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Home My WebLink About02-3514DENISE PIASTRELLI-KOCAN, Plaintiff MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0h' 3J-;~ CIVIL TERM : 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 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 Courthouse, Carlisle, PA 17013. 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 Telephone: (717) 249-3166 fl\div\PIASTRELLI-com DENISE PIASTRELLI-KOCAN, Plaintiff Vo MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON : CUMBERLAND COUNTY, CIVIL ACTION - LAW IN DIVORCE PLEAS OF PENNSYLVANIA COMPLAINT 1. The Plaintiff in this action is DENISE PIASTRELLI-KOCAN, an adult individual, who currently resides at 607 Harding Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant in this action is MARK EDWARD KOCAN, an adult individual, who currently resides at 517 Eighth Street, New Cumber- land, Cumberland County, Pennsylvania 17070. 3. Both the Plaintiff and the Defendant residents of the Commonwealth of Pennsylvania have been bona fide for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on June 28, 1986, in Cambria County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -1- based is broken. 7. marriage. The Plaintiff avers as the grounds upon which this action is that the marriage between the parties hereto is irretrievably The Plaintiff avers that one child has been born of this 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the require 9. vorce. right to request that the court the parties to participate in counseling. The Plaintiff requests the court to enter a decree of di- I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject of 18 P.C.S. ~4904, relating to unsworn falsification to the penalties to authorities. DENISE ~pIA~R~ELLI K~CAN Date: STONE LaFA~E/&,SHEKLETSKI BYEL~ETH~./~TONE Supren~ou/Ft ID #60251 414~ ydg~Street, P.O. Box E N~I ~b/rland, PA 17070 /~el~ o~e 717-774-7435 /_2_Att~ ~ys for Plaintiff fl\div\lmailsrv.aff DENISE PIASTRELLI-KOCAN, Plaintiff Vo MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3514 CIVIL TERM : · CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVIC~ COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Mark Edward Kocan, at 517 Eighth Street, New Cumberland, Pennsylvania 17070, by United States Certified Mail, postage prepaid, restricted delivery, on July 27, 2002, as evidenced by the attached Certified Mail return re- ceipts. / SWORN TO AND SUBSC.,R~BED befor~me_this ~D~day of ~ , 2002. Not~y Publ{c ' ~- lly" ' NOTARIAL SEAL NEI~ Clgl~ERL~I) P~ ~7070 Certified Fee R~m R~I~ F~ t[.75 Name (Pleaae Print Clearly) (To be oompletml by ........................................... I~ ~ ~";~'° e= t~' /~ ~ ~[~ s~'~ ....... ~ ...... r~;~,'~;'~:,'; ........................................ fl\div\lconsentaffidavit DENISE PIASTRELLI-KOCAN, Plaintiff V. MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3514 CIVIL ACTION : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 24, 2002, and served July 27, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. I understand that I may lose righ~zs 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. C.S. ~ 4904 relating to unsworn falsifica- tion to authorities. Date DENISE PI~STRELLI-KOCAN, Plaintiff fl\div\lwaivernotice DENISE PIASTRELLI-KOCAN, Plaintiff Vo MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3514 CIVIL ACTION : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c} OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without 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. C.S. ~ 4904 relating to unsworn falsifica- tion to authorities. Z -2_& -o3 Date DENISE ~ASTRELLI-KOCAN, Plaintiff C'~ o fl\div\lconsentaffidavit DENISE PIASTRELLI-KOCAN, Plaintiff V. MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3514 CIVIL ACTION : : : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 24, 2002, and served July 27, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 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. C.S. ~ 4904 relating to unsworn falsifica- tion to authorities. Date MARK EDWARD KOCAN, Defendant fl\div\lwaivernotice DENISE PIASTRELLI-KOCAN, Plaintiff MARK EDWARD KOCAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3514 CIVIL ACTION : : CIVIL ACTION - LAW : IN DIVORCE Wi~IVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(C} OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without 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. C.S. ~ 4904 relating to unsworn falsifica- tion to authorities. Date MARK EDWARD KOCAN, Defendant fl\div\ltransmitpraecipe\7-97 DENISE PIASTRELLI-KOCAN, Plaintiff Vo MARK EDWARD KOCAN, De fendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3514 CIVIL TERM : ACTION 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 § (3301(c)) (~01(d', (i)) cf-the 2ivcrco Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Jury 27. 2002. US CertifiedMait. Return Receipt Requested, Restricted Delivery, posta.qe prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by ~ 3301 (c) of the Divorce Code: by Plaintiff February 26,, 2003 ; by Defendant February 26, 2003 (b) (1) Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code: ; (2) A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: Att CEAIMS SETTEED 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: ~-~(~.o~ Date Defendant's Waiver of Notice in ~ 3301(c)TDivorce was filed with the Prothonotary: ;~- 7_~ -~ . / Supre~ Court/No. 6Q~51 IN PLEAS THE COURT OF COMMON CF CUMBERLAND COUNTY STATE Of PENNA. DENISE PIASTR~.T.I-KOCAN, Plaintiff VERSUS MARK EDWARD KOCAN, Defendant N O. 02-3514 AND NOW, DECREED THAT AND DECREE IN DIVORCE DENISE PIAST~,T.I -KOCAN , IT IS ORDERED AND , PLAINTIFF, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; ~PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DENISE PIASTRELLI-KOCAN, MARK EDWARD KOCAN, Plaintiff Defe~l~nt NO. 3514 CIVIL ~2002 ~CTION IN DI%K)RCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the llth day of March , x~9 2003, hereby elects to retake and hereafter use her previous name of DENISE PIASTRELLI COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Denise Piastrelli On the day of · ~ 2003, before, a Notary Public, personally appeare Denise Piastrelli-K0can , known to me to be the person whose name is subscribed to the within docu- ment, and acknowledged that she executed the foregoing for the pur- pose therein contained. IN WITNESS WHE~OF, I have hereunto set my hand and Notarial No~ry NOTARIAL SE,~d.. KA. YE R. !.UGKEY, No~J P1Jbllc N~ Ct~'n~'land Boro. CurnN~land Co. My Commission Expires March 27, 2005