HomeMy WebLinkAbout01-0290 FX
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
CHERYL ALESSANDRONI,
No. 2001-290 CIVIL TERM
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Plaintiff
CIVIL ACTION - LAW
VERSUS
IN DIVORCE
MICHAEL ALESSANDRONI,
Defendant
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DECREE IN
DIVORCE
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AND NOW,
~b~
3~ , 2001
, IT IS ORDERED AND
DECREED THAT
CHERYL ALESSANDRONI
, PLAINTIFF,
AND
MICHAEL ALESSANDRONI
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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 t=:NTERED;
The Marriage Settlement'Agreement dated August 31, 2001 and signed by
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the parties is hereby incorporated into this Decree, but not merged.
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By THE COURT: . /'1 L
ATTEST(1~
PROTHONOTARY
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this ~//.)r day of tl{,(..~t:. , 2001, by and
between CHERYL L. ALESSANDRONI (hereinafter referred to as "WIFE") and MICHAEL C.
ALESSANDRONI, (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on June 14, 1997; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and fmally their
respective fmancial and property rights and obligations as between each other, including, without
limitation by specification; the settling of all matters between them relating to the ownership and
equitable distribution of real and personal property; the settling of all claims and possible claims
by one against the other or against their respective estates and equitable distribution of property
and alimony for each party.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
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2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
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(1) is represented by counsel, (Rebecca R. Hughes, Esquire for HUSBAND and
Peter D. Solymos, Esquire for WIFE) of his or her own choosing; or if not
represented by counsel, understands that he or she has the right to counsel;
(2) is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agreement; and
(6) fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective inunediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 3301(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that cdnforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
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6.
Each party represents and warrants that he or she has had sufficient time and access to all
information necessary to enter into this Agreement, including but not limited to property interests
of any nature, whether personal or business, any mortgage, pledge, lien, charge, security interest,
encumbrance, or restriction to which any property is subject. Each party further represents that,
although not all the information was requested, that he or she is satisfied with the cooperation
and disclosure of the property interests of any nature of the other party, and waives any right to
raise the lack of disclosure of property interests of any nature as a defense to the enforcement of
this Agreement. Each further represents and warrants that he or she has not made any gifts or
transfers for inadequate consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
7.
REAL ESTATE: WIFE hereby agree to transfer to HUSBAND all right, title and
interest in the property known and numbered as 123 Pearl Drive, Carlisle, Cumberland County,
Pennsylvania. WIFE hereby agrees to cooperate in the transferring of the deed to said property,
and WIFE's attorney shall hold said deed in escrow until the refmance of the mortgage currently
on the property. HUSBAND hereby agrees to refmance said mortgage removing WIFE's name
from all liens against said property, and holding her harmless from the same. HUSBAND agrees
to pay the sum ofTen Thousand Dollars ($10,000.00) to WIFE at the time of the refinancing of
said property. Furthermore, HUSBAND shall pay to WIFE and additional Fifteen Thousand
Dollars ($15,000.00) as follows: Five Thousand Dollars ($5,000.00) on or before December 31,
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2002; Five Thousand Dollars ($5,000.00) on or before December 31,2003; and Five Thousand
Dollars ($5,000.00) on or before December 31, 2003.
8.
SUPPORT:
SPOUSAL SUPPORT: Both parties hereby waive and forego all fmancial and material
spousal support from each other and agree not to request or seek to obtain alimony, alimony
pendente lite, or spousal support before or after any divorce which may be granted.
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of
same as fully and effectually, in all respects and for all purposes as ifhe or she were unmarried.
10.
AUTOMOBILES: HUSBAND agrees to transfer all interest which he may have in
WIFE's motor vehicle, and WIFE agrees to transfer all interest which she may have in
HUSBAND's motor vehicle.
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11.
MARITAL DEBTS: It is further mutually agreed by and between the parties that WIFE
shall assume all liability for and pay and indemnify the HUSBAND against all debts incurred by
WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the
parties' marital separation she has not contracted or incurred any debt or liability for which
HUSBAND or his estate might be responsible and WIFE further represents and warrants to
HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify and
save HUSBAND harmless from any and all claims or demands made against him by reason of
debts or obligations incurred by her.
HUSBAND shall assume all liability for and pay and indemnify the WIFE against all
debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and Warrants to WIFE that he will not contract or incur any debt or liability after the execution of
this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall indemnify
and save WIFE harmless from any and all claims or demands made against her by reason of
debts or obligations incurred by him.
12.
INSURANCE AND EMPLOYEE BENEFITS:
The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
WIFE waives all right, title and claim to HUSBAND's employee benefits, and HUSBAND
waives all right, title, and claim to any of WIFE's employee benefits.
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13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND, and HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE.
14.
BREACH: If either party breaches any provision of this Agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
15.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
16.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is
not the result of any duress or undue influence. The provisions of this Agreement are fully
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understood by both parties and each party acknowledges that the Agreement is fair and equitable,
that it is being entered into voluntarily, and that it is not the result of any duress or undue
influence. It is the parties' intent that this Agreement does not merge with the Divorce Decree,
but rather shall continue to have independent contractual significance. Each party maintains his
or her contractual remedies or any other remedies provided by law or statute. Those remedies
shall include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
17.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
18.
APPLICABLE LAW: This Agreement shall be construed under the Laws ofthe
Commonwealth of Pennsylvania.
19.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
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20.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquisiunent of all such interests, rights and claims.
21.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
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IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year fIrst above written.
WITNESSES:
(SEAL)
;vI, L. ALESSANDRONI
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:/" ~CHAEL C. ALESSANDRONI
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this3/atday of tl/"'F
2001, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, CHERYL L. ALESSANDRONI, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
~SeeI
r.ladha L NoeU. NoIlMy Pubfic
CallisIe 80m. cu,.....llMod County
My Comnistiun e.piies Sept. 18, 2003
MefIW, l'ennsytvanla Association of NoIalles
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ;./fI1 day ofc21"t ffl/JuJr
2001, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, MICHAEL C. ALESSANDRONI, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Marriage Settlement Agreement , and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notari/ll Seal
Martha L. Noel, Notary Public
Carlisle Boro, CUmberland County
My Commission Expires Sept. 18, 2003
Member, I'ennsvlvaOla ASSOCiatIOn of Notaries
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL ALESSANDRONI,
Civil Action - Law
Plaintiff
vs.
No. OI~J90C'\o~'l
MICHAEL ALESSANDRONI,
Defendant
Divorce
TO: MICHAEL ALESSANDRONI, Defendant
123 Pearl Drive, Carlisle, PA 17013
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 you1 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
counselo:ros is available in the Office of the Prothonotary at the Cumberland
County Court House, Three South Hanover Street, Carlisle, PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR
EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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
P.O. Box 186
Harrisburg, PA 17108
Telephone (800) 692-7375
BY:
ETER
1. D. No.
110 South
York, PA 1 402
Telephone (717) 757~7602
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AVISO PARA DEFENDER Y RECLAMAR DERECHOS
Usted ha sido demandado en la corte. Si desea defenderse de las quejas
expuestas en las paginas siguientes, debe tamar acci6n con prontitud. Se Ie
avisa que si no se defiende, e1 caso puede proceder sin usted y decreta de
divorcio 0 anulamiento puede ser emitido en au contra par la Corte. Una decision
puede tambien ser emitida en su contra par cualquier otra queja 0 compensaci6n
reclamados por el demandante. Usted puede perder dinero, 0 propiedades u otros
derechas importantes para usted.
Cuando la base para el divorcio es indignidades 0 rompimiento irreparable
del matrimonio, usted puede solicitar consejo matrimonial. Una lista de
consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la
York County Court of Common Pleas, 28 East Market Street, York, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO
U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA
EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE
PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE
PUEDE OBTENER ASISTENCIA LEGAL.
Lawyer Referral Service
Cumberland County
P.O. Box 186
Harrisburg, PA 17108
Telephone (800) 692-7375
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of York County, Pennsylvania, is required
by law to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court,
please contact the county at (717) 771-9099. For those with a hearing
impairment, please contact the Deaf Center at (717) 848-2585 ext. 329 or
ext. 342 TOO. All arrangements must be made at least 72 hours prior to
any hearing or business before the court. You must attend the scheduled
conference or hearing.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL ALESSANDRONI,
Civil Action - Law
Plaintiff
vs.
No.
MICHAEL ALESSANDRONI,
Defendant
Divorce
TO: MICHAEL ALESSANDRONI, Defendant
123 Pearl Drive, Carlisle, PA 17013
NOTICE AS TO COUNSELING
You are hereby notified that counseling is available and may be requested
by either party.
Upon written request made to the Domestic Relations Office located at 13
North Hanover Streett Carlisle, PA 17013, both parties will be provided a list
of qualified professionals who give counseling service.
GRIFFITH, STRICKLER,
SOLYMOS & CALKINS
D. SOLYM
I. D. No. 0747
110 South Nort ern Way
York, PA 17402
Telephone (717) 757-7602
BY:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL ALESSANDRONI,
Plaintiff
Civil Action - Law
vs.
NO. pl, .290 ~/R..M-
MICHAEL ALESSANDRONI,
Defendant
Divorce
(LMIJ/f~NT
This 106 day of r/~~__ ' 200l, comes the Plaintiff, Cheryl
Alessandroni, by her attorneys, GRIFFITH, STRICKLER, LERMAN, SOLYMOS & CALKINS,
Esquires, by Peter D. Solymos, Esquire, and files this Complaint in Divorce,
whereof the following is a statement:
l. Plaintiff is Cheryl Alessandroni, an adult, who resides at l20 E.
Louther Street, Apartment C, Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant is Michael C. Alessandroni, an adult, who resides at 123
Pearl Drive, Carlisle, cumberland County, Pennsylvania 17013.
3. Plaintiff and Defendant have resided within the Commonwealth of
Pennsylvania for a period of more than six (6) months immediately preceding the
filing of this Complaint, and are both citizens of the United States of America.
4. The Plaintiff and Defendant were married on June 14, 1997 I York,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between
the parties.
6. One (l) child was born as a result of said marriage, namely: Meryl
Alessandroni, date of birth l2/22/98.
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COUNT I
Divorce
No~Fault
7. Paragraphs 1~6 are incorporated by reference.
8. The marriage between the parties is irretrievably broken.
9. The Plaintiff has been advised of the availability of counseling and
that the Plaintiff may have the right to request that the Court require the
parties to participate in counseling.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce pursuant to Section 3301(c) of the Divorce Code, divorcing Plaintiff and
Defendant.
COUNT II
3301 (D\
10. Paragraphs 7~9 are incorporated by reference.
11. The marriage is irretrievably broken.
12. The parties were separated on February 1, 2000.
13. The parties have lived separate and apart since the separation and
have not cohabited as husband and wife.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce pursuant to Section 3301(d) of the Divorce Code, divorcing Plaintiff and
Defendant.
COUNT III
Divorce - Indianities
14. Paragraphs 10~13 are incorporated by reference.
15. The Plaintiff avers that in violation of the marriage and of the laws
of the Commonwealth of Pennsylvania, the Defendant has offered such indignities
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to the Plaintiff as to render her life burdensome and her condition intolerable.
16. This action is not collusive.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce, divorcing Plaintiff and Defendant.
COUNT IV
Alimonv, Alimonv Pendente Lite, Counsel Fees and Costs
17. Paragraphs 14~16 hereof are incorporated by reference.
18. The Plaintiff lacks sufficient property and income to provide for her
reasonable needs and meet the expenses of this litigation.
19. By reason of the conduct of the Defendant, the Plaintiff will be put
to considerable expense in the preparation of her case, the employment of counsel
and payment of expenses.
20. The Defendant has sufficient income and assets to support the
Plaintiff and meet the expenses that she will incur by reason of this litigation.
WHEREFORE, the Plaintiff requests your Honorable Court to award the
Plaintiff alimony, alimony pendente lite, counsel fees and expenses.
COUNT V
Eauitable Distribution of prooertv
18. Paragraphs 17-20 hereof are incorporated by reference.
19. Plaintiff and Defendant own substantial "marital property II as defined
under the Divorce Code.
20. In order to effectuate economic justice between the
parties, the Plaintiff requests your Honorable Court to enter a fair and just
determination and settlement of the parties' property rights.
WHEREFORE, the Plaintiff requests your Honorable Court to equitably divide
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and distribute the "marital property" of the parties in accordance with the
Divorce Code.
BY:
OS
Plaintiff
ourt I.D. No. 07475
Northern Way
York, PA 17402
Telephone No. (717) 757-7602
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VERIFICATION
I verify that the foregoing facts are true, upon my personal knowledge or
information and belief. This verification is made subject to the penalties of
l8 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CHERYL ALESSANDRONI
Plaintiff
Civil Action - Law
vs.
No.: 2001~290 Civil
MICHAEL ALESSANDRONI,
Defendant
Divorce
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF YORK
Before me, a Notary Public in and for said Commonwealth and County,
personally appeared PETER D. SOLYMOS, ESQUIRE of the law firm of GRIFFITH,
STRICKLER, LERMAN, SOLYMOS & CALKINS, who being duly sworn according to law
deposes and says that he caused to be served upon MICHAEL ALESSANDRONI,
, ,
Defendant, a copy of the Complaint for No Fault Divorce by causing a copy of
said Complaint to be placed in the mails of the United States, as per
Pa.R.C.P. 440, addressed to 123 Pearl Drive, Carlisle, PA 17013, service being
effectuated on said Defendant on January 23, 2001, as evidenced by a copy of
the Return of Service attached hereto.
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BY:
P T OS, ESQUIRE
Attorn y fo Plaintiff
supreme Co t I.D. # 07475
110 South orthern Way
York, Pennsylvania 17402
Telephone: (717) 757~7602
SUBSCRI~D to
this I~ day
., 200-'--.
ItG
Notarial Seal
Dawn M. Kessler, Notary Public
Sprlngettsbury Twp" York County
My Commission Expires Oct. 13, 2003
Member, PennsylvaniaAssoclationofNotartas
*Compieie~ .,r;;~1;?,"arid3.'AiS;;bt;;;:;p(at;"
ilem 4 if R~cted Delivery is desired.
IIIIl , Print your ntt~e_ .and add~ss _on, the reverse
SO thatwecei.o.-ret'urlJ_the,_c!ird_tQ. you. " '
II Attach IhiS,Q~td II) the bacJ< ,,!the mailpiece,
_Qr_on--the ftoNt If spa_ce'p,ermlts.
1. Artlcle'AddrE!issed to:
ltntL. (.f)t.I.lyhdaJJiM~tlit.L
/152.-3' Lf~~
~&) Lff/ /'90/3
3. Service Type
~eitified Mail 0 Express Mail
CJ Registered d ~eturn Re~ipt for Merchandise
o Insured M~lI D_ C.O.D.
4. Restricted Delivery? (Extra Fee)
2. Article Number (Copy from service label)
7d.'1lfl \ i31l::1oi t!ocb 91 : (9 i~(O i\ iSjt!oi
PS Form 3811 , July 1999 Domestic Return,Receipt
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CHERYL ALESSANDRONI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: September 4, 2001
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/~ MICHAEL ALESSANDRONI
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CHERYL ALESSANDRONI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 16, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: September 4, 2001
~~->-Q:.
MICHAEL ALESSANDRONI
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CHERYL ALESSANDRONI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final Decree of 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 inunediately 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: September 4, 2001
~Cd-:
MICHAEL ALESSANDRONI
Defendant
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CHERYL ALESSANDRONI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 16,2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: September I~
,2001
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CHERYL ALESSANDRONI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 inunediately 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: September ~, 2001
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CHERYL ALESSANDRONI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: September Jl, 2001
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CHERYL ALESSANDRONI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-290 CIVIL TERM
MICHAEL ALESSANDRONI,
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:
I. Ground for Divorce: irretrievable breakdown under Section 330 I (c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Michael Alessandroni, on January 23, 2001, by certified, restricted delivery mail, addressed to him at
123 Pearl Drive, Carlisle, Pennsylvania 17013, with Return Receipt Number 7099 3400 0007 0726 2336.
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: September 14,2001; bydefendant: September4,2001.
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintift's affidavit upon the defendant:
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 plaintift's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: September 25, 2001.
Prothonotary:
Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
September 6, 2001. ~ ~
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REBECCA R. HUG S, UIRE
Attorney for Defendant
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE P ARIlES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: September 25, 2001
DOCKET NUMBER: 2001-290 Civil Term
PLAINTIFF~SS# 178-58-3866
NAME: CHERYL L. ALESSANDRONI
DEFENDANT~ SS # 592-24-4684
NAME: MICHAEL C. ALESSANDRONI
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