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HomeMy WebLinkAbout97-01182 \ \) ~ ct - ~ ct '-.J '1 ':> o ~ ~ - ~ ~ '-J '''\ " , ~-'- ," ~ \~ - . - :;) . - '-J ~ ~ ~; C'I ~I () < ! ~/Ul? t. /7 "/) ,;el a'P'" .h':'-.Lr/ -t: ,ctf-rMt.<~ / t/' - '7F1tc/ /I;1d;/ :i ?;~ , ,., VB. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA '/"/, /If.L (~;"j Ti"o- I NO. VINCENT J. CATALANO. Plaintiff TRICIA M. CATALANO, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE COUNT I AND NOW comes the Plaintiff, by Attorney JAMES M. BACH. and avers as follows: 1. Plaintiff is VINCENT J. CATALANO. who currently resides at 215 Briggs Street, Harrisbul], Pennsylvania, 17102. 2. Defendant is TRICIA M. CATALANO, who currently resides at 305 loth Street, New Cumberland, Pennsylvania, 17070. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 14. 1993. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7, Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the right to request that the Court require the parties to participate in counseling, and after being so advised. Plaintiff does not desire counseling. 2 - " ::I::, ~~ - ~.J n ~ ..., .-, F~ --.1 '. -- ~ -~; . '. ~ ,. ~ "-i .:! ".' ~ ... 6'. c..-t '.;\ \(:) ~~ -C:'> .-" ., -, t'l.)" ~ - ; ~--) :.-' ,Iii -I -- ............ .'. :, ~ c..., :--.J .' -0 . c:,.. 0-, l-l) v,. C" '-'I C" VINCENT J. CATALANO IN '1'IIB COURT OF COHHON PI,BAS, PLAINTIFF . CUMAF.RLAND COUNTY, PENNSYLVANIA . vs. 97 - 1182 CIVIL 'rERM TRICIA M. CATALANO . . DEFENDANT . IN DIVORCE . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 6th March. 1997 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree in Divorce, without notice. 4. I understand that, if a claim for alimony, alimony pendente lite, marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of those will be lost. I verify that the statements made in this ~ffidavit 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. ~ - 10 - 7 "1 DATE ' Signed ~Cllta.0uxJ DEFENDIINT TRICIA M. CATALANO VINCENT J. CATALANO : IN THE COURT OF COMMON PLEAS, PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA . VS. . 97 - 1182 CIVIL TERM TRICIA M. CATALANO . : DEFENDANT . IN DIVORCE . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 6th March, 1997 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final Decree in Divorce, without notice. 4. I understand that, if a claim for alimony, alimony pendente lite, marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of those will be lost. 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. t -/6- 9'1 DATE I ~ Signe VINCZNT J. CATALANO IN TilE COURT OF COMMON PLEAS OF PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . 97 - 1182 CIVIL TERM . . . TRICIA M. CATALANO : DEFENDANT : IN 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 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. C, -It - 97 DATE VINCENT J. CATALANO : IN TilE COURT OF COMMON PLEAS OF PLAINTIFF . CUMBERLAND COUNTY, PENNSYLVANIA . vs. . 97 - 1182 . TRICIA M. CATALANO CIVIL ACTION DEFENDAN'r . IN DIVORCE . CERTIFICATE OF PERSONAL SERVICE I, JAMES M. BACH, being duly sworn according to law, say that the Defendant herein was served a copy of said COMPLAINT along with a NOTICE to DEFEND and CLAIM RIGHTS, at 352 South Sportinq Hill Road, Mechanicsburg, Pennsylvania 17055, on the _ 7th day of March , 19-E.., 10:30 A.M., by handing to the Defendant a true and attested copy of the same and at the same time directing the Defendant's attention to the contents thereof and the "Notice to Plead" endorsed thereon. DATE: Ifif/97 BY: S M. BACH, ESQ. orney I.D. No. 18727 2 South Sporting Hill Road Mechanicsburg, PA 17055 717-737-2033 \'.'1 .:) -J : . : ,. .., '1 ,--, , ~r) " , :-1I " ) i-;l " , ~l :J l';) ~.