The URL can be used to link to this page

Home My WebLink About07-1913Denise Salisbury, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW James Salisbury II, No. 0`7 - I 1 13 CIVIL Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 Court House, High and Hanover Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Denise Salisbury, Plaintiff V. James Salisbury II, Defendant CIVIL ACTION - LAW No. 67 - 19 13 CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) & 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Denise Salisbury, an adult individual, who resides at 9 Bellaire Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is James Salisbury, II, an adult individual, who resides at 3 Woodland Drive, Newville, Cumberland County, Pennsylvania 17241 3. Plaintiff is a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 24, 2005 in Carlisle, Cumberland County Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: Respectfully submitted, ROMINGER & WHARE Supreme Court I.D. # 200198 Attorney for Plaintiff Ilgalie A. Tomeo, E?quire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Denise Salisbury, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW James Salisbury II, No. CIVIL Defendant IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date: 7` LSO 7 Denise Salis Plaintiff Denise Salisbury, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW James Salisbury II, No. CIVIL Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: James Salisbury, II 3 Woodland Drive Newville, Pa 17241 Dated: p Le§46 A. Tomeo, E quire 155 South Hanover treet Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff ZT LA) 00 ^\ co C d 6 ,i 7-" Denise Salisbury, Plaintiff V. James Salisbury II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-1913 CIVIL IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Denise Salisbury, Plaintiff, moves the Court to appoint a Master with respect to the following claims: (x) Divorce (x) Distribution of Property ( ) Annulment ( ) Support ( ) Alimony (x) Counsel Fees ( ) Alimony Pendente Lite (x) Costs and Expenses and in support of the Motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Plaintiff has appeared in the action by her attorney, Michael O. Palermo, Jr., Esquire. 3. The statutory ground(s) for divorce are irreconcilable differences. 4. Delete the inapplicable paragraph(s): The action is contested with respect to the following claims: Distribution of property. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. 7. Additional information, if any, relevant to the Motion: None Date: A 1. 2 k AAA. Michael O. Palermo, squire Attorney for Plaintiff 3 0 N t ON it Denise Salisbury, Plaintiff V. James Salisbury 11, Defendant 1JUL 0 3 200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-1913 CIVIL IN DIVORCE ORDER APPOINTING MASTER AND NOW, this day of Qx4? '2008, E. Robert Elicker, II, Esquire, is appointed Master with respect to the following claims: 1. Divorce. 2. Distribution of property. 3. Counsel fees. 4. Costs and Expenses. Distribution: Xlchael O. Palermo, Jr., Esquire /mes Salisbury, II pro se y By the Court: ano-e ? a t??461. J. ..,.., ,? ?,,? ?' _. , ? ?? ?? ?.- `. t ?: ?v V Denise Salisbury, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW James Salisbury II, 07-1913 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 9, 2007 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 unsworn falsification to authorities. Date: 0S ?- ames Salisbury, II/Defendant c?? "t'i ---# ?e f ? 3^" ,. ?? i ^ ? ..-«. ? ? ? ? Denise Salisbury, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW James Salisbury II, 07-1913 CIVIL Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 unworn falsification to authorities. Date: rte- „' C S -? James Salisbury, II, Defendant ?r C?' TM;7 Gn Denise Salisbury, IN THE COURT OF COMMON Plaintiff CUMBERLAND COUNTY, PE V. : CIVIL ACTION - LAW James Salisbury II, 07-1913 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code 'y 9, 2007 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and PLEAS OF NSYLVANIA filed on April (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notic 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, r4ating to unworn falsification to authorities. Date: Denise SalisbwY/Plainti S i'l '_ 2009 JUN 25 H-1 J: 19 Denise Salisbury, IN THE COURT OF COMMO PLEAS OF Plaintiff CUMBERLAND COUNTY, PE SYLVANIA V. CIVIL ACTION - LAW James Salisbury II, 07-1913 CIVIL Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. 1 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 ?y the Court and that a copy of the decree will be sent to me immediately after it is filed with the I verify that the statements made in this Affidavit are true and correct. I statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to i to authorities. Date: ?s/ (J V that false falsification Denise ' S ?? L V? ?c?k.? t y? . A } CUR r , . DEN=S'? SALISBURY, Plaintiff Vs. JAMES SALISBURY, Defendant. IN THE COUNT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - __913 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this day of , 2012, no economic claims having been raised y either party, and both parties having signed affidavits of consent and waivers of notice of intention to request entry of divorce decree, the divorce can conclude under Section 3301(c) of the Domestic Relations Code. The appointment of the Master is vacated and counsel and the parties can file a praecipe tranSITLitting the record to the Court requesting a final decree in divorce. BY THE COURT, _ ;?A- 11" KeVOA? A. Hess, P. J. cc: y` Michael 0. Palermo, Jr. Attorney for Plaintiff" rrt crs -rZ _,r rr r; James Salisbury _nr 71 7- Defendant jed :2 DENISE SALISBURY, Plaintiff V. JAMES SALISBURY, II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-1913 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE --D :x xM :r C'n Y' Q_ 7 .yami r--1 c? w yam. C.0 {.a CD L) ACCEPTANCE OF SERVICE AND NOW, this 6th day of July, 2007 I, James Salisbury, II accept service of the Divorce Complaint in the above-captioned case. James Salisbury, 11 DENISE SALISBURY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW M { Y ; r-1 ?S::6 r" C-) r. JAMES SALISBURY, II, NO. 07-1913y Defendant IN DIVORCE `. '' PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed acceptance of service on July 6, 2007. 3. (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 on June 25, 2009; and Defendant on February 20, 2009. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: None served as the parties signed the Waiver of Notice. Defendant on February 20, 2009 and Plaintiff on June 25, 2009. Respectfully submitted, Mich*Xchherer, Esquire