Loading...
HomeMy WebLinkAbout01-0569 FX - . . . . . . . . . . . . . . . . . . " . ,~ -<,I .,,' ;-", -'.;;,.. - . ",,",,'J.. . &;I''-'~'' _';',~'.1t< "'''_ c-_ , . . . . . ~ ~ ~~ ~ ~~~~~~ ~~~ '" '" :Ii "':Ii . . 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. .. . '" "':Ii '" "'''' '" '" '" '" '" "'''' :Ii;F. "'''' '" "'''':Ii '" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . ~ "'-'- " -~.,~, 53/-tJ( -5:3; 01 ""'" r~ , ,- - -, ~= .~_ ^_ """~',",'="O" M~~;~d4:~ ~ ~ ;6 ajIV'_ . '''':~ "'_"'9;'~p~~,,~_,.l:..,'~""'~:'""":"""~ ., ~"""_'l'!"~~~: -. "'. ,"~--,,-,,, ..'"'-',_.,~: ~ I , . . " -~ '"""",, , ~. . 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 I I' ;," --,< ~'. . 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 I t-- -;. ~" 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. ~ . -, CfJ rILED ""OfFiCE Q,t. ,'crnc'lrwntA.Rv 1 ..', \..'I'~Lj f 01 JP-N 26 P1i 4: 22 CUMBERLi~\JD COUN1Y PENNSYL\I,<\NIA I i I ~ ;j;l ~ ii, ~ ~ " ~ $ :,~ '.' ~ I i ii! .~ @ i. ~ 4'/^lS s-o ~co- )'~ '- <$' /;>6 SO - -PeL 4J.iy C&L '331 fIc:iL /6(. r P7 .-. ""- '...' '" , ~- --'--, - 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 ~ ~ . .,'. ,~ '0' 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 ~ " - =-, ,iii~...~,,",~"oj.~""~~,,-ii6~~....liilfu-hi:~I.1lfJi!.jlW. ~ d _..,~'" - ">",- _I ~ . ~~ " C) C ? fg~ -~;z ~cj :E;c; <<<.:'...(,-, ~c! ~ . .... .,. ~_.i ~=2' --". ~;: -< f,,;. <.,c ;'..') (J1 ~ I" SUSAN LANG FRIDIRICI, . IN THE CXlORT OF CXlMMON PLEAS OF . Plaintiff : CUMBERLAND CXlUNTY, PENNSYLVANIA . . vs. . 2001-569 CIVIL TERM . . . 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 ~ dJ I rlfJo/ ~te 7J ~~ Attorney for Plaintiff ID #41954 39 W. Main Street - Ste. #1 Mechanicsburg, PA 17055-6230 (717) 766-9622 ,.,' ',~ e-,-~_,w""',., OF ,! ,.- fl "~'J 2':' I','j II' 2" ,'j I fl,j 1 ..J <"ill . .~.... CU' '''['' ""Y'l)' /1'( "ti-";-" .;) \.J\iU' 1(' ,\ .\ ",);.....1 ,,_,) d , ..,;~./ I , PENNSYLV/\NIA I i ~ , "I ,~ -~ i ,J I .~ I j 1~ I ,-, ''', -, ~~- ."u,"~.~ "~,,', _,__'.. '<''''''~';-''-I';'''''''":..,~,, 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 " ~_--' ~J -'-i - ~ ~ . .. '-k;-' 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 L! . UF 'i C OJ q,lV ,)~~ v, l I", (._0 JI.'," II'?" "111 . .."'" CU:V:rJUiLJi'iU COUNTY PENNSYLVr\NIA j ~ -~ I ~ ~ ~ II ~ I I I ~ ; 1~