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HomeMy WebLinkAbout01-5939Rebecca J. Giordano Plaintiff SS#180-62-2451 V. Anthony M. Giordano, Defendant SS# 183-60~3579 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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, PA 17013 (717) 24~9-3166 James A. ~ler, Esquire Attorne,,y,,,fOr Plaintiff Rebecca J. Giordano Plaintiff SS#180-62-2451 V. Anthony M. Giordano, Defendant SS# 183-60-3579 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O, CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Rebecca J. Giordano, who currently resides at 521B Reno Avenue, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant is Anthony M. Giordano, whos last known address was 15 S. Baltimore Street, Mt. Holly Springs, PA 17065, Cumberland County, Pennsylvania, 17065. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on Septeber 30, 2000, in Lancaster County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. 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. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 OF THE DIVORCE CODI= 10. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 11. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree dissolving the marriage between Plaintiff and Defendant. Respectfully Submitted, James A. Attorney for ~laintiff 2010 Mark~ Street Camp ~, Pennsylvania 17011 (7,~.,)~737-6400 VITAL RECORDS RECORD OF DIVORCE OR ANNULMENT [~ (CHECK ONE) m~ HUSBAND NAME. N~ E~ ~qF rFi~-$Ij ~/~Midd/e/ & l~lLast/ 2 DATEoF BIRTH WIFE Husband's social security number: Wife's social security number: / 45 ~o ?~'-Z~ / g'ry ~,~ ~/ VERIFICATION I verify that the statements made in the attached 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: LAW OFFICE OF RICHARD GAFFNEY Plaintiff JON P. SUNDELL Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : : 00-5939 CIVIL TERM : : CIVIL JUDGMENT SA TISFA CTION TO THE PROTHONOTARY OF SAID COURT: You are hereby notified to mark the judgment in the above-captioned matter which was entered against Jon P. Sundell and in favor of Law Office of Richard Gaffney as satisfied. Date: [41~.t'~' Charles Rector, Esquire 1104 Femwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Attorney for Plaintiff ~ r~ ;'~:r~ r n REBECCA J. GIORDANO, Plaintiff ANTHONY M. GIORDANO, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW :IN DIVORCE :NO. 01-5939 NOTICE OF INTENTION TO RETAKE PRIOR NAME Notice is hereby given that the Plaintiff in the above-captioned matter, a Final Decree in Divorce having not yet been granted, hereby elects to retake and use her previous name of Rebecca J. Hardy and gives written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. §704. R'eb":ecca J. Gior~an To be Known as: Rebecca J.~H~Y~ COMMONWEALTH OF PENNSYLVANIA ) )ss: COUNTY OF "~P~ ) On the ~ddayof ~~/~ ,2002, beforeme, a Notary Public, personally appe~ed ~BECCA J. GIO~ANO, now ~o~ ~ ~BECCA J. HAZY, ~own to me or satisfactorily proven to be the person whose n~e is subscribed to the within doc~ent ~d ac~owledged that she executed the foregoing for ~e p~ose therein contained· ~ WI~ESS WHE~OF, I have set my h~d ~eal. ] ~44:~,~,', >- ~ .. '% PA ~ ' ~'q6~., ".~'~*'M~ ~,r.~.~,;~ E,~, ,~, ~ ;~. ~'~ .~' 12, 2005 [ i REBECCA J. GIORDANO, Plaintiff Vo ANTHONY M. GIORDANO, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : IN DIVORCE : :NO. 01-5939 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 15, 2002. 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 the decree. 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 unswom falsification to authorities. Dated: i-ii{, 0-~ ,~.~[/~ '~ ~//~ P~nthe~ny~. Giordani~~'~ REBECCA J. GIORDANO, Plaintiff ANTHONY M. GIORDANO, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW · IN DIVORCE :NO. 01-5939 WAIVER OF NOTICE OF INTENTION TO REQUEST 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 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· i.lq, o5 Dated: Afithony 1V~.j~ordano REBECCA J. GIORDANO, Plaintiff Vo ANTHONY M. GIORDANO, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : :CIVIL ACTION - LAW : IN DIVORCE : :NO. 01-5939 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 15, 2002. 2. The marriage of plaintiff and defendant is inretrievably 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 diw~rce after service of notice of intention to request entry of the decree. 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 unswom falsification to authorities. Dated: Rebecca J. GioCano I REBECCA J. GIORDANO, Plaintiff Vo ANTHONY M. GIORDANO, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW · IN DIVORCE :NO. 01-5939 WAIVER OF NOTICE OF INTENTION TO REQUEST 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 ifI 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 tree 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. Rebecca J. Gior/:Jano t Affidavit of rocess Server _ o (NAME~ ~ ~ ~ ~ ~ C~E ~ I declare that I am a cilizen of the Uniled States, over the age off eighteen and not a pa~y to this action. And that within the boundaries of the s'a'e where service was ef~ted,~as au~ by~ t;2;orm said series. Se~Jce: I se~ed ~m sa~d se~ice. ~ME OF PER~ with the {documents) WO/'~ /~ ~ t~ on _ / -/y-o I DATE at ~ ~ TIME ~ Thereafter copies of the dOCuments were mail~ by prepaid, fi~t class mail on trom DATE [] Moved, Left no Forwarding ri Olher: [] Address Does Not Exist [] Service Cancelled by Litigant C] Unable to Serve In · Timely Fashion Service Attempts: Service was attempted on: ( ) _ ( )_ DATE -- - TIME ' ( ) ~ DATE DATE TIME -- * ( ) -- DAT~--~ " 'r II~IE ' ( ) -- CITY STATE Manner of Service: c] Ry personally delivering copies to the person/authorized agent of entity being served. Charge thereof. [] By leaving, during office hours, copies at the office of the person/entity being served, leaving same with the person apparenlty in [] By leaving copies at the dwelling house or usual place of abode of the person being served, with a meT bet of the hous&hold or older and explaining the general nature of the papers. "' 18 D By posting copies in a conspicuous manner to the address of the person/entity being served. Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above. I have been unable to effect process upon the person/entity being served because of the following reason(s): D Unknown at Address [] Evading TIME -- DATE - ?~E -- -- Description. Age: Sex: Race: Hgt: Wgt: Hair: Glasses: ! declare under Denalty of perjury that the informati . //- ,,~ ~O_ ~.~ C.~ .,,~ ,~__. ~ti~c~talned herein is true and Correct and this affidavit was executed on DATE CITy ~ ' ~ ~ STATE State of /~ County of subscribed and SWorn before me. a notary public Ibis WITNESS MY HAND AND OFFICIAL SEAL TO NOTARIAL SEAL ~ristie L Underkoffler, Publ / No~J*y ¢ amp Hdl Bom, Cumberland County __Commission Explrea June 24, 200ej REBECCA j. GIORDANO, Plaintiff V. ANTHONY M. GIORDANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : IN DIVORCE : : NO. 01-5939 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the fo/lowing information, to the Court for the entry ora Decree of Divorce. 1. Ground for divorce: irretrievable breakdown of the marriage under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Anthony M. Giordano, on November 14, 2001, by personal service. 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiffon January 17, 2003; by defendant on January 14, 2003. 4. Related claims pending: No economic claims raised. 5. (a) Date ofplaintiWs filed on January 21, 2003. Waiver of Notice: January ! 7, 2003, and it was (b) Date of defendant's Waiver of Notice: January 14, 2003, and it was filed on January 2 l, 2003. of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box ! 1998 Harrisburg, PA 17108 (717)233-7691 Respectfully submitted, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~,~ PENNA. REBECCA j. GIORDANO VERSus ANTHONY M. GZORDANO ~0. 5939 2001 DECREE IN DIVORCE IT IS ORDERED AND DECREED THAT __-P~_.~ J. GZOi~)/3A.~) , PLAINTIFF, AND -~i"4"I~ONY' M. GZOPJAZLNO , 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; ATTEST: