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HomeMy WebLinkAbout99-01991 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 99-1991 CIVIL TERM CIVIL ACTION - LAW LESLIE A, DILILLO, Plaintiff v. JAMES A. DILILLO, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: see Affidavit of Service filed April 14, 1999. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: July 18, 1999; by the Defendant: July 12, 1999. 4. Related pending claims: None. 5. Date of execution of Waiver of Notice of Intention to Request Entry of Divorce Decree under section 3301(c) of the Divorce Code: by the Plaintiff: July 18, 1999; by the Defendant: July 12, 1999. SNELBAKER, BRENNEMAN & SPARE, P,C. LAW OFFices SNE1.BAKER. BRENNEMAN Be SPARE i1!11~ Date: July 21, 1999 By: Attorneys for Plaintiff ..... {: ~ : . -:! ~ , , -.0, ., ~ , _J " (1.: " (~ ,. " :~ , . ,- c . 0) N "I:'>: " '--." ~cJ __.1 'frO ~ :_!C.J... 1.1_ 0', :s 0 ,,~ u LESLIE A. DILILLO, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 1''i'J/ CIVIL TERM CIVIL ACTION - LAW JAMES A, DILILLO, 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 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LAW OFFICES SNEt.8AKER. BRENNEMAN & SPARE SNELBAKER, BRENNEMAN & SPARE, P.C. ~(k~_ Attorneys for Plaintiff By: " WHEREFORE, Plaintiff LESLIE A, DILILLO requests this Court to order equitable distribution of marital property. WHEREFORE, the Plaintiff requests this Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; (b) order equitable distribution of marital property; and (c) order such other relief as this Court deems just and reasonable, ; !. I I , I , I , , SNELBAKER, BRENNEMAN & SPARE, P,C, Date: A/flU...- ~, (191 BY:~~ Ke1th 0, Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Leslie A. DiLillo LAW OFFICES SNELBAKER, BRENNEMAN & SPARE -3- ~ (') \1/." S.ll~) 'l.. ~l' ~\~, ; 'rf-l (:;1';' ~~jU. W'II U"~I' I-'- '~ N <:~ i', :0:: 0.. Ul I Co: O. ct C'l en ~ .-: :,~) ..,. I)",' I') <~ :.... :"');:.1 . " ;'1 ~ ::J. rf: ;) 1"1:Ll ~tu.. a 1~ ~ ~. ... ~ ..." ~~ "~ .~ ~~\'~ ~ .. \~ -~. ',,- '\, "'-\ ~ ~'", \0.- \ ' 'v) ~ \j y, I'; CJ \j\ 1'\ VJ \' \I] - '~ ~ 1- ~ ('\. ~ " '^' ^' ~ \\0 f'. ''\1;. ~~ " 'i' :;i " ";:';t ,if ~b.l J,M "'I '~(" , c',,!:. '''<t~ ^",; ~~ mE-< ..... .... ;~ ..... = ." III ~~ ... 'tl = = u ." QI ... ~ ~ . III ..... Z 0 .-l . QI H ~I -< P< 0 Q ~ -< -< H -< ~ 0' -< H U Z H -< I ~~ Q H U , Q . > LIP:; < , , 1< 0 < '" ::- ~ H~~~ ~ H en -< ~ . o~z en ~ , ZU IH -< f"\ . t. LESLIE A. DILILLO, Plaintiff v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 99-1991 CIVIL TERM CIVIL ACTION - LAW I JAMES A, DILILLO, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 33011CI OF THE DIVORCE CODE 1, A complaint in divorce under Section 3301(C) of the Divorce Code was filed on April 6, 1999, 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. 4. 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. S4904, relating to unsworn falsification to authorities. Date: C/o (If) ,1, IC) q C) j.2-{u IJ ;') ?f-<-.f!.e Leslie A. DiLillo .'- r-J . ~-.: ,- , \'-'; ". , J/:' 0 r " ~ - ( -.. ., : t-," (~j (L. :":.J C) - '>J t.:.... ~\1 c:.'l ;.'::.: --.J ,,':(",5 :::::., ,. -, '::!ri.. t.~. '" ~:; 0 '" c..> LESLIE A, DILILLO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 99-1991 CIVIL TERM CIVIL ACTION - LAW v, JAMES A. DILILLO, Defendant IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330110) 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 ~Iill 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, 4, 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, S 4904 relating to unsworn falsification to authorities. Date: ( IrA f t: f ;gC)9 / I' ;:;. I ! I f ~.!: o. f.:: l.'': "': -5 IJ ~ <- r- ~. (i..-: '..) '. " (.) ,~~ ! c~ 7 '. .- Cl:. '" ....l~.~. /..1.;.. -../, -I .f:;:.-- i:C~i: :::J . ; {~;J " -J ',,'~ U. ..:.:; CT, :;:, 0 en C,) LESLIE A, DILILLO, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 99-1991 CIVIL TERM CIVIL ACTION - LAW JAMES A, DILILLO, Defendant IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(01 OF THE DIVORCE CODE 2. I understand that I may lose rights concerning alimony, 1, I consent to the entry of a final decree of divorce without notice. 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. 4, 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. S 4904 relating to unsworn falsification to authorities. Date: 1/2/91 I , ':t:- A, Z1;6?a: --' James A. OiLillo LAW OFFICES SNELBAKER. BRENNEMAN &: SPARE ~.~ CJ ;... (~.: ~ <c: i'~. 0 ~- -:) L: ~l ::l i :0;: .r~f ". r;j t:1_ , .::1 ; ,- ~... :1 ./) '" _.J. -.1 '-9- u_' :JI1) ==-" ,:in.; --, S 11.. c-. 0 '^ CJ .. LAW OFFICES SNELBAKER. BRENNEMAN 8: SPARE LESLIE A, DILILLO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-1991 CIVIL TERM CIVIL ACTION - LAW v. JAMES A, DILILLO, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND) Keith 0, Brenneman, Esquire, being duly sworn according to law deposes and says: that he is a principal in the law firm of snelbaker, Brenneman & Spare, P. C" being the attorneys for Leslie A. DiLillo, the Plaintiff in the above captioned action in divorce; that on April 6, 1999, he did send to Defendant James A, DiLillo by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for certified Mail No, Z 462 230 589; that both the Complaint and cover letter were duly received by James A. DiLillo, the Defendant herein, as evidenced by the return receipt card for said certified mail dated April 9, 1999; that a copy of the aforementioned cover letter dated April 6, 1999 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B"; and ~.- en L'~ L: '0 ; . 0:J l,~ u " ---. '7.,. 'c , .:;: : '- ~:~ ( " n , , '- ,~ I Ci' __:i u G) (J .-~ . .