HomeMy WebLinkAbout03-0544RICHARD H. PIZZARRO,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SHERRY PIZZARRO,
Defendant
NO. O.~-
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 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 at the Cumberland County Courthouse,
Carlisle, PA 17013.
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) 249-31~/
Pamela L. Purdy
100 Pine Street, P. O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
RICHARD H. PIZZARRO,
Plaintiff
SHERRY PlZZARRO,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03
IN DIVORCE
COMPLAINT
COUNT I
Divorce Under 3301(c) or 3301 (d) of the Divorce Code
1. Plaintiff is RICHARD H. PIZZARRO who currently resides at 3 Conestoga
Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is SHERRY PIZZARRO who currently resides at 3 Conestoga
Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months previous to the filing of this
Complaint.
4.
5.
parties.
6.
7.
Plaintiff and Defendant were married on August 19, 1994 at Maui, Hawaii.
There have been no prior actions of divorce or for annulment between the
The marriage is irretrievably broken.
The grounds on which the action for divorce is based are:
A. Section 3301(c): The marriage of the parties is irretrievably broken.
After 90 days have elapsed from the filing of this Complaint, it is believed the parties will
file Affidavits of Consent to a divorce.
8. Plaintiff has been advised of the availability of counseling and that he/she
may have the right to request that the Court require the parties to participate in
counseling. Plaintiff hereby waives his/her right to such counseling.
9. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under
Section 3301(c) or (d) of the Divorce Code.
Dated:
February 3, 2003
McNEES WAJ2~;ACE & NURICJ~ LLC
' 'D"81ano M. Lant'z(,/ 'k,,.~ ID No. 21401
Pamela L. Purdy
ID No. 85783
100 Pine Street
P. O. Box 1166
Harrisburg, PA 17108-1166
(717) 232-8000
Attorneys for Plaintiff
-2-
VERIFICATION
I verify that the statements made in this Complaint 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.
l~ichard H. Piz/z~'rr'~) ~
RICHARD H. PIZZARRO,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
SHERRY PIZZARRO,
Defendant
NO. 03-544 Civil Term
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint on behalf of Defendant and certify that I am
authorized to do so.
Dated:
REAGER & A~LI:-'R, P.C.
2331 Market Street
Camp Hill, PA 17011-4642
Attorneys for Defendant
RICHARD H. PIZZARRO,
Plaintiff
SHERRY PIZZARRO,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 03-544 CIVIL TF~RM
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF ELECTION TO RESUME MAIDEN NAME
Notice is hereby given that a final decree in divorce being granted, Sherry Ellen Pizzarro
hereby elects to resume her prior name of Sherry Ellen Collins, attd gives this written notice of her
intention in accordance with the provisions of 54 Pa.C.S. Section 704.
to be known as:
Sherry Elllfll Collins
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
Onthe /0 fl'xlay of
,2003, before mt;, a Notary Public, personally
appeared Sherry Ellen Pizzarro, t/b/k/a Sherry Ellen Collins, known to n~ to be the person whose
name is subscribed to the within document and acknowledged that she executed the foregoing for
the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
/ - No tary/,l~tublic
NOTARIAL SEAL
ROBERT J. GOLD, No~y Public
Haml~den Twp. Cumberland Ceunly
My Commission Expires July 10, 2005