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Home My WebLink About07-1980,A , . Erica E. Karlsen-Forgione Plaintiff V. John A. Forgione Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 1980 IN DIVORCE CIVIL TERM 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 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Erica E. Karlsen-Forgione Plaintiff . V. John A. Forgione Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA : NO. 07- / 9fd CIVIL TERM : IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ?'?", who currently resides at 1011a ?p?(t.IS1? PA 1? c? I Cumberland County, Pennsylvania. 2. Defendant is *9--? C91p ?' who currently resides at 29:0 1 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on at 5. The marriage is irretrievably broken, and the parties separated on 6. There°have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. +./ 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ? Date Plai tiff, Pro e ; I, C=ad" verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pal. C.S. §4904. Date: 6\A,_ Plaint ff, Pro Assisted by: Susan Candiello, Esquire 4010 Glenfinnan Place Mechanicsburg, PA 17055 (717) 724-2278 ....? ?} !?_ -? S} ,? T ' °C) 1 --? ? R ? ?--r ?.. ?? ® ? ? f' r f f Cl. ??? j ?' Erica E. Karlsen-Forgione Plaintiff V. John A. Forgione Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- ft o CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Erica E. Karlsen-For ione Plaintiff, to proceed in forma au eris. I, Susan Candiello, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party I Susan Can lo, Esq. Attorney f r Plai tiff 4010 Glenfin an Place Mechanicsburg, PA 17055 (717) 724-2278 =n ai -TI t } ` =i Erica E. Karlsen-Forgione Plaintiff V. John A. Forgione Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 1980 CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a' waiver of your right to request counseling. _-j 77- .? (J Erica E. Karlsen-Forgione IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.07- I q ? d CIVIL TERM John A. Forgione Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, John A. For ig_one (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. 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 ohn A. Forgione, Defendant e% a .. f..w rn ?,... Erica E. Karlsen-Forgione IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 07- (Q CIVIL TERM John A. Forgione Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on ?00?1 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 divorce. 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. Section 4904 relating to u sworn falsification to authorities. 7 , Date: Signature: n A. Forgione, Defendant sv ? Erica E. Karlsen-Forgione IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- Q( CIVIL TERM John A. Forgione 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 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: Signature: . Forgion efendant r r-? fl'a rfi Erica E. Karlsen-Forgione Plaintiff V. John A. Forgione Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- (Ci ?-O CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on &'-.a 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 divorce. I verify that the statements made in this affidavit are true and corn understand that false statements herein are made subject to the p n of 18 a. S. Sect on 4904 relating to unsworn falsification to authorities Date: Signature: daca 1 Karlsen-For io e, laintiff ? ? --s t =?`° `;, ? "°'? ?.,, ^'°-^ . t ?-; ?? -Nr° I ? ,?? .?=° ..G. _? Erica E. Karlsen-Forgione IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- lq 'R;D CIVIL TERM John A. Forgione 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 statements made in this affidavit are t e and correct. I understand that false statements herein are made subject to the pe altie f 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. N/- Dater Signature: Eric arisen-Forgi a Plainti ?f 9 - ...( co Erica E. Karlsen-Forgione IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- CCt!i?D CIVIL TERM John A. Forgione 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 3. Date of execution of the Affidavit,of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, °7 11 5?-A ? ; by Defendant, 5_- I -ZQIZ 11 If 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:' 71t 5?-7 (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: /C) a/p . 11 Plaintiffs Social' Security Number: Defendant's Social Security Number: Erica E. Karls n- orgione f'i`t cJ. g co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. ERICA K KARLSEN-FORGIONE PLAINTIFF VERSUS JOHN A. FORGIONE DEFENDANT No. 07-19M DECREE IN DIVORCE AND NOW, N%35%sS? 'o 2007 IT IS ORDERED AND ERICA E. KARLSEN-FORGIONE DECREED THAT JOHN A. FORGIONE AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; NONE. BY THE COURT: PROTHONOTARY ? /D'.'?'? ? ' COQ 9E?-3 ?, . .-? -.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. Defendant FILE NO. ?- - q "90 6 j'• 1 Te rn @G-N IN DIVORCE 0 • Wit,. NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 2 day of US -2607 hereby elects to resume the prior surname of a. `2 P Y"j and gives this written notice pursuant to the provisions of 5-4,?-?S 704. DATE: ,V o I 2001 t C' ??-m o 0 f d Ph* 74 6 (a 24,617117 of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. sf On the / day of 4,1-1- j , 20 / b , before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Notary Public y 4008