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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
SUSAN LANG FRIDIRICI,
Plaintiff
No. 2001-569
VERSUS
CURTIS THEOOORE FRIDIRICI.
Defendant
DECREE IN
DIVORCE
AND NOW,
~ '>0
2001 ,IT IS ORDERED AND
DECREED THAT
, PLAINTIFF,
SUSAN LANG FRInrRT~T
AND
CURTIS THEODORE FRIDIRICI
, 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.
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SUSAN LANG FRIDIRICI, : IN THE COURT OF COMMON PLEAS OF
plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . 2001- .s&,? CIVIL TERM
.
:
CURTIS THEODORE FRIDIRICI, :
Defendant . IN DIVORCE
.
NOl'ICE 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 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:
CUMBERLAND OOONTY CXXlRT HOUSE, 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
TOLL FREE: 1-800-990-9108
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SUSAN LANG FRIDIRICI, : IN THE OOURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs. . 2001- 5-"" CIVIL TERM
.
.
.
CURTIS THEODORE FRIDIRICI, :
Defendant : IN DIVORCE
c:xm>LAINT
Plaintiff, Susan Lang Fridirici, by her attorney, Dawn S. Sunday
sets forth the following:
1. Plaintiff is SUsan Lang Fridirici, who currently resides at
820 S. York Street, Mechanicburg, Cumberland County, Pennsylvania.
2. Defendant is Curtis Theodore Fridirici, who currently resides
at 1623 N. 3rd Street, Harrisburg, Dauphin County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth for at least six months immediately preceding the filing of
this COmplaint.
4. plaintiff and Defendant were married on May 14, 1988, in
Monmouth County, New Jersey.
5. There have been no prior actions for divorce or for annulment
between the parties.
6. Plaintiff avers, as the grounds upon which this action is
based, that the marriage between the parties is irretrievably broken.
7. Plaintiff has 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.
8. Plaintiff requests that the Court enter a Decree of Divorce
under Section 3301(c) or 3301(d) of the Pa. Divorce Code.
Respectfully Submitted,
Dawn~orr
Attorney for Plaintiff
III #41954
39 West Main Street
Mechanicsburg, PA 17055
(717) 766-9622
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VERIFICATION
I verify that the statements made in the foregoing Complaint are
true and correct. I understand that false statements herein are subject to
the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to
authorities.
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01 JP-N 26 P1i 4: 22
CUMBERLi~\JD COUN1Y
PENNSYL\I,<\NIA
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SUSAN LANG FRIDIRICI, : IN THE COURT OF COMMON PLEAS OF
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. : 2001-569 CIVIL TERM
:
CURTIS THEODORE FRIDIRICI, .
.
Defendant : IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint.
DATE
"2. { OS/Ol
C.~T~
Curtis Theodore Fridirici
1623 N. 3rd Street
Harrisburg, PA 17102
.-.- ,-.
1'.",
SUSAN LANG FRIDIRICI, : IN THE OOURT OF OOMMOO PLEAS OF
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . 2001-569 CIVIL TERM
.
.
.
CURTIS THEODORE FRIDIRICI, :
Defendant : IN DIVORCE
AFFIDAVIT OF CXX!iISENT
1. A Complaint in Divorce under ~3301(c) of the Divorce Code was
filed on January 26, 2001 and served on February 5, 2001.
2. The marriage of plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of service of the
Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer I s fees or expenses if I do not claim them
before a divorce is granted.
I verify that the statements made in the 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.
5 - IS - 0/
Date
~XUV~~
Susan L g F 1r1C1, a1n 1
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SUSAN LANG FRIDIRICI, : IN THE CXlURT OF CXlMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . 2001-569 CIVIL TERM
.
.
.
CURTIS THEODORE FRIDIRICI, .
.
Defendant : IN DIVORCE
WAIVER OF NOrlCE OF INTENTION TO ~
ENTRY OF A DIVORCE DECREE UNDER
i3301(c) OF THE DIVORCE CXDE
1. I consent to the entry of a final decree of divorce wi thout
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 ~othonotary.
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 unswqrn falsification to
authori ties.
5-/5 -01
Date
'~~~f
Susan Lang ~r~c~, P a~n ~
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SUSAN LANG FRIDIRICI, . IN THE CXlORT OF CXlMMON PLEAS OF
.
Plaintiff : CUMBERLAND CXlUNTY, PENNSYLVANIA
.
.
vs. . 2001-569 CIVIL TERM
.
.
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CURTIS THEODORE FRIDIRICI, :
Defendant . IN DIVORCE
.
PRAEX:IPE ro TRANSMIT RECXlRD
To the Prothonotary:
please transmit the record, together with the following information,
to the Court for entry of a Divorce Decree:
1. Ground for divorce: Irretrievable breakdown under ~330l(c) of the
Divorce Code.
2. Date and manner of service of the Complaint:
Acceptance of Service signed by Defendant on February 5, 2001 (attached
for filing).
3. Dates of execution and filing of the Affidavits of Consent and
waivers of Notice required by ~3303l(c) of the Divorce Code:
By Plaintiff: Signed May 15, 2001, enclosed for filing.
By Defendant: Signed May 16, 2001, enclosed for filing.
4. Related claims pending: NONE
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Attorney for Plaintiff
ID #41954
39 W. Main Street - Ste. #1
Mechanicsburg, PA 17055-6230
(717) 766-9622
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SUSAN LANG FRIDIRICI, : IN THE OJURT OF OJMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : 2001-569 CIVIL TERM
:
CURTIS THEODORE FRIDIRICI, .
.
Defendant : IN DIVORCE
AFFIDAVIT OF CCI\ISENT
1. A COmplaint in Divorce under ~3301(c) of the Divorce Code was
filed on January 26, 2001 and served on February 5, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of service of the
Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
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 the 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
authori ties.
Date
5/lfp to I
C:1U--~
Curtis Theodore Fridirici, Defendant
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SUSAN LANG FRIDIRICI, : IN THE OOURT OF OOMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. . 2001-569 CIVIL TERM
.
.
.
CURTIS THEODORE FRIDIRICI, :
Defendant . IN DIVORCE
.
WAIVER OF NOTICE OF INTENTICIII TO REQUEST
E!iITRY OF A DIVOOCE DECREE ONDER
~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 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. ~4904 relating to unsworn falsification to
authorities.
,. fib/or
C-~F~
Curtis Theodore Fridirici, Defendant
Date
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PENNSYLVr\NIA
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