HomeMy WebLinkAbout03-0155ROBERT S. GUARINO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL DIVISION -LAW
JENNY R. GUARINO, : NO.2003- 1,g CIVIL TERM
Defendant
IN 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 grounds 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
Prothonotary's Office at the 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, PA 17013
(717) 249-3166
ROBERT S. GUARINO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL DIVISION -LAW
JENNY R. GUARINO, : NO.2003-1&5_ CIVIL TERM
Defendant : IN DIVORCE
COMPLAINT
AND NOW, comes the Plaintiff, by and through his attorney, John H. Broujos of Broujos &
Gilroy, P.C., and sets forth the following:
Plaintiff is Robert Stephen Guarino, who currently resides at 5 McCoy Lane, Carlisle,
Cumberland County, Pennsylvania.
2. Defendant is Jenny Rene Guarino, who currently resides 5 McCoy Lane, Carlisle,
Cumberland County, Pennsylvania.
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 parties were married on February 7, 1996 in Leavenworth, Kansas.
5. There have been no prior actions for divorce or annulment between the parties in this or
any other jurisdiction.
6. 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.
WHEREFORE the Plaintiff requests your Honorable Court to decree that the Plaintiff be
divorced from the Defendant.
January 9, 2003
John V. Broujos, Attorney for Plaintiff
RROUJOS & GILROY, P.C.
4 North Hanover Street
Carlisle, Pennsylvania 17013
717-243-4574 or 717-766-1690
I verify that the statements made in this pleading are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unworn falsification to authorities.
DATE:
Robert S. Guarino
ROBERT S. GUARINO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL DIVISION -LAW
JENNY R. GUARINO, NO. 2003- CIVIL TERM
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
I, John H. Broujos, Esquire, hereby certify that I have served a true and correct copy of the
foregoing Divorce Complaint on the following person at the following address by United States
First Class and Restricted Certified Mail, return receipt requested, on January 9, 2003 to:
Jenny R. Guarino
5 McCoy Lane.
Carlisle, PA 17013
January 9, 2003
John H. roujos, Esquire No.
Attorne for Plaintiff
BRO S & GILROY, P.C.
4 North Hanover Street
Carlisle, Pennsylvania 17013
717-243-4574;717-766-1690
FAX 717-243-8227
co 'lt? pr
Curtis R. Long
Prothonotary
office of the Protbonotarp
Cumber[anb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573