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Home My WebLink About03-3238HEIDI BETH SALVAGGIO, Plaimiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. o3- IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Chad Michael Salvaggio 518 Warren Street Lemoyne, PA 17043 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 annulmem 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. When the ground for 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, Courthouse Square, 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 249-3166 1-800-990-9108 Document #: 266659.1 HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 1N DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff, Heidi Beth Salvaggio, is an adult individual currently residing at 518 Warren Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 2. The Defendant, Chad Michael Salvaggio, is an adult individual currently residing at 518 Warren Street, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Plaintiffhas been a bona fide resident of the Commonwealth for at least six months immediately prior to the filing of this Complaim. 4. Plaintiff and Defendant were married on April 14, 2002 in Harrisburg, Dauphin County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security number is 202-66-0671, and Defendant's Social Security number is 200-62-0784. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plaintiffhas 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. Document #: 266659.1 10. 11. There were no children bom of this marriage. The marriage is irretrievably broken. The parties have been living separate and apart but in the same residence since April 13, 2003. 12. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and Defendant. WHEREFORE, Plaimiff requests that this Court enter a decree in divorce and any such other Orders as are appropriate and just. Dated: METZGER, WICKERSHAM, KNAUSS & ERB, P.C. A~ornc¥ I.D. No. 5{~799 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 266659.1 VERIFICATION I, Heidi Beth Salvaggio, hereby certify that the facts set forth in the foregoing Complaim in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworu falsification to authorities. Document #: 266659 1 HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 IN DIVORCE AFFIDAVIT OF SERVICE I, Brace J. Warshawsky, counsel for Plaintiff, Heidi Beth Salvaggio, hereby certify that a true and correct copy of the Complaint in Divome was served upon the following, by certified mail, restricted delivery, return receipt on July 15, 2003. Attached hereto, marked as Exhibit "A" and incorporated herein by reference, is a copy of the return receipt card indicating service npon: Chad Michael Salvaggio 518 Warren Street Lemoyne, PA 17043 Date: December _.~, 2003 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. P.O. Box 5300 Harrisburg, PA 17110~0300 (717) 238-8187 Attorney for Plaintiff Heidi Beth Salvaggio Document #: 266659.1 Exhibit A ¢-.~.1o~,~' 'D No · HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE UNDER SECTION 3301(c) OF DIVORCE CODE 1. I consent to the entry of a final decree of divome without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divomed until a divome 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 any false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to unswom falsification to authorities. . __, '/ Dated: /c~ Ii 10~ Chad M. Salvaggio 291764-1 HEIDI BETH SALVAGGIO, : Plaintiff, : V. CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE UNDER SECTION 3301(c) OF DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyers' fees or expenses ifI do not claim them before a divome is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court, and that a copy &the decree will be sent to me immediately atter it is filed with the Prothonotary. I verit~ that the statements made in this Affidavit are true and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to unswom falsification to authorities. Dated: 291764-1 HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 CIVIL TERM 1N DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 9, 2003 and served upon Defendant on July 15, 2003. 2. The marriage of Pla'mtiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date offihng 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 Divorce. I verify that the statenaents made in this Affidavit are true and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to unswom falsification to author/ties. Dated: /~/[ [0.~ Chad M. Salvaggio 291764-1 {Jo HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 9, 2003 and served upon Defendant on July 15, 2003. 2. The marriage of Plaintiffand Defendant is irretrievably broken, and ninety (90) 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 se~ice of Notice of Intention to Request Entry of the Divorce. I verify that the statements made in this Affidavit are tree and correct. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to unswom falsification to authorities. Dated: Heidi B. Salvaggio ~ [ 291764-1 HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly 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 Divome Code. 2. Date and manner of service of Complaint: A Complaint in Divome was filed on July 9, 2003, and served on Defendant on July 15, 2003, via certified mail, restricted delivery. An Affidavit of Service was filed on December 5, 2003. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiff's and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: Plaintiff: December 1, 2003, filed December 5, 2003 Defendant: December 1, 2003, filed December 5, 2003 (b)(1) Date of execution of Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: NA (2) Date of filing and service of the Plaintiff's Affidavit upon the respondent: Filing: NA Service: NA 293998-1 IN THE COURT OF COMMON PLEAS Of CUMBI~RLAN D COUNTY STATE OF ~ PENNA. BETH 5ALVAGGIO NO. 03-3238 VERSUS 14IC~ SALVAGGIO AND NOW, I DECREED THAT DECREE IN DIVORCE HEIDI BETH SALVAGGIO , IT IS ORDERED AND , PLAINTIFF, AND ~ M]:CNAI~. SAI.VAG(~IO ,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; HEIDI BETH SALVAGGIO, Plaintiff, CHAD MICHAEL SALVAGGIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3238 IN DIVORCE CERTI ICA* OF S RVIC AND NOW, this"j/Dday of December, 2003 I, Bruce J. Warshawsky, Esquire, of Meager, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, Heidi Beth Salvaggio, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Chad Michael Salvaggio 518 Warren Street Lemoyne, PA 17043 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. B~:~B~'c/e j./~haws~ ~//~" ~/~ ky~Y'~ 293998-1