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Home My WebLink About01-5800FRANK J. PIACINE, Plaintiff KAREN A. PIACINE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND cOLrNTY, PENNSYLVANIA : NO. tDI --,5'g0C-3 : : CIVIL ACTION - LAW : COMPLAINT 1N DIVORCE NOTICE TO: KAREN A. PIACINE, Defendant 2721 N. University Drive Apt. #206 Waukesha, WI 53188 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 fights important to you, including custody or visitation of yohr 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, 1 Courthouse Square, 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 Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Document It: 216626,1 FRANK J. PIAC1NE, Plaintiff KAREN A. PIACINE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE COMPLAINT IN D1VORCE 1. The Plaintiffis Frank J. Piacine, an adult individual residing at 1428 Timber Chase Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Karen A. Piacine, an adult individual residing at 2721 N. University Drive, Apt. No. 206, Waukesha, Wisconsin 53188. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on August 11, 1990 in Pottsville, Pennsylvania. 5. Both Plaintiffand Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Rights Act of the Congress of 1940 and its amendments. 6. Plaintiff's social security number is 203-50-5691 and Defendant's social security number is 389-66-2038. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plaintiffhas 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. Document #: 194824.1 10. I1. 12. Defendant. No children were bom of this marriage. The marriage is irretrievably broken. The parties have been living separate and apart since November 23, 2000. Plaintiffrequests the Court to enter a Decree in Divorce divorcing Plainfiffand COUNT I Equitable Distribution 13. The averments of paragraph 1-12 are incorporated herein by reference. 14. During the marriage the parties acquired marital property, assets, and debts which Plaintiffrequests the Court equitably distribute and assign. WHEREFORE, Plaimiffrequests that this Court enter a Decree in Divorce, enter an Order equitably distributing marital property and enter such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB By: Date: Meliss~t L.-Van Eck, Esquire Attorney I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 194824.1 VERIFICATION I, Frank J. Piacine hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: Frank J. Piaci e~ Document #: 194824.1 CUMBERLAND DIVORCE OR ANNU~ENT STATE ~IL~ DATE ~ (CHECK ONE) 3. RESIDENCE ~AZNER KAR~N A. pTACTN~ 2721N. University Dr~ Apt. #206~ Waukesha, WI HUSBAND (Oay) 1428 Timber Chase Drive~ MechanicsburK, Cumberland PA _~i[2~m~ PA WIFE m~ q 1 ~ 5 6 OTHER (Speci~ 14. USUAL OCCUPATION [-~ I Nurse's Aid PA I MARRIAGE 8 IpLAINTIFF 9. DECREE GRANTED TO 8. HUSBAND WTFE OTHER (Specify) I HUSBr~AND MRRRIAGE 2 [~ UA~E Pottsville 20. NUMBEROF HUSBAND WIFE SPUTOUSTOOY OTHER(S~pecily) ~,LDREN TO [] [] [] 11 ] qq~ FRANK $. PIACINE, Plaintiff KAREN A. PIACINE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-5800 : : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE I, Melissa L. Van Eck, counsel for Plaintiff, Frank J. Piacine, hereby certify that a true and correct copy of the Complaint in Divorce was served upon the following, by certified mail, return receipt on October 29, 2001. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is a copy of the return receipt card indicating service upon: Karen A. Piacine 2721 N. University Drive, Apt. 206 Waukesha, WI 53188 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Date: November 5, 2001 Melissa L. Van Eck, Esquire I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document #: 219695. I · ??~ 4 # F,e~ Peavey/is de~. - so that we ca~ return the ca~ to you. ~to~~l~' Kamen A. P~ac~ne . 2721 N. University Dr. Apt. 206 ~aukesha, ~I 53188 n ~ed'Maa [] c.o.D. · - ' ~ PSFo~m3811,July199g ~,~,T,--~.RetumRecapt 4. Restricted Delive~ ~,ylre Fee) ri Yes I P~tage & Fees Pai~ ! usPs / · Sender:Please pdntyourname, address, and ZIP+4inthis box. Helissa L. Van Eck, Esquire ~etzger, ~ickersham~ Knauss & Erb~ P.C. 3211N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 FRANK PIACINE, Plaintiff KAREN A. PIACINE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5800 CML TERM IN DIVORCE PRAECIPE TO ENTER APPEARANCE AND NOW, this ]q'~ day of December 2001, the undersigned attorney enters his appearance on behalf of the defendant, Karen A. Piacine. Date Camp Hill, PA 17011 (717) 737-1956 Attorney for Defendant ID No. 59020 FRANCIS J. PIACINE, Plaintiff KAREN A. PIACINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 01-5800 Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW APPEARANC~ TO THE PROTHONOTARY: Please withdraw the appearance of Melissa Van Eck, Esquire, in the above-captioned action as Matthew J. Eshelman, Esquire is entering his appearance on behalf of the Plaintiff. Respectfully submitted, Date: II/1~/~; ~ Melissa ~. Vah Eck, Esquire 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 ID# 85869 Tel. (717)238-8187 PRAECIPE TQ ENTER APPEARANCe. TO THE PROTHONOTARY: Please enter the appearance of Matthew J. Eshelman, Esquire, in the above-captioned action. 2108 , Camp Hill, ID# 72655 Eshelm~n, Esquire Street, Aztec Building Pennsylvania 17011-4706 Tel. (717) 763-1800 FRANCIS J- PIACINE, Plaintiff vs. KAREN A. PIACINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 5800 CIVIL IN DIVORCE QRDER OF COU_R__T ~~ · AND NOW, this /~_ day of ~4~ ~ , 2003, both counsel having failed to return the certification document to the Master's office which was dated October 17, 2002, certifying the status of discovery, the appointment of the Master is vacated. cc: Matthew J. Eshelman Attorney for Plaintiff jAustin F. Grogan Attorney for Defendant BY THE COURT,