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HomeMy WebLinkAbout02-4809ELIZABETH FLAVIA BORRELLI, Plaintiff CHRISTOPHER PATRICK BORRELLI, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O.q - : IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement 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, 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, PENNSYLVANIA 17013 (717) 249-3166 ELIZABETH FLAVIA BORRELLI, Plaintiff CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE COMPLAINT 1. The Plaintiff is Elizabeth Flavia Borrelli, who currently resides at 30 School House Road, Gardners, Cumberland County, Pelmsylvania 17324. 2. The Defendant is Christopher Patrick Borrelli, who currently resides at 102 Country Villa Lane, Apt. 108, St. Robert, Missouri 65583. 3. Plaintiff and Defendant have 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 August 3, 1999 in Shippensburg, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections 3301(c) and 3301(d), in that: a) The marriage is irretrievably broken. b) Plaintiff and Defendant have lived separate and apart since November 16, 2001 and continue to do so. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Defendant is a member of the armed services. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, Date Austin F. Grogfin, Es~u~e 24 North 32nd Street ~' Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff I.D.//59020 VERIFICATION I, ELIZABETH F. BORRELLI, verify that the statements made in the foregoing Complaint are true 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. § 4904, relating to unsworn falsification to authorities. Date ELIZAI~TH F. BORRELLI ELIZABETH FLAVIA BORRELLI, Plaintiff CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4809 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST m rr ENTRY OF A DIVORCE DECREE IYNDER ~ ~ SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODEr_~C; 1. I consent to the entry of a final decree of divorce without ~o ~e. 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 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. ELIZI~ETH [~AVIA BORRELLI ELIZABETH FLAVIA BORRELLI, Plaintiff Vo CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 024809 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 2, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the ComplainL 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 axe true and correct. I understand that false statements herein axe made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. C'HRI~TOPHER PAT?~t~I;~ ELIZABETH FLAVIA BORRELLI, Plaintiff Vo CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 024809 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) AND 3301(d) 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 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 unswom falsification to authorities. ELIZABETH FLAVIA BORRELLI, Plaintiff CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4809 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 2, 2002. 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 tree 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. ELIZABI~i'H FLAVIA BORRELLI ELIZABETH FLAVIA BORRELLI, Plaintiff Vo CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-4809 CIVIL TERM · IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, CHRISTOPHER PATRICK BORRELLI, Defendant in the above-captioned action in Divorce, hereby acknowledge that I have in fact received a copy of the Complaint for Divorce in this matter on ('~-r~ _~-~: 2t3~2_..at ~ '.L,~ 'TM. 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. Date (---~TO'-~HER PA,.~(~g~ ELIZABETH FLAVIA BORRELLI, Plaintiff Mo CHRISTOPHER PATRICK BORRELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4809 CIVIL TERM 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. Date and manner of service of the complaint: By acceptance of service on October 24, 2002 3. Date of execution of the Affidavit of Consem required by § Divorce Code: by Plaintiff February 25, 2003; by Defendant January 31, 2003. 3301(c) of the 4. Related claims pending: 5. Date Plaintiff's Waiver Prothonotary: February 27, 2003. No claims raised. of Notice in § 3301(c) Divorce was filed with the 6. Date Defendant's Waiver of Prothonotary: February 27 2003. Date: Notice in § 3301(c) Divorce was filed with the ~udt~u~ 'AGI~°Dg ~y sNq~. C. Attorney for Plaintiff 3901 Market Street Camp Hill, PA 17011 (717) 737.-0464 ID # 59020 INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~.~~. PENNA. ELIZABETH FLAVIA BORRELLI Plaintiff VERSUS CHRISTOPHER PATRICK BORRELLI Defendant NO. 02-4809 civil Term DECREE IN AND NOW, DIVORCE , i~, 1T IS ORDERED AND ELIZABETH FLAVIA BORRELLI DECREED THAT _, PLAINTIFF, AND CHRISTOPHER PATRICK BORRELLI , 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. ATTEStl/~~ J' PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. Defendant File No. IN DI VOR6F. NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 5+n day of .~kc(~ , hereby elects to resume the prior surname of ~{Tf*~A ~-'\0~{dk ~-~_~i~D\k~ , and gives this written notice pursuant to the provision~of 54 P.S. S 704. S igna~-u~e Signature o~ name being r~med COMMONWEALTH OF PENNSYLVANIA: : COUNTY OF CUMBERLAND : SS. the __~ On .... day of ~r/0~.~ , L~'~, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In WiLness Whereof, I have hereunto set my hand and official seal. NOIA~IAL SEAL CLALii~tA A. BREWBAKER, NOTARY PUBLIC Car~isl~ Boro, Cumberland County ~,lv Commission Expires Apr!~: ?005 Notary Public