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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
PENNA.
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RONALD D. LiBRANDI,
NO.
2000-5660 CIVIL TERM
PLAINTIFF
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VERSUS
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JO ANN N. LiBRANDI,
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DEFENDANT
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DECREE IN
DIVORCE
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cA ,,: 3 r ,A.tt1.
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~ Id-.
2000 IT IS ORDERED AND
,
AND NOW,
DECREED THAT
RONALD D. LiBRANDI
, PLAINTIFF,
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AND
JO ANN N. LiBRANDI
, DEFENDANT,
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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;
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NONE
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5660 CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c)..
2. Date and manner of service of the Complaint: Acceptance of Service filed by
Plaintiff's counsel indicating service on or about 21 August 2000 on Defendant.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by
Section 3301 (c) of the Divorce Code:
By Plaintiff: 6 December 2000 By Defendant: 6 December 2000
(b) (1) Date of execution of the Affidavit required by Section 3301
(d) of the Divorce Code: (2) Date of filing and service of
the Plaintiff's Affidavit upon the Respondent:
4. Related claims pending:
None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File
Praecipe to Transmit Record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce
was filed with the Prothonotary: dated 6 December 2000. filed
contemporaneollsly herewith. Date Defendant's Waiver of Notice in
Section 3301 (c) Divorce was filed with the Prothonotary: dated 6
December 2000 filed contemporaneously herewith.
BY'-~
Sam el L. Andes
Attorney for Plaintiff
Date: 6 December 2000
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-.5'!;6tJ CIVIL TERM
JO-ANN N. LiBRANDI,
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
foregoing 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 in 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 the 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:
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, Pennsylvania 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, Pennsylvania 17013
Telephone: (717) 249-3166
1
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000- sU.tJ
CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
accordance with Section 3302(d) of the Divorce Code, you may request that the court
require you and your spouse to attend marriage counseling prior to a divorce being handed
down by the court. A list of professional marriage counselors is available at the Domestic
Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this
list is kept as a convenience to you and you are not bound to choose a counselor from this
list. All necessary arrangements and the cost of counseling sessions are to be borne by you
and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
2
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"
RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-3Hb
CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, RONALD D. LiBRANDI, II, by his
attorney, Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is RONALD D. LiBRANDI, II, an adult individual who currently resides
at 2007 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is JO-ANN N. LiBRANDI, an adult individual who currently resides
at 55 Oliver Road, Enola, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 9 October 1993 in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This marriage is irretrievably broken.
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7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
I verify that the statements made in this Complaint are true and correct. I understand
that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904
(unsworn falsification to authorities).
DATE: f1u1(Jjf ~2000
!~ iJJ!W Jt-
RONALD D. LiBRANDI, II
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Sa el L. And "
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5660 CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
16 August 2000 and was served upon the Defendant on or about 21 August 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
, complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
,
i Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
final.
I verify that the statements made in this Affidavit are true and correct and 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.
6 December 2000
. DATE
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RONALD D. LiBRANDI, II
II
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5660 CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 {c} of the Divorce Code was filed on
i 16 August 2000 and was served upon the Defendant on or about 21 August 2000.
,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing of the complaint and the date of service of the
;complaint on the Defendant.
3. I consent to the entry of a final decree in divorce either after service of a Notice of
Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of
Intention to Request Entry of the Decree.
4. I have been advised of the availability of marriage counseling and understand that
the Court maintains a list of marriage counselors and that I may request the Court to require
my spouse and I to participate in counseling and, being so advised, do not request that the
Court require that my spouse and I participate in counseling prior to the divorce becoming
"final.
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I verify that the statements made in this Affidavit are true and correct and 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.
6 DecPlTlher 2000
DATE
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5660 CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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
I court and that a copy of the decree will be sent to me immediately after it is filed with the
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i 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. Section 4904
. relating to unsworn falsification to authorities.
6 December 2000
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if ALD D. LiBRANDI, II
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5660 CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301lcl OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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. Section 4904
relating to unsworn falsification to authorities.
6 December 2000
Dated:
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RONALD D. LiBRANDI, II,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 2000-5660 CIVIL TERM
JO-ANN N. LiBRANDI,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
The undersigned, Jo-Ann N. Librandi, does hereby accept service of the Divorce
Complaint filed against her in this matter and acknowledges receipt of a certified copy of
that Complaint.
,DATED: 21 August 2000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
..
7mALP LJ. L EYurd0 ]I:
" , P lain tiff
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File No. 2-0e:t:)-O'S{p&C'
vs.
IN DIVORCE
--1- Al\JiV tJ.
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Defendant :
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff~fenda~ in the
above matter, having been granted a Final Decree in Divorce on the
12... day of DeA'2~r , .2..CC(), hereby elects to resume the
prior surname of ~f"id.e\ \ , and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE: ,- 2-0\
uc;;;;j
COMMONWEALTH OF PENNSYLVANIA:
KE(OELL-
COUNTY OF CUMBERLAND
On the ;2., lid day of q0.~' , i:<J~,J. before me, a
Notary Public, personally appeared t above affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
In Witness Whereof,
I have hereunto set my hand and official
&a1fdJ<Lq,&~loaA/
seal.
NOTARIAL SEAL
CLAUDIA A. BREWBAKER, NOTARY PUBLIC
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005
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