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Home My WebLink About99-03958J 2 e N O It) M? 'J VALERIE L. YANNONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW GARY S. YANNONE, NO. 99-3958 CIVIL TERM Defendant IN CUSTODY AFFIDAVIT OF SERVICE 1 confirm that 1 did this day of .Tel 1999, hand deliver a certified and true copy of a Complaint in Divorce and Notice to Defend and Claim Rights, to the Defendant, Gary S. Yannone, at the address of /(; V11, 5T 9/6,A/ .S P LPrz/)16 P P1. 17z?i3 Charles York, Constabl Sworn and subscribed to before me this day of '1999. l / Notary Pu c Notarial Seal Rabin J. Goshorn, Notary Public Carlisle Boro, Cumberland County My Commission Expires Apr. 17, 2003 q ? Ci== W 7 SD 3 fyh Q -) 7\ ? L47 2a v rn °1 U VALERIE L. YANNONE, Plaintiff V. GARY S. YANNONE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW r, n / NO. CIVIL 1999 - 3 V S16 l t'j 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 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 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL EXPENSES DIVORCE PROPERTY, LAWYER'S FEES OR ANNULMENT 1S GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO LAWYER NOT HAVE A CANNOT O O TELEPHONE OFFICE SET FORTH BELOW TO FIND D OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013 (717)249-3166 VALERIE L. YANNONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW I NO. CIVIL 1999 Cl V t l GARY S. YANNONE, Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Valerie L. Yannone, an adult individual whose mailing address is the marital home at 17 Grant Court, Carlisle, Cumberland County, Pennsylvania. However, Plaintiff is in a temporary residence pending the issuance of a Protection from Abuse Order. The temporary address is 1002 West Foxcroft Drive, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Gary S. Yannone, an adult individual whose current residential address is unknown but whose last known mailing address was 17 Grant Court, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediate) prc? ious to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 16, 1996, in Cumberland County, Pennsylvania. 5. A prior Complaint in Divorce was filed by Plaintiff on August 6, 1997, and was docketed in Cumberland County at 1997-04232. A Praccipe to withdraw that Complaint in Divorce was filed on December 18, 1997. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant arc members 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. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the 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). COUNT 11 INDIGNITIES It. Paragraphs I through 10 are incorporated herein by reference as if set forth in their full test. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent and injured spouse, as to make her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests your Honorable Count to enter a divorce pursuant to 23 P.S. Section 3301 (a) (6). COUNT 111 EQUITABLE DISTRIBUTION 13. Paragraphs I through 12 are incorporated herein by reference as if set forth in their full text. 14. Plaintiff and Defendant are joint owners of certain real estate located at 17 Grant Court, Carlisle, Cumberland County, Pennsylvania. 15. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 16. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. COUNT IV ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES, AND EXPENSES 17. Paragraphs I through 16 are incorporated herein by reference as if set forth in their full text. 18. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 19. Plaintiff is without sufficient property and otherwise unable to financially support herself as she is working on only a part time basis. 20. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs, as well as alimony, and alimony pcndentc lite for the Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order of Court requiring Defendant to pay counsel fees, expenses, and costs as well as providing for payment of appropriate alimony and alimony pcndentc lite to Plaintiff. Respectfully submitted, GRIFFIE K ASSOCIATES ll ? 'A Kristen Goddard D scn, Esqurre Attornev for Plaintiff GRIFFIE K ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: !/ &? / lei, VALERIE L. Y I ONE, Plaintiff ?.. i'I ? r ?. I. kii ^ BROUJOS & GILROY, r. C. ATTORNEYS AT LAW ?t F 4 NORTH HANOVER STREET CARLISL ... . E, PENNSYLVANIA 17013 717-243-4574 766-1690 SEP 2 9 799, , E l t VALERIE L. YANNONE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMEBRLAND COUNTY PENNSYLVANIA v : NO. 99-3958 CIVIL TERM GARY S. YANNONE, : IN DIVORCE Defendant : CUSTODY ORDER OF COURT AND NOW, this M day of SCP\embP (- , 1999, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before z\ L, a_, Esquire, the Conciliator, at 5,1` ?. on the ?'& day of K?MTr 1999, at C\; 0(l _ .M., for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute, or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Molirt o r " 1? lf(1F3' Custody Conciliator (1?. 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. 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 conferences or hearing. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 717-249-3166 ?9OCi -I ":I,I,r• C 11 is JlV VALERIE L. YANNONE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMEBRLAND COUNTY PENNSYLVANIA v : NO. 99-3958 CIVIL TERM GARY S. YANNONE, : IN DIVORCE Defendant : CUSTODY CUSTODY COMPLAINT Petitioner, Gary S. Yannone, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: Petitioner is Gary S. Yannone, the Defendant in the above captioned action, and an adult individual residing at 1555 McClure's Gap Road, Carlisle, Pennsylvania. 2 Respondent, Valerie L. Yannone, is the Plaintiff in the above captioned action and an adult individual residing at 17 Grant Court, Carlisle, Pennsylvania. 3 Petitioner and Respondent were married on November 16, 1996. 4 Petitioner and Respondent are the natural parents of Anthony S. Yannone, born November 18, 1998. 5 There is a prior custody order entered involving the parties which was entered at a Protection From Abuse Docket No. 99-3845 in Cumberland County Pennsylvania. A copy of said custody order is attached hereto and marked Exhibit "A" and, pursuant to Paragraph 8 of said Custody Order, is a temporary custody order subject to a permanent order being entered after a Custody Conciliation Conference. 6 Petitioner desires that a formal custody order be entered that would provide as follows: A. The parties would enjoy shared physical custody of the minor child. B. The Mother would enjoy primary physical custody of the minor child. C. Father would enjoy temporary physical custody of the minor child on alternating weekends from Friday when he would pick the child up from daycare until Monday morning when he would return child to daycare. If Monday was a holiday, the child would be returned to daycare on Tuesday morning. Additionally, on the off week, the Father would pick up the child Tuesday evening at daycare and would drop the child off Wednesday morning at daycare. The order would also provide for Father having alternating holidays and extended visitation over Christmas and Thanksgiving holidays with an extended vacation in the summer. WHEREFORE, Petitioner requests your honorable court to enter an order granting the custody rights as set forth above. Respectfully submitted, n H. Broui s, ?sq. Attorney for Defendant Broujos & Gilroy, PD.'_ C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 verify that the statements made in the foregoing document 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 unswom falsification to authorities. Lf DATE: y 2 y` ?_? Gary S. Yanr i:? a uu 474: 7 _ 4' O "ci O Oi ?J VALERIE L. YANNONE, Plaintiff VS. GARY S. YANNONE, Defendant TO: THE PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA CIVIL ACTION - LAW NO. 1999-3958 CIVIL TERM IN DIVORCE On behalf of the Plaintiff, please withdraw and discontinue the above-captioned divorce action. Respectfully submitted, 4Kristenkodda 62 onsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ? ? _ ._ I-. ..?. p.._ - ?' IJJ?-? - , i'' ?` t _ G_ ??. 1.. ,:? i. i ='? - it !; _.. ' n ' ? % ?_ NOV1(; 1 VALERIE L. YANNONE, ) Plaintiff ) VS. ) GARY S. YANNONE, ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3958 CIVIL TERM CIVIL ACTION - CUSTODY ORDER AND NOW this ) ? #' day of //O' " -?-- , 1999, it being reported to the Conciliator that the parties have reached an agreement which makes further proceedings unnecessary, the undersigned Conciliator hereby relinquishes jurisdiction and returns the matter to the Court Administrator. If either of the parties wishes further proceedings in this action, they should petition the Court anew. FOR THE COURT, 7 MICHAEL L. BANGS Custodv Conciliator cc: Kirsten G. Donsen, Esquire Hubert X. Gilroy, Esquire VALERIE L. YANNONE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ' CIVIL ACTION - LAW GARY S. YANNONE, Defendant No. 99-3958 CIVIL TERM ORDER OF COURT AND NOW, this 22nd day of October, 2002, it appearing that docket activity has occurred recently in the above-captioned case, the case is stricken from the purge list, and shall remain active. Kristen G. Donsen, Esquire For the Plaintiff Gary S. Yannone 16 W. High Street Carlisle, PA 17013 Defendant Court Administrator By the Court, J. Wesley Ol-e Jr. wcy J. WESLEY OLER, JR. JUDGE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 for 1 ao a vs`sl°? : Q 3 ,,.. PBN(na 7113460 u. S. POSTrcE ; Gary S. Yannone 16 W. High Street Carlisle, PA 17013 ! t~'J S i' T G 't i 'I ti %! 1!111 1 11111 11!111!! I It t it 11111 11 1!11!! 11111:! 1 t l l i l ilt 111111' 1 .1 // /2/ /02 J?,?9e Qler? loary vro ?o.-,9Er wars 0./ a9E?-,ey, hie res,S?PCB a6ou-f- 7?-G.O years a9a, 1n/? olo1? I zL I-Czve 0. 0- `rrek7f 40,",0 aa`cF-'ess 7?o? /,,-„ , % ?xecuf;ve Q; rec7er ._ VALERIE L. YANNONE.: IN'rI-IE COURTOF COMMON PLEAS OF Plaintiff CUMBERLAND COUN'rY. PENNSYLVANIA V. CIVIL. ACTION - LAW GARY S. YANNONE, Defendant NO. 99-3958 CIVIL'1'L'•RM ORDER OF COUR'r AND NOW, this 25°i day or November, 2002, it appearing that the above- captioned case was settled and discontinued on November 18, 1999, and that it was placed on the purge list inadvertently, the order of court dated October 22, 2002, relating to the purge list is vacated and the placement of the case on the recent purge list is also vacated. BY THE COURT, J. Wesley Qler, r., j J. Kristen G. Donsen, Esq. Attorney for Plaintiff Gary S. Yannone 16 W. High Street Carlisle, PA 17013 Defendant, Pro Se Court Administrator :rc 0" ' , 'r^; v'tY 02POV26 P1i I: 19 CUM rt ',;?y; CQUMY PENNSYLVAPUA VALERIE L. YANNONE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. GARY S, yANNONE, No. 99-3958 CIVIL TERM Defendant ORDER OF COURT AND NOW, this 22nd day of October, 2002, it appearing that docket activity has occurred recently in the above-captioned case, the case is stricken from the purge list, and shall remain active. Kristen G. Donsen, Esquire For the Plaintiff Gary S. Yannone ? l01 ?' - ?' 16 W. High Street Carlisle, PA 17013 Defendant J Court Administrator wcy i BV the Court,