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Home My WebLink About01-2035 FX " LEONARD A. ARNABOLDI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.O I, ;;lDJ-S CIVIL NANCY ARNABOLDI, 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 fOllowing pages, you must take prompt action. You are warned that if you fail to do so the case 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, CuriJberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE ~ DIVORCE AR ~MENT 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ';l;_. ,,'"',-- ~ "1'"' ,_,_eo" , ~"~~-"~ LEONARD A. ARNABOLDI Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. I!) J- ;2.030' Ci vil NANCY ARNABOLDI Defendant IN DIVORCE COMPLAINT AND NOW comes Plaintiff, by his attorney, Kent H. Patterson, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, Leonard A. Arnaboldi, is an adult individual residing at 295 Sled Drive, Apt# 2, Sher.mans Dale, Perry County, Pennsylvania 17090. 2. Defendant, Nancy Arnaboldi, is an adult individual residing at 115 Hillside Road, Silver Spring Township, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been a bona fide resident in the COIl1Illonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 20, 1973 in Yonkers, New York. 5. There have been no prior actions for divorce or annulment between the parties. ;:'~~~~,,, , "I-.f"-I _' Y --~I r~ . . -~" ~~T . ~'"._--~ " 6. Plaintiff and Defendant are both citizens of the United States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plain~iff and Defendant and such further relief as the Court may determine equitable and just. ~//~ . Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 ,-if1l~_"~"", ,. - I' ~ "C'- f_l,- ~-- ,.~ ."",",'" ~~ . VERIFICATION I, Leonard A. Arnaboldi, verify that the statements in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~pafild~ eo ard A. Arnaboldi 1/- 0~ .;leol Date "~-~I, ,.",", . , -~ " -, T r,'",,-- , ,- . ~ 1- "1_', ,. . l - ,~ ~ ~,~--""'-~ ~ !~ ~ FF, ~ ~ "'"" ~. ^ ~~.,,~' '"'_v_ ",_~,,, "~ ~_ ~ ?9 Q "- "S f a ~ h~ 1'. ~ n .- I 9 C5 6 D ~ '-....J ~ ~V) r-- ~ J ~ r-n ~;;:--- u)~" r:::i~~ ,-- ~:~:' >~ ......:::... :~ ""No"'''''''. "'~" . -',""" ~'-1 -.I -@ G\ . , ~J ::::1 :~ ~ ,:.,) ,.i::- - Ifrm_.~"1&!i!l! , ~,,~IiI'!l"""""~-~~'''r''" ~~,~ ~..._;trw""P1!f~!;;'"~~_".-<;>:,1",~""'U;,!jl\"!'-;:_~!IV';Il!l"".,N.r:1iI!I~@1IW'!~~.._~~.; " ... .. . , .. . . . . LEONARD A. ARNABOLDI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-2035 CIVIL NANCY ARNABOLDI, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Kent H. Patterson, attorney for Plaintiff, hereby certify that I served Defendant with the Complaint in Divorce on April 10, 2001 by mailing a copy of same by U.S. Certified Mail, postage paid, addressed to Defendant as follows: Nancy Arnaboldi 115 Hillside Road Mechanicsburg, PA 17050 Attached hereto is the sender's receipt and the return receipt card which is signed by Nancy Arnaboldi and indicates a date of delivery of April 16, 2001. /L--.fIR~ Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 SI\, "" r ~I ,- " c ~. " ~ .. .., .. . ., . . , LEONARD A. ARNABOLDI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-2035 CIVIL NANCY ARNABOLDI, Defendant IN DIVORCE ~ IT' n- r'- .JJ 1lECHAIl1CS8UR6 PA 1705$ Postage $ tG.55 "'"" r'- .JJ I"TJ Certified Fee . '> ...D i,1 Return Rec:eiptFee n (Endorsement Required) Cl Restricted Delivery Fee Cl '~Endorsement Required) o o "'"" FT1 Total Postage & Fees n- n- O r'- ~. SENDER: .g . Complete items 1 and/or 2 for additional services. "iii . Complete items 3, 4a, and 4b. CD . Print your name and address on the reverse of this fonn so that we can return this I! card to you. ~ . Attach this form to the front of the rnailpiece, or on the back if space does not ! permit . Write "Return Receipt Requested" on the mailpiece below the article number. CD . The Retum \:l,eceipt will soo.w te whom the article was delivered and the date :5 delivered. S 3. Article Addressed to: " I'm Yrk.c.I-ruUc.s r also wish to receive the following services (for an extra fee): 1. 0 Addressee's Address 2.. Restricted Delivery Consult postmaster for fee. 4a. Article Number .. 4b. Service Type D Regislered D.~ail ~iptfor Merchandise livery .'t?~ 'FA "," 's Address (Only if requested and tee is paid) I( Certified D Insured DCOD 102595.9'"',0229 Domestic Return Receipt ,."."" , I ,- ... . . . <Ii " .~ " '" Q. 'Iii " " II: ,~'?' " " a; II: ,..'S') 'C 'Uj " - oS! " g, .lC C .. J:: I- t ~~~. - " ~b ~" , , .~-- (") C"" 8 , ~~ I-! , -uri.") :,,:"'" nif;--i ,..< ._~- ;,:;::: :(" L:'" r , ;-;-: '-' en ;2:~ 'lD .-L. -< ~ c; - "-.I .''0 T; ,- ):."'/~' , C) ~i~~ (_=')IT1 ':::-=-1 :2: ~ .--i Cl .-<~ -- .r?"" '<"'" .'-c-' ~",-.'""".' ='1 ~ ~_n;1fJI~Ill,H Utili..'""" _~!!!!l~f'l~~~ImtliI!~lli~~'fflF.~~~!lf1!lJ ~~ \ ~~, LEONARD A. ARNABOLDI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-2035 CIVIL NANCY ARNABOLDI, Defendant IN DIVORCE PETITION FOR SPECIAL RELIEF TO ENJOIN SALE. TRANSFER. ENCUMBRANCE OR DISSIPATION OF MARITAL ASSETS AND NOW comes Plaintiff, Leonard A. Arnaboldi, by his attorney, Kent H. Patterson, and files this petition as follows: 1. Petitioner is Leonard A. Arnaboldi who is the Plaintiff in this divorce action. 2. Respondent is Nancy Arnaboldi who is the Defendant in this divorce action. 3. Plaintiff and Defendant separated in March 2001 and Plaintiff filed the complaint in divorce on April 6, 2001. 4. Plaintiff and Defendant own marital property consisting of real estate which is titled in joint names and personal property which is titled in individual and joint names or is untitled, including pensions, deferred savings, motor vehicles, bank accounts, household furnishings and other tangible personal property. 1 ,y ___C,_"'_' .,_ '~" vW-, 11 '-I r 5. Since the separation Defendant has been in possession of the marital residence at 115 Hillside Road, Silver Spring Township, Cumberland County and its contents which consist of marital assets and Plaintiff's individual non-marital assets. 6. Plaintiff recently learned that Defendant has been removing and selling many items of household furnishings and tangible personal property but Defendant has refused to disclose the whereabouts of this tangible personal property and to whom and for how much she has sold the tangible personal property. 7. Plaintiff also recently learned that Defendant, on or about July 1, 2001, hired an auctioneer whose identity is unknown to remove all items from the garage which is attached to the house and which consisted of power, hand and hydraulic tools, work benches, industrial steel cabinets, air compressor and other mechanics tools and equipment which are the property of the Plaintiff (both martial and non-marital) and have significant value. 8. Plaintiff further recently learned that Defendant listed the real property at 115 Hillside Road for sale with a realtor and signed Plaintiff's name to the listing agreement without Plaintiff's authorization. 2 9. Section 3323(f) and Section 3S0S(a) of the Divorce Code and Pa R.C.P. 1920.43(a) gives the court equity power to issue injunctions and other orders necessary to protect the interests of the parties and to prevent the removal, dissipation, transfer or encumbrance of real or personal property. WHEREFORE, Plaintiff requests Your Honorable Court to grant the following relief: a. Order that Defendant be enjoined from removing any household furnishings, tools and equipment and other tangible personal property from the premises at 115 Hillside Road, Silver Spring Township, Cumberland County (Mechanicsburg, PA 17050) and from selling, transferring, dissipating or encumbering any household furnishings, tools and equipment and tangible personal property, except upon agreement of the parties or further order of court; and b. Order that Defendant be enjoined from selling, transferring, disposing, dissipating or encumbering any other marital assets of the parties and any of Plaintiff's non-marital assets, except upon agreement of the parties or further order of court; and . 3 "'f~_""<r'" '" <.._ ','0 ~""',_,,_'" , 'n-'_~' , 1- ~ _'r'" 1-- , c. order that Defendant disclose and provide an accounting of all household furnishings, tools and equipment and tangible personal property that she removed or caused to be removed from the premises at 115 Hillside Road, Silver Spring Township, Cumberland County, PA and any other marital and non-marital assets that she has sold, transferred, dissipated or encumbered since March 2001. d. Such other action as the court deems appropriate. ~17~ IKent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 4 '~'.- 'Of ":' '''-' - ^" 'i', -~ 'I r"~-~_- , , - VERIFICATION I,Leonard A. Arnaboldi, verify that the statements in the foregoing petition are true and correct to the best of my knowledge, infor.mation and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~~o~~~ Leonard A. Arnaboldi 7-//- 01 Date if'#~",,""""~. '^ '._".' ,,_~ ,'~" _ - q'-><, -",- , " ~ "- ~~ 'H_ , II il II II I! i I' J II I! E,~dl (i ! " ! I _~ ,_"",><><= ffif_ ~ ,- ~~r ~.-' ~," ~-- -, -"-~ 'k" ~-" """,,,~ -., <-'"."~~ .- .'''' ~ ,,' .,^, >.._ o-~ ,'~' -.~- " ,~~-;~ "., ,. , ' I o C." C' l,' '~-.) {,C ~ ,_~i!Rll!1l""'Il.IU.Q"I!\lIl!'I!!'IIIIM~RmlliWlp\}<WI!!'it!'~'~'"-"i'7!!'-;'!i''oI'''''-io<!<i-"~"'!>1itI,~j!l/!'_~'''!~~ll1@~'!Ii'j;,~(~.'jf''~~'''!'.I!l'ii'l~iC<'!f*1I'tl~lfli LEONARD A. ARNABOLDI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-2035 CIVIL NANCY ARNABOLDI, Defendant IN DIVORCE ORDER AND NOW this ,--rtA day of ~ ,2001, it is ordered a hearing shall be held on the /'7-tIJ day of auF ,2001, the Cumberland that at /0; CfV Q., m. in Court Room No. i of County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, at which time the Court shall consider the Petition for Special Relief to Enjoin Sale, Transfer or Dissipation of Marital Assets filed by Plaintiff. Except upon further order of court or agreement of the parties, Defendant shall not remove any household furnishings, tools and equipment or other items of tangible personal property from the residence at 115 Hillside Road, Silver Spring Township, Cumberland County, PA and shall not otherwise sell, transfer, dissipate or encumber any of said tangible personal property, any other marital assets of the parties and any non-marital assets of Plaintiff. tangible personal property that she has removed from the Defendant shall disclose to Plaintiff all .~ <<~ ~~ ~.D\ V<\,' BY THE COURT: residence at 115 Hillside Road since March 2001. , Ai J. -""F''''''"f''''''"'''' _",,~~ I ;; __", - 1- - I... ~-,~- , "., . ,~ ."~~ ~ ~ ~ - .~,'~ - ~~1 '" ~ ~-~ .. ,,~, ,"- , \//[\'-'J',_ /1_1.",,'11':,,/\1.11'1\ /'-/:\1 i;j-"/ ',.--"./t:::';I'i\~j0 7,;Vn:') .- I " ii/i' /1" mII'!iP' ~1IlII6_ ""'-'<~ .Jgf <,'" "~~~,~~..'l'1!;'il1l1ti!!'f;lS\f~~I!lll\1m!I~_~~!!/I~~~"!\U"", ,,, " . LEONARD A. ARNABOLDI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 01-2035 CIVIL CIVIL ACTION - LAW NANCY ARNABOLDI, Defendant IN DIVORCE ORDER, AND NOW, this 17+h day of August, 2001, this matter having been called for hearing and following meeting with counsel in chambers, it is ordered and directed that neither party hereto shall remove any household furnishings, tools and equipment or other items of tangible personal property from the residence at 115 Hillside Road, Silver Spring Township, Cumberland County, Pennsylvania, nor shall they otherwise sell, transfer, dissipate or encumber any of said tangible personal property, any other marital assets of the parties and any nonmarital assets of either party, except upon further order of court or upon agreement of the parties. This order will reflect that the defendant has provided to the plaintiff by way of auctioneer's receipts an itemization of marital assets previously sold by her. The defendant is directed, further, to provide a listing of items of marital property removed from the residence and their current locations. Defendant shall forthwith retum to the plaintiff an antique hunting rifle, The plaintiff shall be permitted to retrieve the mechanic's tools at a time and place to be mutually agreed upon by the parties. .;) O~,';}\ BY THE COURT, ,;l/J i<'~, _~ ,"":,,,.- __ ^- . c' ",,,., , ,~~~,," f .i , Iii 'III )1 ~~ fi I" 11'? 1!1 I" I,~ I:: :: !~ V!N\fI!l,\S;\IN:/d A 'N...........,- ,.....~" ,"'1' '-'''''''''nJ I ';1), 1 ")',,"1 .;...",'".1,..""1<'1 ,.... 1 ''...\,...-' '-_' ",'( ". .',l~', I 8'1 =21 ~id l. I 5iWI 0 Il,'\"lu"" "...'.. '"'"' "': X") AU" I'J\.~, ,~\,,'\._,,_ _" I..'... .....\.._ 30f::LIO-C/:ll:":! !"',""I" " Ii;) .... ~-, .~~"""",,, ~ ~~W/i:~!~!.'Wil!if~liI!I~~~~~~'t!ifJ. , "i~"""""~~~ Kent H. Patterson, Esquire For the Plaintiff Lindsay Dare Baird, Esquire For the Defendant :rlm -,."' " , 'I~' 'f '" ,- . " c ,- , _ ,_ _ , ^ ~ . ~ ~..~ <.. 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