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Home My WebLink About03-1935AMANDA LEE LOMBARDO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. · CIVIL TERM DAVID MICHAEL LOMBARDO,: DIVORCE Defendant : 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 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 County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 AMANDA LEE LOMBARDO, Plaintiff VS. DAVID MICHAEL LOMBARDO, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03- I'~,JS"' CIVIL TERM · DIVORCE 5. parties. COMPLAINT IN DIVORCE COUNT I - NO FAULT 1. Plaintiff is Amanda Lee Lombardo, an adult individual currently residing at 129 Marbeth Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is David Michael Lombardo, an adult individual currently residing at 401 Ridge Avenue, Apartment 21 l, York, York County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. Plaintiff and Defendant were married June 23, 2000 in Mt. Holly, Pennsylvania. There have been no other prior actions for divorce or annulment between the 6. Neither Plaintiff nor Defendant is a member of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. The parties' marriage is irretrievably broken. 9. Plaintiff desires a divorce based upon the belief that Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P. S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Margaret M. Simok Attorney for the Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 VERIFICATION The above named Plaintiff, Amanda Lee Lombardo, verifies that the statements made in the above ~n are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: c/-O.,S -O~3 Amanda Lee Lombardo AMANDA LEE LOMBARDO, : 1N THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. · No. 03 - ~ CIVIL TERM : DAVID MICHAEL LOMBARDO,: DIVORCE Defendant : PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Christina Marie Tavema, Plaintiff, to proceed in forma pauperis. I, Margaret M. Simok, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay costs and that I am providing free legal service to the party. Margar6~ M. Simok Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 AMANDA LEE LOMBARDO, Plaintiff VS. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 - 1935 CIVIL TERM DAVID MICHAEL LOMBARDO,. DIVORCE Defendant · PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Amanda Lee Lombardo, Plaintiff, to proceed in forma pauperis. I, Margaret M. Simok, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay costs and that I am providing free legal service to the party. ~Mm:ga~t M. Simok Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 AMANDA LEE LOMBARDO, Plaintiff VS. · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 - 1935 CIVIL TERM DAVID MICHAEL LOMBARDO,: DIVORCE Defendant · NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, having filed a complaint for divorce on the twenty-fifth day of April, 2003, hereby intends to resume and thereafter use the previous name of Amanda Lee Miller and gives written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, as amended November 22,200, P.L. 689, No. 92 § 1, 54 P. S. Section 704 (effective January 22, 2001 .) COMMONWEALTH OF PBNNSYLV~ 1 COUNTY OF CIJI~~ J ' a ? JUDITH D. ~U~, ~ P~ I My C0mmi~lm ~~ 10, ~ 1 Signature of Petitioner Amanda Lee Lombardo TO BE KNOWN AS: Signature - Intended Amanda Lee Miller Amanda Lee Lombardo : Plaintiff : Vs. : David Michael Lombardo : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1935 Defendant · IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE BY MAIL I, Margaret Mary Simok, do hereby swear that I served David Michael Lombardo with a Complaint in Divorce under Section 3301 (c) of the Divorce Code pursuant to Pa.R.C.P. 1920.42(a)(2) on the 28th day of April, 2003, by certified mail, return receipt, to the person and address below: David Michael Lombardo 401 Ridge Avenue Apartment One York, Pennsylvania 17403 I, Margaret M. Simok verify that the statements made in this Affidavit of Service 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: .&~ '/o - 0 ~ Signature: ~ l'arx ~'~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 2. Article Number IIA. Signature / X ~ /"--~-'~ [] Agent 11 O. Is ~iv~ a~ di~t ~ ~ 17 B Yes _~No 3.. ~wice Ty~ ~ ~ J ~ste~ ~ Return R~eipt for Memhandi~ ~ ~ Insu~ M~I ~ C.O.D. ' J4. R~tHct~ Deliver? (~m F~) ~ y~ PS Form 3811, August 2001 Don-,,e~t;c Return Receipt 102595-02-M-103~ Amanda Lee Lombardo, Plaintiff VS. David Michael Lombardo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU?~rY PENNSYLVANIA No. 03- 1935 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A comphfint in divorce under §3301(c) of the Divorce Code was filed on April 25, 2003. 2. The marriage ofplaintiffand defendant is irretrievably broken, and ninety days have elapsed fi'om the date of filing and 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 divorce. 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 attthorities. Amanda Lee Lombardo, Plaintiff Amanda Lee Lombardo, Plaintiff VS. David Michael Lombardo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03- 1935 Civil TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 25, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and 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 divorce. I verify that the statements made in this affidavit are tree 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: ~)/;~°'"-/°~' Signature:]~c~ ){~,t/e~ttt,0~ Z~.~At~ 'l~avid M~ichael'!£ombardo, De-fendaritr Amanda Lee Lombardo, Plaintiff VS. David Michael Lombardo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03- 1935 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIvORCE DECREE UNDER §330 l(c) OF 'rile DIVORCE CODE I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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 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:~3 Amandi L~ r0~h~"~ao, ~fainti~f Amanda Lee Lombardo, Plaintiff VS. David Michael Lombardo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'rY PENNSYLVANIA No. 03- 1935 C1VILTERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF 'ritE DIVORCE CODE I consent to the entry ora final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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 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. David Michael Lombardo, Defendant Amanda Lee Lombardo, Plaintiff VS. David Michael Lombardo~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03- 1935 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECOR[} To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divome decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and Manner of service of the Complaint: Complaint was sent by certified mail, restricted delivery, return receipt requested on April 25, 2003. The defendant received the complaint and signed the return receipt acknowledging he had received the complaint on April 28, 2003. 2. 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, August 12, 2003; by Defendant, August 25, 2003. (b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) Date of filing and service of Plaintiff's Affidavit upon Defendant: N/A 3. Related claims pending: There are no outstanding claim~. 4. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intentiort to file Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September 4, 2003. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Se tember 4 2003. Plaintiff's Social Security Number: 198-60-9158 Defendant's Social Security Number: 198-62-4369 Attorney fc,r Plaintiff MidPerm Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 IN THE COURT OF AMANDA LEE LOMBARDO COM NON PLEAS PENNA. OF CUMBERLAND COUNTY STATE OF ~ PLATNTIFF VERSUS DAVID MICHAEL LOMBARDO N o. 03-1935 CIVIL DEFENDANT DECREE IN DIVORCE AND NOW,~ t~ ~% ~: " IT IS ORDERED DECREED THAT AMANDA LEE LOMBARDO , PLAINTIFF, AND DAVID MICHAEL LOMBARDO ,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; ALL CLAIMS HAVE BEEN RESOLVED. ~h