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Home My WebLink About02-3545NORA M. KASTELIC~ PLAINTIFF J. LEONARD KASTELIC~ DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 0,~ · ~ 5~"/~'- CIVIL TERM IN DIVORCE COMPLAINT 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, 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 Lawyer Referral Service 2 Liberty Avenue, Carlisle, PA 17013 Telephone:717.249.3166 NORA M. KASTELIC, PLAINTIFF J. LEONARD KASTELIC, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. ~,~- 3~'~f'. CML TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Nora M. Kastelic, by and through her attorneys, The Law Offices of Richard C. Gaffney, who files this Complaint under Sections 3301(c) of the Divorce Code, and who, in support thereof, respectfully represents that: Plaintiffis Nora M. Kastelic, who presently resides at 26 Country Club Place West, Camp Hill, Cumberland County, Pennsylvania 17011 since 1996. Defendant is J. Leonard Kastelic, whose residence is 332 Fairview Street, Carlisle, Cumberland County, Pennsylvania 17013, since 1996. Plaintiff and Defendant are sui [uris and both have been bona fide residents of the Commonwealth for a period of more than six months immediately preceding the filing of this Complaint. Plaintiff and Defendant were married on or about July 6, 1984 in Mobile, Alabama. Plaintiff and Defendant have one minor child to the marriage, Jesse D. Kastelic, 16 years of age. The parties to this action separated on or around January 1, 2002 and have continued to live separate and apart since then. There have been no prior actions of divome or for annulment between the parties. 10. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. Neither the Plaintiff nor the Defendant is in the military or naval service or in any branch of the armed fomes of the United States of America or its allies or is otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. WHEREFORE, Plaintiff respectfully prays this Honorable Court, if both parties file affidavits consenting to the divome after ninety (90) days have elapsed from the date of filing and service of this complaint, to enter a decree of divorce pursuant to 23 P.S. Section 3301(c). Respectfully submitted, Richard C. Gaffnc"yTEbq~r~r"~ Supreme Court I.D. No. 633'1'~ L^w OFFICES OF RICHARD C. OAFFNEY 2120 Market Street Suite 101 Camp Hill, PA 17011 Telephone: 717.975.9033 Attorney for Plaintiff NORA M. KASTELIC, PLAINTIFF J. LEONARD KASTELIC, DEFENDANT .} } } } } } } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. - ClWL TERM IN DIVORCE VERIFICATION I verify that the statements made in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unswom falsification to authorities. Dated: ~'~/,~- o~tgdPoo'- NORA M. KASTELIC, } PLAINTIFF } } V. } } J. LEONARO KASTELIC, } DEFENDANT } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY~ PENNSYLVANIA No. 02-3545- CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE Richard C. Gaffney, being duly sworn according to law, deposes and says that he is the attomey for the Plaintiff in the above-captioned action; that the defendant personally receive, at 332 Fairview Street, Carlisle, Pennsylvania, a true and correct copy of the Complaint in Divorce, duly endorsed with a Notice to Defend, by certified mail, return receipt requested; that on Monday, August 5, 2002, Defendant did personally receive said Complaint in Divorce as evidenced by the signed Return Receipt attached hereto; and that the facts set forth in the within Affidavit are true and correct to the best of his information and belief. P&hard"C. Attorney for Plaimiff Swom to and subscribed before me this ~ day of ~~ 2002. N~-ta~y Pt~0jic My commission · Complete items 1, 2, and 3. Nso complete item 4 if Restricted Delive~ is de~ired. · Print your name and address on the reveme so that we can return the cen:l to you. · Attach this card to the back of the m~J,'lpiece, or on the front if space permits. E] Addressee 17 I-lyes YES, enter delivery address below: I-I No [] Insured Mail [] C.O.D. PS Form 3811, JuN 1999 Domestic Retum Receipt t 102595-60-M-0952 < C~RLISLE PA 1701~ Certmad Return Receipt Fee (F.n~omememt Required) (End~ Required) NORA M. KASTELIC, PLAINTIFF J. LEONARD KASTELIC, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY~ PENNSYLVANIA No. 02-3545- CIVIL TERM IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Pursuant to Pennsylvania Rule of Civil Procedure No. 229(a), please mark the above- captioned matter as settled and discontinued. SMIGEL, ANDERSON & SACKS, LLP Ri6hard C. Gaffne~, Esquire Supreme Court ID# 63318,_fl 4431 North Front Street Harrisburg, PA 17110-1223 Telephone: (717) 234-2401 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Richard C. Gaffney, Esquire, attorney for the Plaintiff in the above-captioned matter, do hereby certify that I served a true and correct copy of the Praecipe to Withdraw Complaint by depositing same in the U.S. Mail, first class, postage prepaid, on the 10th day of November, 2003, addressed as follows: J. Leonard Kastelic 216 N. Enola Drive Enola, PA 17025 SMIGEL, ANDERSON & SACKS, LLP By: 'Richard C. ~. MBA, Esquire Supreme Court I.D.V~q53313 4431 North Front Street Harrisburg, PA 17110 Telephone: (717) 234-2401 Attorneys for Plaintiff