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HomeMy WebLinkAbout02-4572JOSEPH M. UHRINEK, Plaintiff VS. CHERI A. UHR1NEK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. O.2- : C1VIL ACTION - 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 action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DiVISION OF MARITAL PROPERTY, COUNSEL FEES OR ESPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F 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, Pennsylvania 17013 (717) 249-3166 JOSEPH M. UHRINEK, Plaintiff VS. CHERI A. UHRrNEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - DIVORCE .COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE Plaintiff,s Joseph M. Uhrinek, an adult individual who currently resides at 117 Locust Street, Apt. #1, Harrisburg, 17110, Dauphin County, Pennsylvania. 2. Defendant is Cheri A. Uhrinek, an adult individual who currently resides at 50 Pine Ridge Circle, Enola, 17025,Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on, May 6, 1986, in New Cumberland, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto, in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of the Congress of 1940 and its amendments. 7. This marriage is irretrievably broken. 8. Plaintiff avers that he has been advised of availability of counseling and he is aware of his rights to request that the parties participate in cotmseling. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully submitted, THE LAW OFFICES OF EDWARD J. MIMNAGH Date:~. /c-j/ ~C~?._ By: Edward J Mim~agh, E~qmre Attorney for Plaintiff Supreme Court I.D. # 87860 203 West Caracas Avenue Suite 201 Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Fax: (717) 534-1344 VERIFICATION I, Joseph M. Uhrinck, verify that thc statements made in the foregoing Complaint arc true and correct. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: JOSEPH M. UHRINEK, Plaintiff VS. CHERI A. UHRINEK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4572 CIVIL TERM CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE On this 27th day of September, 2002, I, Edward J. Mimnagh, Esquire, hereby certify that I served a true and correct copy of the foregoing Complaint in Divorce upon all parties of record via Certified Mail Return Receipt Requested and United States Mail, postage prepaid, addressed as follows: Cheri Uhrinek 50 Pine Ridge Circle Enola Pennsylvania, 17025 Date: By: Respectfully submitted, THE LAW OFFICES OF EDWARD J. MIMNAGH Edward J. Mimna~h, E ~q~tre Supreme Court ID # 87860 203 West Caracas Avenue, Suite 201 Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Fax: (717) 534-1344 JOSEPH M. UHRINEK, Plaintiff, V. CHERI A. UHRINEK, Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-4572 CIVIL TERM · CWIL ACTION-DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 2002. 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 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. CHERI A. UHRINEK Defendant JOSEPH M. UHRINEK, Plaintiff V. CHERI A. UHRINEK, Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-4572 CIVIL TERM : : .- · CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) oF TI-~ DIVORCE COOE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights conceming 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 falsification to authorities. CHERI A. UHR1NEK Defendant JOSEPH M. UHRINEK, Plaintiff, V. CHERI A. UHRINEK, Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4572 CIVIL TERM : · CIVIL ACTION- DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 2002. 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 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. JOSEPH M. UHRINEK, Plaintiff, V. CHERI A. UHR1NEK, Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 02-4572 CIVIL TERM .. · CIVIL ACTION-DIVORCE AFFIDAVIT OF SIGNATURE I, Joseph M. Uhrinek, hereby verify that I am the Plaintiff in the above-captioned divorce action; that I am familiar with the signature of Defendant, Cheri A. Uhrinek, and that the signature on the return receipt, attached hereto as Plaintiff's Exhibit "A", is the signature of the above-captioned Defendant. I verify that the statements made in the 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· Date: ~ ~-) Zoo'~ E13H M. UHRINEK ttiff UNIIEO STATES PO: ~ERVIC£ -'.-'T.~"-~,., Permit No. G-10 J Sender: Please print your name, address, and ZIP-;-4 in th~s box · · Complete items .... and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Addressee C. Date of Delivery Is delivery address different from item 17 [] Yes If YES. enter delivery address below: [] No 3. Service Type i '~ Certified Mail [~] Express Mail I Registered ~-Return Receipt for Merchandise [] Insured Mail 11 C.O,D. 4. Restricted Delivery? (Extra Fee) [] Yes 2. Article Number ~ransferfrornservicelabel) 7002 0510' 0003 3930 0030 PS Form 3811, August 2001 Domestic Return Receipt ~02595-02-M-I035 © JOSEPH M. UHRINEK, Plaintiff, V. CHERI A. UHRINEK, Defendant. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA ' NO. 02-4572 CIVIL TERM · CIVIL ACTION-DIVORCE PRAECIPE TO TRANSMIT RECORD AND NOW, Plaintiff, Joseph M. Uhrinek, by and through his counsel, Edward J. Mimnagh, Esquire, files the foregoing Praecipe to Transmit the Record, together with the following information, to this Honorable Court for entry ora divorce decree: irretrievable broken under § 3301 (c) of the Pennsylvania Divorce Code. Divorce, No. The ground for the above-captioned Divorce Action, No. 02-4572, is 2. Joseph M. Uhrinek, Plaintiff above-captioned, filed a Complaint in 02-4572, with the Cumberland County Court on September 23, 2002. (See Plaintiff's Complaint in Divorce attached hereto as Exhibit "A") Complaint in 3. Cheri A. Uhrinek, Defendant above-captioned, was served with Plaintiff' s Divorce on September 27, 2002, via U.S. First Class Mail and Certified Mail Return Receipt Requested. (See Plaintiff's Certificate of Service attached hereto as Exhibit "B") 4. The Plaintiff and Defendant executed an affidavit of consent required by §3301(c) of the Pennsylvania Divorce Code on February 1, 2003 and February 4, 2003, respectively. (See Plaintiff's and Defendant's Affidavits attached hereto as Exhibit "C") There are no claims pending between the Plaintiff and Defendant above- captioned. 6. Plaintiff aftixed his signature to the Waiver of Notice, required pursuant to §3301(c) of the Pennsylvania Divorce Code, on February 1, 2003. (Plaintiff's Waiver of Notice will be flied with the Cumberland County Prothonotary with Plaintiff's Praecipe to Transmit the Record) (See Plaintiff's Waiver of Notice attached hereto as Exhibit "D") 7. Defendant's Waiver of Notice in §330~(c) Divorce was filed with the Cumberland County Prothonotary on February 12, 2003. (See Defendant's Waiver of Notice attached hereto as Exhibit "E") Date: / t, oo~ By: Respectfully submitted, THE LAW OFFICES OF EDWARD J', MIMNAGH ~ard~.~jd.~~M/~torney for i~l~intiff ~ Supreme Court I.D. # 87860 203 West Caracas Avenue Suite 201 Hershey, Pennsylvania 17033 Telephone: (717) 534-2600 Fax: (717) 534-1344 IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of J~~r~ PENNA. Jn.R~pH M_ UHR!NEK: PLAINTIFF~ VERSUS CHERI A. UHRINEK, DEFENDANT. NO. fl?.-4~77 CIV-D.--T~ Decree IN DIVORCE AND NOW,__~ DECREED THAT JOSEPH M. UHRINEK , ~.~'~, IT 15 ORDERED AND , PLAintiff, AND CHERI A. UHRINEK , 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; NONE BY THE COURT: . t PROTHONOTARY Jo