?
(Seal)
IF A NONLAWYER HELPED YOU FILL OUT THIS FORM THEY MUST FILL
IN THE BLANKS BELOW (fill in all blanks):
(city)
helped
nonlawyer located at (street)
(state) , (phone)
who is the [ one only] petitioner or responder,
fill out this form.
TRESSIA M. PANKEWICZ,
Plaintiff
V.
JOSEPH C. PANKEWICZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-6856
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Joseph C. Pankewicz, Defendant in the above-captioned matter, do
hereby accept service of the Complaint in Divorce filed on November 30, 2006.
Date: -'--
Joseph C. Pankewicz
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TRESSIA M. PANKEWICZ,
Plaintiff
V.
JOSEPH C. PANKEWICZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-6856
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(c) OF THE DIVORCE CODE
1. A Complaint in divorce under § 3301 (c) of the Divorce Code was filed on
November 30, 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 without formal notice of the
intention to request entry of a divorce decree.
4. 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 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. Cons.
Stat. § 4904, relating to unsworn falsification to authorities.
Date: 7
Joseph C. Pankewicz
r~ 6?=d a a
TRESSIA M. PANKEWICZ,
Plaintiff
V.
JOSEPH C. PANKEWICZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2006-6856
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.
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. Cons.
Stat. § 4904, relating to unworn falsification to authorities.
<
Date: d ~ j r
oseph C. Pankewicz
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TRESSIA M. PANKEWICZ,
Plaintiff
V.
JOSEPH C. PANKEWICZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-6856
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER 3301(c) OF THE DIVORCE CODE
1. A Complaint in divorce under § 3301 (c) of the Divorce Code was filed on
November 30, 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 without formal notice of the
intention to request entry of a divorce decree.
4. 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 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. Cons.
Stat. § 4904, relating to unsworn falsification to authorities.
Date:2/jv/07-
/'Tie-ssia ewicz dlo;?o,
TRESSIA M. PANKEWICZ,
Plaintiff
V.
JOSEPH C. PANKEWICZ,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-6856
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.
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. Cons.
Stat. § 4904, relating to unsworn falsification to authorities.
Date: U7 8 d
ressia M. icz
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TRESSIA M. PANKEWICZ,
Plaintiff
vs.
JOSEPH C. PANKEWICZ,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-6856
CIVIL ACTION - LAW
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 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Acceptance of Service
attached hereto as part of the record.
3. Date of execution of the affidavit of consent required by 3301(c) of the
Divorce Code: by Plaintiff 7-28-07 ; by Defendant 7-28-07
4. Related claims pending: NONE
5. Date Plaintiff s Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary: 8-24-07 ; by Defendant 8-24-07
Respectfully submitted,
Date:
Mindy S. Goodman, Esquire
I.D. No. 78407
2215 Forest Hills Drive - Suite 35
Harrisburg, PA 17112
(717) 540-8742
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Alft
STATE OF PENNA.
x
TRESSIA M. PANKEWICZ,
Plaintiff
No. 2004-6856
VERSUS
JOSEPH C. PANKEWICZ,
Defendant
DECREE IN
DIVORCE
IT IS ORDERED AND
AND NOW, A?JQJST ?? , _106
DECREED THAT TRESSIA M. PANKEWICZ , PLAINTIFF,
AND
JOSEPH C. PANKEWICZ
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
,DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
A Marital Settlement Agreement executed by the parties is
incorporated herein but shall not-merge.
BY THE COURT:
ATTEST:
PROTHONOTARY
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