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HomeMy WebLinkAbout00-05215 " '-~ ,-",- , 'i, -.-: ~~" ~<-~~ ._,__,"_W'~. <'i ,",- 'J.! ;,,-- o ,-" _ ,_~ ~, . , . . ~~ ~ ~ ~ ~ ~ ~ . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . . . . CIVIL . . . . . . . STATE OF PENNA. . . . . . . . . . ELISA M. ARENA, Plaintiff NO. 2000-5215 . . VERSUS . . SALVATORE ARENA, . Defendant . . . . DECREE IN DIVORCE . . . . . Ot'LG""'7hfJ 2000 , IT IS ORDERED AND I f-+'-1 AND NOW, . DECREED THAT ELISA M. ARENA PLAINTIFF, . . AND SALVATORE ARENA , 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 . . . ~~ ~ ~~ ~ ~ . . J. . . . ATT ROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~_ ' ~___~ '~';J_ $' ,< ~ =,~ .il1'--' -~,,,;,..,'- ""I -0'- ~1IiI' ~=""~'~n., : -~'Z~~ cA7./?/.CJj ~~~'7~~W CO'~IC'I .. \' '< ,..~ . ... , ~""'-,, --'~" -->,. c_<_' iIIilIiiAl , 'I ~I '-, --,'~ ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV1UlIA v. NO. 2000 - 5215 CIVIL TERM SALVATORI!: ARENA, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (d) (1) of the Divorce Code. 2. Date and manner of service of the complaint: U.S. Mail, Restricted Delivery, July 30, 2000. 3. (a) (1) Date of execution of the affidavit required by section 330l(d) of the Divorce Code: October 9, 2000; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on December 4, 2000, served October 9, 2000. 4 . Related claims pending: None 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: U.S. Mail, postage prepaid, October 30, 2000. fh".,fU (). ~ Thomas D. Gould Attorney for Plaintiff >>,',- .;.;,- " "~'-'If -~.... """'~. ;.";,....;....;."'-"~.,;". _c__ _'"""-~~~"' ~ g 0 .." 0 .... I M ~~ n I -<:,~ .r:-- -I' ~5?, :I> ;01;,""" ~~ x Z~ l?? 9. to> ~ (jU .:8 " , ~, ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -5;Zlj- CIVIL TERM SALVATORE ARENA, 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 ground for is indignities or irretrievable breakdown ': of the marriage, you may request marriage counseling. A list of "marriage counselors is available in the Court Administrator's 'Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 l;,,:\~'i;-t':r'p'~ '" " ' ~ , ~ "-~~iillrlW#i ELISA M. ARENA, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 5.2/5 CIVIL TERM SALVATORE ARENA, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Elisa M. Arena who resides at 637 Cumberland Pointe Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2, The Defendant is Salvatore Arena who currently resides at v. Mercato Di Sabato, Bacoli, NA, Italia 80070 (Italy). 3. The Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 11, 1996 in Baltimore, Maryland. 5. The parties separated on October 6, 1998. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. ,-,,,,. ~' "- -'-r-I 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. iknoN D. JJ;nd~ Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 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. Date: I /25100 ~u 1n. ~ Elisa M. Arena ""',,"" ..1 ; '* "'-'-, ,-,< '':'''''~m-' ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 5215 CIVIL TERM SALVATORE ARENA, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on July 25, 2000, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on August 7, 2000. --rh'lWl44 0, ~ Thomas D. Gould 10 # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ~ . ..., .-"" ."iO' ~__'- -I~~ ',~ ^ -= ' '"""'lilIt~ , ~ ~'- ~"~"1 """. 'n'....""~~~-'~.............. , 8 c 0 C -n - 0 fTI f';~-:':J, n ~;;h1 I .s;:- ~z 'Ii ;l:>oo ...,,- I'! '~-n ::x r)~ 9? t5' (..) ~ Nl -< ~ .. . ~. ~ -- . . ' . !it ~" \ .. ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 5215 CIVIL TERM SALVATORE ARENA, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code was served upon the Defendant by depositing the same in the United States mail, postage pre-paid, to the address upon which the complaint in divorce was served upon the defendant, on October 9, 2000. ~..{),~ Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ~ , ~'~~'~i"",'i_ /' " . ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 5215 CIVIL TERM SALVATORE ARENA, DEFENDANT IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on October 6, 1998 and have continued to live separate and apart for a period of at least two years, 2. The marriage is irretrievably broken. 3. 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. 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: ~ ~1h,~ Elisa M. Arena ',., " . """!ll~;l;..:..:4N -,. ~Vl:llil.1ilI ~ "'---".,..... . {. ~~ , ~ ",J. ,'.. ~ g ~ <:::1 .C! r ~ R'~~ n i I '."p:J .c- :p~ s~ > :t:-n :x ":')-~- in ~ 0 ~ C'T1 'c ~ ~, (.,> t'oV I\} ~< ~" , .~ .. <, ~, - , ~ ~ oli,,", ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 5215 CIVIL TERM SALVATORE ARENA, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a Plaintiff's Notice of Intention to Request Entry of Section 3301(d) Divorce Decree and Defendant's counter-affidavit was served upon the Defendant by depositing the same in the United States mail, postage pre-paid, to the address upon which the complaint in divorce was served upon the defendant, on October 30, 2000. ---r:&rnM O. :/Jnd Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 '0.-,;:, ,,' ,-'-- ~;...,--.,""'~~ ~ , ,,~---", ;I~,,"-";"~"" ~-....... ~ <- "....La....:.....'-. , ,~~. =.< ,.,..= < - . ~', q 0 q -c, 3:: 0 ::.;1 ~ fT1 "~"i-n n ""hi I -u ~':l? ~t5 + Qc, -""f'_. ;;:: J> ~r: -H i@ :% ~iM r:9 0 ~ w ~ N ~ ~ ~~ """ ~ -- CJfwmas 'f), qoufri 2 e:AST MAIN STREET SHIAEMANSTOWN,PA 17011 ATTORNEY AT LAW (717) 731-1461 FAX 761.1974 October 30, 2000 SALVATORE ARENA C/O VITA ULIANO V. MERCATO DI SABATO BAROLI, (NA), ITALIA (ITALY) 80070 Re: Divorce Dear Mr. Arena: Enclosed is Plaintiff's Notice of Intention to Request Entry of Section 330l(d) Divorce Decree and Defendant's Counter- affidavit. Sincerely, !L,4A~. ~ Thomas D. Gould enclosures cc. Elisa M. Arena , " .. ~~~~ L' ~ .- ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 5215 CIVIL TEBM SALVATO~ ARENA, DEFENDANT IN DIVORCE NOTICE OF INTENTION TO llEQUEST ENTRY OF SECTION 3301(d) DIVORCE DECllEE TO: SALVATORE ARENA You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit. Therefore, on or after November 20, 2000, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter- affidavit by the above date, the court can enter a final decree in divorce. A Counter-affidavit which you may file with the prothonotary of the court is attached to this notice. ."'.Unless you have already filed with the court a writtei{"claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 . ---~~-----~, f' __ ELISA M. ARENA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 5215 CIVIL TERM SALVATORE ARENA, DEFENDANT IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (bl I oppose the entry of a divorce decree because (Check (ii, (ii) or both) : (i) The parties to this action have not lived separate and apart for a period of at least two years. (iil The marriage is not irretrievably broken. 2. Check either (a) or (bl: (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division-of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to request Divorce Decree, the divorce decree may be entered without further notice to me, and shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit 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 unsworn falsification to authorities. Date: Salvatore Arena NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC llELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. ",,'.Lti!>', '.J', ",.. "'..,~..lDiltJi~iMil.fiiljl11-~~~~~~I\lhll'iI:!~)jj.f' ~'"~ .~.~ Ltil.- _iIfiIlilIlt~~' tlj - ~ g C> ~ c:> ~ 0 .-~,~ ~w. r"1 ;;:,~; ::0 c-> ,. 'r- :p I --'-11'\) ~~ _::t'jt4 .s:- c5>2) ~ ",.. ;:!"Tl :x ~-B "-~rn Cf! 0 w ~ rv- ~ "