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Home My WebLink About02-3531Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel For Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaimiff Vo JOHN K. KRITIKOS Defendant 02 - 3531 Civil Tettii CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce. I certify that I am authorized to accept service on behalf of defendant. Date: J~iy~, 2002 A~thony L: I)~ca~sq~ir~- 113 Front Street P.O. Box 258 Boiling Springs, PA 17007 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel For Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff JOHN K. KRITIKOS Defendant 02 - ~'"~ Civil Term CIVIL ACTION - 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, Cumberland County Courthouse, South 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: 2 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel For Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff JOHN K. KRITIKOS Defendant 02 - ,~.~.,~! Civil Term CIVIL ACTION - DIVORCE COMPLAINT IN DIVORCE Count ! - Divorce 1. Plaintiff is Patricia A. Kritikos (SS// 177-42-2477) who currently resides at 12 East Main Street, New Kingstown, Cumberland County, Pennsylvania since in or around June 30, 2002. 2. Defendant is John K. Kritikos (SS# 186-34-0459) who currently resides at 50 Hoover Road, Carlisle, Cumberland County, Pennsylvania since in or around October, 1994. 3. The parties have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The parties were married on February 26, 1988 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The grounds for divorce are: a. the marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the pa~ies to participate in counseling. Wherefore, Plaintiff requests the Court to enter a Decree in Divorce under sections 3301(c) of the Divorce Code. Count H - Equitable Distribution 8. Plaintiff incorporates by reference paragraphs 1 through 7 above. 9. During the marriage, Plaimiff and Defendant acquired real and personal property. Wherefore, Plaintiff requests the Court to enter an Order equitably dividing all the mariml property. Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: July ~ ~ ,2002 2 VERIFICATION I, Patricia A. Kritikos, state upon personal knowledge or information and belief that the averments set forth in the foregoing document are tree. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: ~ ~ "~"~/ ,2002 Patricia A. Kritikos ~.~ G\ 0 CZ. Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff V. JOHN K. KRITIKOS Defendant NO. 02-3531 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 2002. A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 25, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consem 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 statemems 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. Patricia A. Kritikos ~'~ Date: May 30, 2003 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaimiff V. JOHN K. KRITIKOS Defendant NO. 02-3531 Civil Term CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consem to the entry of a f'mal 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 umil a divorce decree is emered by the Court and that a copy of the decree will be sero to me immediately after it is filed with the prothonotary. I verify that the statemems 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. Patricia A. Kritikos ~-" Date: May 30, 2003 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff V. JOHN K. KRITIKOS Defendant NO. 02-3531 Civil Term CIVIL ACTION - DIVORCE PRAECIPE To the Prothonotary: Please withdraw all economic claims raised in the above-captioned divorce action Supreme Court No. 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Plaintiff Date: June 19, 2003 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff JOHN K. KRITIKOS Defendant 2002. NO. 02-3531 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 25, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 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. § 4904, relating to unsworn falsification to authorities. John K. l~ritikos Date: June ~ ,2003 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff v. : NO. 02-3531 Civil Term : JOHN K. KRITIKOS : Defendant : CIVIL ACTION - 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 flied 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 falsification to authorities. John K. Kritikos Date: June ~ ,2003 Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. KRITIKOS Plaintiff V, NO. 02-3531 Civil Term JOHN K. KRITIKOS Defendant CIVIL ACTION - 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) (3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: 08/01/02 on defendant's counsel per the acceptance of service filed of record on 08/01/02. 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: 05/30/03; by defendant: 06/05/03. (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: N/A. (2) Date of filing and service of the plaintiff's affidavit upon the respondent: N/A. withdrawn. Related claims pending: All economic claims raised of record have been 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record: N/A. (b) Date plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: 06/02/03. Date defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: 06/20/03. 2 1N THE, COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PATRICIA A. KRITIKOS Plaintiff N O. VER:5LJS JOHN K. KRITIK0$ Defendant DECREE IN DIVORCE PENNA. PLEAS 3531 Civil 2002 AND NOW, ~¢f-~, i~ 2003 Patricia A. Kritikos DECREED THAT AND John J. Kritikos ARE DIVORCED FF;IOM THE BONDS OF MATRIMONY. THE COURT RETA]NB JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; None , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ATT ~ PROTHONOTARY