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Home My WebLink About95-02747 I \ . ., .' ., '" ~ 0: :~<-- f~- ,/ ~L' "'l, l~ ,; ~- ~ " -- - - jr:~ j r- :t r- (7)1 i i i HAYMOND C. PESKE, Plaintiff IN TilE COUHT OF COMMON I'I,EAS OF CUMBEHl.l\ND COUN'l'Y, PENNSYLVANIA vs, CIV1L ACTION - l.I\W lJefendant NO. 'I', I " 'II CIVJI, TERM IN IJlVOHCE JEANNINE M. PESKE, 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 against you and a decree in 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 with 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 Cl.I\IM FOH ALIMONY, DIVISION OF PROPEHTY, l.I\WYER'S FEES OR EXPENSES BEFORE A DIVOHCE OR ANNULMENT IS GHANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUH l.I\WYER A'l' ONCE. IF YOU DO NOT HAVE A l.I\WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE OFFICE SET FORTH BELOW TO FIND OUT WHEHE YOU CAN GET LEGAL HELP. Court Administrator t"ourth Floor cumberland County Courthouse Carlisle, Pennsylvania 17013 (717) 240-6200 (717) 697-0371 ilL) CI J By I flV\(t1J.t'l1 C ,)\'\.t,L/\.... Andrew C. Sheely, ES~8 PA. 1.0. No. 62469 1 West Main street Shlremanstown, PA 17011 (717) 737-0761 Attorney for Plaintiff HAYMOND C, PESKE, plaintiff 1 N TilE COUHT OF COMMON PI,EAS Of' CllMUERIJlIHl COUN'I'Y, PENNSYLVANIA CI Vll, AC'l'ION - IJlW vs. lJefendant NO. CIVIl. TEIU4 IN [JI VOHct; JEANNINE M. PEBKE, ~J.UlfT 1. Plaintiff Is Haymond C. Peske, who currently resides at 29 Laurel Drive, Mechanicsburg, cumbel'land County, Pennsylvania. 2. Defendant is Jeannine M. Peske, who currently resides at 407 N. Markst street, Mechanicsburg, Cumberland county, Pennsylvania. l. Plaintiff and Defendant have been bona fide residents of ths commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4, Plaintiff and lJefendant wsre married on July 26, 1991, at HarriSburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling, 7. Plaintiff avers as the grounds upon which this action is based Is thatl (A) 'lhat the Defendant has offered such indignities to the Plaintiff, the Injured and Innocent spouse, as to render his condition intolsrable and life hurdensome or, in the alternatlvel (II) 'l'hat tho marrlalJo hetween tho partlee hereto Is irretrievably broken and that the Plaintiff and Defendant have lived separate and apart since March 6, 1995 or, in the alternative I (C) That plaintiff and Defendant are now living separate and apart and, at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken, WHEREFORE, plaintiff requests your lIonorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. COUNT I. EOUITABLE DISTRIBUTION B. The allegations in Paragraphs 1 through and including 7 are incorporated herein and made a part hereof. 9. Plaintiff and Defendant have legally and beneficially acquired marital property, both real and personal, during their marriage from July 26, 1991 to March 6, 1995. 10. Plaintiff and Defendant have been unable to agree as to the equitable division of said marital property to the date of the filing of this complaint. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property pursuant to section 3501 and 3502 of the Divorce Code prior to the entry of a final divorce decree, Respectfully submitted t)"iU1/ C StUl( _- Andrew C. sheely, ESq6!re Attorney for Plaintiff Date I /i/.I ;-; / I'N'f (SEAL) 2 HAYMOND C. PESKE, Plaintiff 1 N Tim COURT OF coMMON PLEAS OF CUMUERl.AND COUN'I'Y, Pt:NNSYI.VANIA vs. Cl V lJ, AC'l'lON - LAW JEANNINE M. PESKE, Dsfendant NO. CIVIL'l'EIlM IN lllVOIlCE AU1J.W'U' HAYMOND C. PESKE, being duly sworn according to law, deposes and sayel (1) 1 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 t.he Domestic Relations 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 llecree being handed down by the Court. 1 understand that false statements herein are made subject to the penalties of 18 Pa.c.S.A. section 4904 relating to unsworn falaiM fication to authorities. , ' -1l~' I' j I e I, '.. Haymond C. Peske SWORN to and subscribed before me thlB l'le), day of /'/ :I() ,1995. , ) I I ;.- I~ ii'('~ ~,L..L{ l ' --2...L 1/1 Notary Publ.1c' My commission Expiresl N01AklAI ml CaTlflAIN[ I HARRA, NotUHIIAllC SHIRl MAN~ tOWN BORO, CllfollH RI ANIlI:O PA MvrOMMIS~ION IlP,RI', ~II" 9 1995