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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
SUSAN S. LOSTRAGLIO. _
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PLAINTIFF tt.....6495 ....... .:......9.9.. 19
.ROBERT R. LOSTRAGLIO
DEFENDANT
DECREE IN
DIVORCE
AND NOW,... 10 ........ 282A41, it is ordered and
decreed that ...susA•ri ,s,• Lgs?tt.AG?Zo ........................ plaintiff,
and .... ROBERT• R., •LOSTRA?LIO • , • • , • ...... • , • • • „ • • • • , • , • , . , 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:
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NONE
.........................................................................
By The Cot rt j.
Atte3t: J.
Prothonotary
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PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
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: Complaint served on
ROBERT R. LOSTRAGLIO by personal hand delivery on 11-17-99
3. Date of execution of the plaintiffs affidavit required by Section
3301(c) of the Divorce Code: 3-21-00
Date of service of plaintiffs affidavit on defendant: 3-22-00
Date of execution of the defendant's affidavit required by Section
3301(c) of the Divorce Code: 10-01-00
4.
Related claims pending: None
Dated: %010% 0\
ully mi
Peter J. Russo
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OCT ! 7 1999r.
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SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
ROBERT R. LOSTRAGLIO NO. 99 - 444< CIVIL TERM
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this I_ day of?x 1999, upon
consideration of the attached Complaint, it is hereby directed that the parties and their
respective counsel appear before x , the
Conciliator, at m. 0" VNc?x Ql C '
on the 10*i N day of Qge,'6 ._ 1999, at q:. -q -.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 at the request of either attorney or party, be present at the conference. Failure to
appear at the Conference may provide grounds for the entry of a temporary or permanent
Order.
FOR THE COURT,
By: 11 lgn j• ?4 ? A -n
Custody Conciliator v0;?).)
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.
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 Lawyers Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
FILFf}O"FICE
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SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
ROBERT R. LOSTRAGLIO NO. 99 - CIVIL TERM
Defendant 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 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 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, Cumberland County Court House, 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 Lawyers Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99- 4y9fCIVILTERM
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE
AND NOW, COMES, the above-named Plaintiff by and through her attorney
Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named
Defendant, upon the grounds hereinafter more fully set forth:
1. Plaintiff is an adult individual residing at 131 Fern Avenue, Carlisle,
Cumberland County, Pennsylvania and is a citizen of the United States.
2. Defendant is an adult individual residing at 705 Hanover Manor, Apt. B206,
Carlisle, Cumberland County, Pennsylvania and is a citizen of the United States.
3. Plaintiff has been a bona fide resident of the Commonwealth of
Pennsylvania for 28 years and has resided continuously therein for at least six months
prior to filing of this Complaint.
4. Defendant has been a resident of the Commonwealth of Pennsylvania for 4
years and has resided continuously therein for at least six months prior to filing of this
Complaint.
5. Plaintiff and Defendant were married on November 9, 1996, in
Pennsylvania.
6. There is one (1) child of the parties under the age of eighteen (18):
Tyler Lostraglio
COUNT I - DIVORCE
May 5, 1997
7. Plaintiff hereby incorporates by reference averments 1 through 6 of this
Complaint as if each averment were set forth fully hereunder.
8. There has been no prior action for divorce by either party against the other.
9. Neither Plaintiff nor Defendant Is in the Armed Forces of the United States
or any of its allies.
10. Plaintiff avers that the marriage between the parties is irretrievably broken.
11. 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, but
does not request the same.
12. Plaintiff and Defendant have property which will be subject to a property
settlement agreement addressing support issues, which will be filed herein at the
appropriate time.
WHEREFORE, Plaintiff, SUSAN S. LOSTRAGLIO, prays that a decree be entered
in favor of the Plaintiff and against Defendant as follows:
A. That a decree in divorce be entered dissolving the marriage between the
two parties.
COUNT 11 - CUSTODY
13. Plaintiff hereby incorporates by reference averments 1 through 12 of this
Complaint as if each averment were set forth fully hereunder.
14. Plaintiff Is SUSAN S. LOSTRAGLIO residing at 131 Fern Avenue, Carlisle,
Cumberland County, Pennsylvania.
15. Defendant Is ROBERT R. LOSTRAGLIO residing at 705 Hanover Manor,
Apt. B206, Carlisle, Cumberland County, Pennsylvania.
16. Plaintiff seeks custody of the following child:
Name Present Residence DOB
Tyler Lostraglio 131 Fern Avenue, Carlisle, PA May 5, 1997
17. The child was not born out of wedlock.
18. The child is presently in the custody of the Plaintiff, who resides at, 131
Fern Avenue, Carlisle, Cumberland County, Pennsylvania.
19. In the last five years the child has resided with the following persons and at
the following address:
Name Address Dates
Mother & Grandparents 131 Fern Avenue 10-99 to present
Mother & Father 487 Highland Court 10-1-98 to 10-99
Mother & Father 711 Hanover Manor, Apt#F204 10-1-97 to 10-1-98
Mother & Father 703 Hanover Manor, Apt#C111 May 1997 to October 1997
20. The Defendant, the father of the child, is residing at 705 Hanover Manor,
Apt. B206, Carlisle, Cumberland County, Pennsylvania. He is married.
21
22.
The Defendant currently resides with the following persons:
Name
Unknown
Relationship
The Plaintiff the mother of the child, is SUSAN S. LOSTRAGLIO residing at
131 Fern Avenue, Carlisle, Cumberland County, Pennsylvania. She is married.
23. The Plaintiff currently resides with the following persons:
Name _ Relationship
David Sheller Father
Mary Sheller Mother
Tyler Lostraglio Son
24. Plaintiff has not participated as a party or witness, or in another capacity,
in other litigation concerning the custody of the child in this or another court. The court,
term and number, and its relationship to this action is: NONE.
25. Plaintiff has no information of a custody proceeding concerning the child
pending in a court of this Commonwealth. The court, term and number, and its ;
relationship to this action is: NONE.
26. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation right with respect to
the child. The name and address of such person is: NONE.
27. The best interest and permanent welfare of the child will be served by
granting the relief requested because set forth facts showing that the granting of the
relief requested will be in the best interest and permanent welfare of the child:
a. Mother has been the primary care taker of the child since birth.
28. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action. All other persons named below, who are known to have or claim a right to
custody or visitation of the child will be given notice of the pendency of this action and
the right to intervene:
Name Address Basis of Claim
NONE
WHEREFORE, Plaintiff requests this Honorable Court to order that the parties:
Respectfully submitted,
Peter J. Russo
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
PETER J. RUSSO, ESQUIRE Attorney for Plaintiff
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
ROBERT R. LOSTRAGLIO NO. 99 - CIVIL TERM
Defendant IN DIVORCE
I, SUSAN S. LOSTRAGLIO, verify that the statements made in the foregoing
document are true and correct. I understand that false statements made herein are
subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Dated: 10-QP5'LJQ rah,l,_{ „'trf 3 ' c?0?
SUSAN S. LOSTRAGLIO
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PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 99 - 6495 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT
UPON DEFENDANT
AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff SUSAN S.
LOSTRAGLIO, and certifies that on q 1131a ?e did serve
the Defendant, ROBERT R. LOSTRAGL with a true and correct copy of the Divorce
Complaint filed against him alleging the parties' marriage was irretrievably broken under
Section 3301(d) and Section 3301(c) of the Divorce Code. Said complaint was served
upon the defendant by placing same in an envelope, return receipt requested and
addressed to ROBERT R. LOSTRAGLIO at 705 Hanover Manor, Apt. B206, Carlisle,
Cumberland County, Pennsylvania.
(l Service of Plaintiffs Complaint on the Defendant, ROBERT R. LOSTRAGLIO was
effected on . A true and correct copy of the
U.S. Postal Service Return Receipt Is attached hereto and the original is affixed to
the reverse of this document.
lXl Service of Plaintiffs Complaint on the Defendant, ROBERT R. LOSTRAGLIO was
effected on 11171161 . A true and correct copy of
Defendant's Acknowledgment of Service is attached hereto and the original is
affixed to this document.
Respectfully submitted,
Peter J. Russo
Dated: November 17, 1999
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
ACKNOWLEDGMENT OF SERVICE OF COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE
AND NOW, COMES, Defendant. ROBERT R. LOSTRAGLIO, and does hereby
acknowledge that on the date indicated below he did receive a verified copy of a
Complaint in Divorce filed against him in the above captioned case,
R R. LOSTRAGLIO
Dated: ?-/?- 9 9
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SUSAN S. LOSTRAGLIO
Plaintiff
ROBERT R. LOSTRAGLIO
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE
OF INTENTION TO ENTER DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on October 26, 1999.
2. The marriage is irretrievably broken and ninety days have elapsed from
the date of the filing and service of the Complaint.
3. 1 consent to the entry of a Final Decree of Divorce without further notice.
4. 1 understand that I may lose rights concerning alimony, division of
property, lawyers fees or expenses if I do not claim them before a divorce is granted.
5. 1 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's Office.
6. 1 have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I participate in
counseling. i understand that the court maintains a list of marriage counselors in the
Domestic Relations Office, which list is available to me on request.
7. Being so advised, I, SUSAN S. LOSTRAGLIO, do not request that the
Court require my spouse and me to participate in counseling prior to a divorce decree
being handed down by the Court.
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.
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DATE SUSAN S. LOSTRAGLIO
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SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE
OF INTENTION TO ENTER DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on October 26, 1999.
2. The marriage is irretrievably broken and ninety days have elapsed from
the date of the filing and service of the Complaint.
3. 1 consent to the entry of a Final Decree of Divorce without further notice.
4. 1 understand that I may lose rights concerning alimony, division of
property, lawyers fees or expenses if I do not claim them before a divorce is granted.
5. 1 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's Office.
6. 1 have been advised of the availability of marriage counseling and
understand that I may request that the court require that my spouse and I participate in
counseling. I understand that the court maintains a list of marriage counselors in the
Domestic Relations Office, which list is available to me on request.
7. Being so advised, I, ROBERT R. LOSTRAGLIO, do not request that the
Court require my spouse and me to participate in counseling prior to a divorce decree
being handed down by the Court.
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 'ROBERT R. LOSTRAGLIO
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PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
PROOF OF SERVICE OF PLAINTIFF'S AFFIDAVIT
UPON DEFENDANT
AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, SUSAN S.
LOSTRAGLIO, and certifies that on 3-22-00 he did serve the Defendant,
ROBERT R. LOSTRAGLIO with the Affidavit of Defendant Under Section 3301(c) of the
Divorce Code requesting his signature thereon by placing same in an envelope
addressed to ROBERT R. LOSTRAGLIO, 705 Hanover Manor, Apt. B206, Carlisle, and
deposited same in the U.S. Mail receptacle for transmittal by first class mail.
Respectfully submitted,
Peter J. Russo
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
Dated: March 22, 2000
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CURTIS R. LONG ?.., i
Prothonotary
Cumberland County crpq .? CEC 2 i'0 0 033
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One Courthouse Square
Carlisle, PA 17013 FBME, req
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SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
ROBERT R. LOSTRAGLIO
Defendant NO. 6495 1929
OTION FOR APPOINTMENT OF MASTER
SUSAN S. LOSTRAGLIO (Plaintiff) (Defendgm), moves the court to appoint a master with
respect to the following claims:
( X) Divorce ( X) Distribution of Property
( ) Annulment ( X) Support
( ) Alimony ( X ) Counsel Fees
( ) Alimony Pendete 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 Defendant (has) (has not) appeared in the action (personally).
(3) The statutory ground(s) for divorce (is) (arc) 3301(c)
(4) Delete the inapplicable paragraph(s):
(a) .
(b) been renehed with Fe6pee! !a !he fell
(c) The action is contested with respect to the following claims:
(5) The action (invelyes) (does not involve) complex issues of law or
fact.
(6) The hearing is expected to take 2 - 3 (hours) (days).
(7) Additional infonnation, if any, relevant to the motion:
Date: Attorney for (Plaintiff)
()
AND NOW de 200d ,
appointed master with respect to the following cl
Esquire, is
BY TH
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SUSAN S. LOSTRAGLIO
Vs.
ROBERT R. LOSTRAGLIO
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99 - 6495
NO. CIVIL 19
IN DIVORCE
Defendant
STATUS SHEET
DATE: (n ACTIVITIES:
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SUSAN S. LOSTRAGLIO,
Plaintiff
VS.
ROBERT R. LOSTRAGLIO,
Defendant
TO: Peter J. Russo
Robert R. Lostraglio
. IN THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
N0. 99 - 6495 CIVIL
. IN DIVORCE
Attorney for Plaintiff
Defendant
DATE: Wednesday, January 31 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
SUSAN S. LOSTRAGLIO, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL
ROBERT R. LOSTRAGLIO,
Defendant IN DIVORCE
TO: Peter J. Russo
Robert R. Lostraglio
, Attorney for Plaintiff
, Defendant
A pre-hearing conference has been scheduled
at the Office of the Divorce Master, 9 North Hanover Street,
Carlisle, Pennsylvania, on the 21st of June, 2001, at 9:30
a.m., at which time we will review the pre-trial statements
previously filed by counsel, define issues, identify
witnesses, explore the possibility of settlement and, if
necessary, schedule a hearing.
Very truly yours,
Date of Notice: 6/4/01
E. Robert Elicker, II
Divorce Master
Peter J. Russo, Attorney for Plaintiff, filed a pre-trial
statement on May 14, 2001.
Robert R. Lostraglio, Defendant, has not filed a pre-trial
statement as of the date of this notice.
4h
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717)240.6535
E. Robert Elicker, 11
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
West Shore
697.0371 Exl. 6535
April 12, 2001
Peter J. Russo, Esquire
61 West Louther Street
Carlisle, PA 17013
Robert R. Lostraglio
P.O. Box 103
New Kingstown, PA 17072
534M Beaver Avenue
Enola, PA 17025
RE: Susan S. Lostraglio vs. Robert R. Lostraglio
No. 99 - 6495 Civil
In Divorce
Dear Mr. Russo and Mr. Lostmglio:
I was appointed Master on December 21, 2000. The Plaintiff has certified that
discoveryis complete. I have had no response from the Defendant. I do note that the file
contains affidavits of consent and waivers of notice of intention to request entry of
divorce decree signed and filed by both parties so that the divorce can be concluded
under Section 3301(c) of the Domestic Relations Code.
On June 19, 2000, the Plaintiff filed an amended complaint raising the economic
issues of equitable distribution, alimony, alimony pcndcnte lite, and counsel fees and
expenses.
In accordance with P.R.C.P. 1920.33(b) I am directing Mr. Russo as counsel for
wife and Mr. Lostraglio, who is apparently unrepresented, to each file a pretrial statement
on or before Monday, May 14, 2001. Upon receipt of the pretrial statements, I will
r
Mr. Russo and Mr. Lostraglio
12 April 2001
Pac 22
immediately schedule a pre-hearing conference to discuss the issues and, if necessary,
schedule a hearing.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (e) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
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SUSAN S. LOSTRAGLIO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v
ROBERT R. LOSTRAGLIO,
Defendant
CIVIL ACTION - LAW
: NO. 99-6495 CIVIL
: IN CUSTODY
COURT ORDER
AND NOW, this ? day of December, 1999, the Conciliator being advised that the parties have
reached an agreement, the Conciliator rclinquishcs jurisdiction.
cc: Peter J. Russo, Esquire
Robert R. Lostmglio
705 Hanover Manor, Apt. B206
Carlisle, PA 17013
BY THE COURT,
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1 ubcrt X. Gil y, Esquire
Custody Ceficiliator
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SUSAN S. LOSTRAGLIO
Plaint!)"
V.
ROBERT R. LOSTRAGLIO
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUMTY, PENNSYLVANIA
NO. 99 - 6495 -CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
C w y?
CUSTODY ORDER
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AND NOW
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of the within Stipulated Custody Agreement, :
IT IS HEREBY ORDERED AND DECREED THAT:
1. The parties shall share legal custody of the parties' minor child, Tyler
Lostraglio, born May 5, 1997.
2. Susan S. Lostraglio shall have primary physical custody of the Tyler Lostraglio.
3. Robert R. Lostraglio shall be entitled to liberal periods of visitation, as the
parties mutually agree.
4. Transportation shall be the responsibility of the parent who is receiving custody
of the child, with the other parent retrieving the child at the end of the agreed
upon period of visitation.
5. If either party hereto breaches any of the provisions of this Agreement, the
other party shall have the right to bring any actions or actions in law or equity
for such breach, and the breaching party shall be responsible for the payment
of all costs and reasonable legal fees incurred by the other party in enforcing
her rights under this Agreement.
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.
6. Neither party shall do anything which may estrange the Child from the other, or
Injure the opinion of the Child as to the other party, or which may hamper the
free and natural development of the Child's love or affection for the other party.
7. Any modification or waiver of any of the provisions of this Agreement shall be
effective only if made in writing and only if executed with the same formality as
this Stipulation and Agreement.
8. The parties desire that this Stipulation and Agreement be made an Order of
Court to the Court of Common Pleas of Cumberland County does, in fact have
jurisdiction over the issue of custody of the parties' minor Child and shall retain
such jurisdiction should circumstances change and either party desire or
require modification of said Order.
9. The parties agree that in making this Agreement, there has been no fraud,
concealment, overreaching, coercion, or other unfair dealing on the part of the
other.
10. The parties acknowledge that they have read and understand the provisions of
this Agreement. Each party acknowledges that the Agreement is fair and
equitable and that it is not the result of any duress or undue influence.
Robert R. Lostraglio, Pro Se „ ?y Mid r r'?s /19.
Peter J. Russo, Esquire _'J. e
BY THE COURT,
SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 - 6495 -CIVIL TERM
ROBERT R. LOSTRAGLIO CIVIL ACTION-LAW
Defendant IN DIVORCE
STIPULATED CUSTODY AGREEMENT
AND NOW, comes the parties in the above-captioned matter, to wit, Susan S.
Lostraglio, represented by Peter J. Russo, Esquire and Robert R. Lostraglio, after being
provided the option of obtaining counsel, remains unrepresented, and request that the
attached Order of Court be entered by the Court, by stipulation of the parties.
NOW, THEREFORE, the parties hereto, each intending to be legally bound
hereby, place their seal:
AtaM..,d.Hamd
Susan 8. Lostraglio
Lostraglio
Witness for Susan L Lostraglio
Date: November 17. 1999
?ll?,?,;?.4 a lip 6
Witness for Robe R. L stragiio
Date: November 17. 1999
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SUSAN S. LOSTRAGLIO : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
ROBERT R. LOSTRAGLIO
Defendant NO. 6495 1992
OTION FOR APPOINTMF_NT_OF MASTER
SUSAN S. LOSTRAGLIO (Plaintiff) (Oefendam), moves the court to appoint a master with
respect to the following claims:
( X ) Divorce ( X ) Distribution of Property
( ) Annulment ( X ) Support
( ) Alimony ( X) Counsel Fees
( ) Alimony Pendete 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 Defendant (has) (has ne() appeared in the action (personally).
(3) The statutory ground(s) for divorce (is) (are) 3301(c)
(4) Delete the inapplicable paragraph(s):
(a) Theselien OF; not ,
(b) Anflffeemen! 1186 WON Fe !a !he feilewing
elaifs:
(c) The action is contested with respect to the following claims:
(5) The action (invelves) (does not involve) complex issues of law or
fact.
(6) The hearing is expected to take 2 - 3 (hours) (days).
(7) Additional information, if any, relevant to the motion:
Dater
Attorney for (Plaintiff)
(Pefendaat)
AND NOW + 20 cc) OCi-4t 4 Esquire, is
appointed master with respect to the following claims: /T eC
BY TH
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SUSAN S. LOSTRAGLIO,
Plaintiff
VS.
ROBERT R. LOSTRAGLIO,
Defendant
TO: Peter J. Russo
Robert R. Lostraglio
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 6995 CIVIL
IN DIVORCE
Attorney for Plaintiff
Defendant
DATE: Wednesday, January 3, 2001
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed. __-?
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
1?g1O, L/?
DATE COUNSEL FOR PLAINTIFF (r)
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
AND NOW, COMES, the above-named Plaintiff by and through her attorney
Peter J. Russo, and seeks to Amend the Divorce Complaint as more fully set forth:
29. Plaintiff re-avers paragraphs 1 through 28 of Plaintiffs Divorce Complaint as if
each averment were set forth fully hereunder.
COUNT III: DIVORCE - EQUITABLE DISTRIBUTION
30. Plaintiff hereby incorporates by reference averments 1 through 29 of this
Complaint as if each averment wara set forth fully hereunder.
31. Plaintiff and Defendant have acquired property, both real and personal, during the
course of their marriage.
32. The parties have also acquired home furnishings, motor vehicles, bank accounts,
retirement accounts, investments and miscellaneous items of personal property in
addition to martial obligations.
33. Thus far plaintiff and defendant have been unable to agree as to an equitable
distribution of said property, therefore Plaintiff requests the equitable distribution of said
marital property.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide the
parties assets and obligations.
COUNT IV ALIMONY PENDENTE LITE ALIMONY,
COUNSEL FEES AND COSTS
34. Plaintiff hereby incorporates by reference averments 1 through 33 of this
Complaint as if each averment were set forth fully hereunder.
35. Plaintiff is without sufficient resources so as to pay for her reasonable needs,
counsel fees and costs of these proceedings.
WHEREFORE, Plaintiff requests this Honorable Court to award Plaintiff alimony in
an amount sufficient to meet her reasonable needs, counsel fees and costs.
Respectfully submitted,
Peter J. Russo
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
Date: I9 Ia Ono
PETER J. RUSSO, ESQUIRE Attorney for Plaintiff
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495
IN DIVORCE
VERIFICATION
CIVIL TERM
I, SUSAN S. LOSTRAGLIO, verify that the statements made in the foregoing
document are true and correct. I understand that false statements made herein are
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
Dated: /u~ 1-1-00 nlm/y ?)4tz
SUSAN S. LOS RAG IO
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PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495
IN DIVORCE
CERTIFICATE OF SERVICE
CIVIL TERM
AND NOW9 THIS DAY, Peter J. Russo, Attorney for Plaintiff, SUSAN S.
LOSTRAGLIO, and certifies that on this day he did serve the Defendant, ROBERT R.
LOSTRAGLIO with the Amended Complaint by placing same in an envelope addressed
to ROBERT R. LOSTRAGLIO, P.O. Box 103, New Kingston, PA and deposited same in
the U.S. Mail receptacle for transmittal by first class mail.
Respectfully submitted,
Peter J. Russo'
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
Dated: (? 11 G
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PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
61 West Louther Street
Carlisle, PA 17013
(717) 249-2721
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Peter J. Russo, hereby certify on this day, that I personally hand delivered a
copy of the divorce Complaint upon the person(s) and at the address listed below:
Robert R. Lostraglio
61 West Louther Street
Carlisle, PA 17013
L+A
Peter J. Russo
Date: November 17.1999
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNIY
COURT OF COMMON PLEAS
9 North Hanover Street
Carisle, PA 17013
(717) 240-6535
E. Robert Elicker, II
Divorce Master
Traci Jo Colyer
Office Manager/Reporter
April 12, 2001
Peter J. Russo, Esquire
61 West Louthcr Street
Carlisle, PA 17013
West Shore
697.0371 Ext. 6535
Robert R. Lostraglio
P.O. Box 103
New Kingstown, PA 17072
534M Beaver Avenue
Enola, PA 17025
RE: Susan S. Lostmglio vs. Robert R. Lostraglio
No. 99 - 6495 Civil
In Divorce
Dear Mr. Russo and Mr. Lostraglio:
I was appointed Master on December 21, 2000. The Plaintiff has certified that
discovery is complete. I have had no response from the Defendant. I do note that the file
contains affidavits of consent and waivers of notice of intention to request entry of
divorce decree signed and filed by both parties so that the divorce can be concluded
under Section 3301(c) of the Domestic Relations Code.
On June 19, 2000, the Plaintiff filed an amended complaint raising the economic
issues of equitable distribution, alimony, alimony pendentc litc, and counsel fees and
expenses.
In accordance with P.R.C.P. 1920.33(b) I am directing Mr. Russo as counsel for
wife and Mr. Lostraglio, who is apparently unrepresented, to each file a pretrial statement
on or before Monday, May 14, 2001. Upon receipt of the pretrial statements, l will
AUJ-li
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Mr. Russo and Mr. Lostraglio
12 April 2001
Raul
immediately schedule a pre-hearing conference to discuss the issues and, if necessary,
schedule a hearing.
Very truly yours,
E. Robert Elickcr, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements are set
forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED
IN THE MASTER'S OFFICE AND A COPY SENT DIRECTLY
TO OPPOSING COUNSEL.
FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED
BY THE MASTER MAY RESULT IN THE MASTER'S
APPOINTMENT BEING VACATED.
• f
SUSAN S. LOSTRAGLIO IN TIIE COURT OF COMMON PLEAS OF
1'Iainliff CUMBERLAND COUNTY, PENNSYLVANIA t_
?. CIVIL ACTION - LAW
ROIi1:RT R. LOSTRAGLIO IN NO. 99 - 6495 1)190{295 CIVIL TERM
Defendant
I'I AINTIFF'S PRE TRIAL. STATEMENT
AND NOW COMES, Plaintiff. by and through her counsel, Peter J. Russo, and sets forth
the following Pre Trial Statement:
ASSUS Maripd I'rnmerlc Lien flah
ller - Value
9,000.00 4/2001
1999 Port/ liscurt 18,585.60
Assrrs - Non-MurlUd 1'r0per:Y
Saturn
4/2001
I1, I:xpI:RT WITNESSES
Plaintift' does not intend to call any expert witnesses to trial. Plaintiff reserves the right to amend
this pre-trial statement to include any experts required to rebut the testimony of any Defense experts that
may be called.
111, WITNF.SSFS
Plaintiff intends to call the following witnesses to trial:
a. Susan S. Lostraelio - Plaintiff: Will testify as to the assets, her financial status, etc.
IV. liXunms
I'laintifl' intends to introduce the following exhibits:
a, Consumer Credit Counseling Payment Schedule - Not Attached f'
b. Payroll Stubs - Not Attached
c, Detailed List of Expenses - Attached
d. 'fax Returns - 1999 R. 2000
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V. INCODtE OF PLAINTIFF
Employer: SCALLES
Job Title/Description: WAITRESS
Payroll Number: SU 00
Pay Period: WEEKLY
Gross Pay per Pay Period: $312.71
ITEMIZED PAYROLL DEDUCTIONS:
Federal Withholding $20.22
Social Security $19,39
Local Wage Tax $3.13
State Income Tax $8.76
Retirement $0.00
Savings Bonds $0.00
Credit Union $0.00
Life Insurance $0.00
Health Insurance $19.60
Other (FICA) $0.00
PA Unemployment $0.00
Before Tax Flex $0.00
Before Tax Savings $0.00
After Tax Savings $0.00
Occupational Tax $10.00
Total $81.10
Net Pay Per Period $231.61
Net Yearly Salary $12,043.72
VI. ExPF.NSF.
See Income and Expense Statement.
VII. PENSION
Plaintiff has no pension or retirement benefits.
VIII. COIINSF.L FEES
Plaintiff seeks the payment of counsel fees in the amount of $1.200.00 by Defendant.
IX DISPUTES AS TO VALUATION
None.
X. MARTIAL DFRT
See Attached
XI!, PROPOSED RF.SOLUTIOY
Plaintiff proposes that Defendant be awarded sole possession of the 1999 Ford Escort and be
solely responsiblc for all debt and obligations thereon. Plaintiff has dutifully paid the totality of the
parties' revolving credit obligations via Consumer Credit Counseling Center for the past several years
and seeks an order directing Defendant to make the balance of those payments,
Plaintiff also seeks alimony from Defendant.
All personal possessions were divided when Defendant left the marital residence.
sPc ally su
Peter J. Russo
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EXPENSES:
WEEK MONTH YEAR
Home $ § §
Mortgage
Rent § §
$
Maintenance $ $ $
Utilities $ $ $
Electric S $ $
Gas $ $ $
Oil § $ $
Telephone $ $ $
Water $ $
Sewer $ $ $
Employment $ g $
Public Transportation
Lunch $ 1200 $ 48.00 $ 624.00
Taxes $ $ $
Personal Taxes 10.00
School Taxes $ $ S 18790
Income Taxes $ $ $ 5200
Insurance $ $ $
Homeowners
Automobile $ $ $ 884.00
Life $ $ $
Accident $ $ $
Health $ $ 78.40 $ 940.80
Other $ $ $
Other $ $ $
Automobile $ S $
Payments
Fuel $ 12.00 S $ 624.00
Repairs $ $ $ 120.00
Medical $ S §
Doctor 100.00
Dentist $ $ $ 120.00
Orthodontist $ $ S
Hospital $ $ $
Medicine $ $ 12.50 $ 150.00
Special needs $ $ $
Education $ $ $
Private School 1432.00
Parochial School S $ S
College $ $ $
Religious $ $ $
Personal $ $ $
Clothing 400.00
Food $ $ $ 2,600.00
Barber/Hairdresser $ $ $ 104.00
Credit Payments $ S 1,125.00 $ 13,5000
Credit Card $ g §
Charge Account $ $ $
Memberships $ g 5
Loans S $ $
Credit Union $ $ $
Household Help
Child Care
Papers/ Books/ Magazines
Entertainment
Pay TV
Vacation
Gifts
Legal Fees
Charitable Contributions
Other Child Support
Alimony Payments
Other
Other
Other
Other
Total
S
$
$
$
$
$
$
$
$
$
$
$
S
$
$ 24.00
$ $
$ g
$ 30.00 $ 360.00
S g
$ $ 500.00
$ S 1004.26
5 g
S g
$ g
S g
$ g
$ g
$ 1,293.90 $ 23,712.96
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PETER J. RUSSO, ESQUIRE
PA Supreme Court ID: 72897
5010 E. Trindle Road
Mechanicsburg, PA 17050
(717) 591-1755
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99.6495 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Peter J. Russo, hereby certify on this day, serving a copy of the foregoing
document(s) upon the person (s) and in the manner indicated below;
Service by First-Class Mail, Postage Prepaid, and Addressed as Follows:
Robert R. Lostragilo
P.O. BOX 103
New Kingston, PA 17072 _
Peter J. Russo
Date:
SI1( O I
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
t CIVIL ACTION - LAW
NO. 99.6495 CIVIL TERM
IN DIVORCE
INCOME AND EXPENSES STATEMENT
INVENTORY AND APPRAISEMENT
of
Plaintiff
SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
ROBERT R. LOSTRAGLIO NO. 99 - 6495 CIVIL TERM
Defendant IN DIVORCE
INCOME AND EXPENSES STATEMENT
INVENTORY AND APPRAISEMENT
AND
ASSETS OF PARTIES
NOTICE
BOTH PARTIES TO A DIVORCE ACTION ARE REQUIRED TO FILE WITH THE
PROTHONOTARY AN INVENTORY AND APPRAISEMENT OF ALL PROPERTY
OWNED OR POSSESSED AT THE TIME THE ACTION COMMENCES AND ALL
!'ROPERTY TRANSFERRED WITHIN THE PRECEDING THREE (3) YEARS. YOU
MUST COMPLETE THIS FORM AND FILE IT WITHIN SIXTY 60) DAYS OF RECEIPT
OF THIS STATEMENT. IN ADDITION TO FILING THIS COMPLETED FORM WITH
THE PROTHONOTARY, YOU MUST ALSO SERVE A TRUE AND CORRECT COPY OF
THIS FORM ON THE OTHER PARTY TO THE DIVORCE, PURSUANT TO RULE OF
COURT. THIS STATEMENT SHALL INCLUDE THE INFORMATION REQUESTED AS
ATTACHED. YOU MAY NEED ADDITIONAL ROOM TO COMPLETE THIS FORM.
PLEASE KEEP EACH CATEGORY SEPARATE AND FOLLOW THE FORM AS
CLOSELY AS POSSIBLE.
IF YOU DO NOT FILE THE INVENTORY AND APPRAISEMENT AS REQUIRED,
SANCTIONS MAY BE IMPOSED AGAINST YOU BY THE COURT.
2
?,R
INCOME AND EXPENSE STATEMENT
Both parties to a divorce action are required to file with the Prothonotary a complete income and expense
statement. You must complete this form and file it within 30 days of receipt of this statement. If you are self-
employed or if you are salaried by a business of which you are owner in whole or in part, you must also fill
out the Supplemental Income Statement.
NAME:
ADDRESS:
TELEPHONE NUMBER:
SOCIAL SECURITY NO.:
DATE:
INCOME
Employer:
Job Tide/ Description:
Payroll Number:
Pay Period: (weekly,
bi-weekly, monthly):
Gross Pay per Pay Period:
SUSAN LOSI'RAGUO
131 FERN AVENUE, CARLISLE, PA 17013
717-2434036
175.48-3646
SCALLES
WAITRESS
SU 00
WEEKLY
312.71
ITEMIZED PAYROLL DEDUCTIONS:
Federal Withholding
Social Security
Local Wage Tax
State Income Tax
Retirement
Savings Bonds
Credit Union
Life Insurance
Health insurance
Other (FICA)
PA Unemployment
Before Tax Flex
Before Tax Savings
After Tax Savings
Occupational Tax
Total
Net Pay per Period
$20.22
$19.39
$3.13
$8.76
S
$19.60
$
$
$10.00
$81.10
S
$231.61
3
INCOME FROM ALL SOURCES:
WEEK MONTH YEAR
Interest $ $ $
Dividends $ $ $
Pension $ $ $
Annuity $ $ $
Social Security $ $ $
Rents $ $ $
Royalties $ $ $
Expense Account $ $ $
Gifts $ $ $
Unemployment Compensation $ $ $
Workmen's Compensation $ $ $
Other.(CHILD SUPPORT) $ $ $ 1,783.54
Total $ 0 $ 0 $ .54
EXPENSES:
WEEK MONTH YEAR
Home $ $ $
Mortgage
Rent $ $ $
Maintenance $ $ $
Utilities $ $ $
Electric $ $ $
Gas $ $ $
Oil $ $ $
Telephone $ $ $
Water $ $ $
Sewer $ $ $
Employment $ $ $
Public Transportation
Lunch $ 12.00 $ 48.00 $ 624.00
Taxes $ $ $
Personal Taxes 10.00
School Taxes $ $ $ 187.90
Income Taxes $ $ $ 52.00
Insurance $ $ $
Homeowners
Automobile $ $ $ 884.00
Life $ $ $
Accident $ $ $
Health $ $ 78.40 $ 940.80
Other $ $ 5
Other $ $ $
Automobile $ $ $
Payments
Fuel $ 12.00 $ $ 624.00
Repairs $ $ $ 120.00
Medical $ $ $
Doctor 100.00
Dentist $ $ $ 120.00
4
Orthodontist $
Hospital $
Medicine $
Special needs $
Education $
Private School
Parochial School $
College $
Religious $
Personal $
Clothing
Food $
Barber/Hairdresser $
Credit Payments $
Credit Card $
Charge Account $
Memberships $
Loans $
Credit Union $
Household Help $
Child Care $
Papers/Books/Magazines $
Entertainment $
Pay TV $
Vacation $
Gifts $
Legal Fees $
Charitable Contributions $
Other Child Support $
Alimony Payments $
Other $
Other $
Other $
Other $
Total $ 24.00
$
$ 12.50
$
$
1,125.00
30.00
1,293.90
$
$ 150.00
1432.00
$
$
400.00
$ 2,600.00
$ 104.00
$ 13,500.00
360.00
500.00
1004.26
23,712.96
5
SUSAN S. LOSTRAGLIO
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ROBERT R. LOSTRAGLIO NO. 99 - 6495 CIVIL TERM
Defendant IN DIVORCE
INCOME AND EXPENSES STATEMENT
INVENTORY AND APPRAISEMENT
OF
PLAINTIFF
Plaintiff, Susan S. Lostra4lio . files the following Inventory and
Appraisement of all property owned or possessed by either party at the time this action
was commenced and all property transferred within the preceding three (3) years.
Plaintiff verified that the statements made in this Inventory and Appraisement are true and
correct. Plaintiff understands that false statements herein are made subject to the
penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities.
Plaintiff
ASSETS OF PARTIES
Plaintiff, Susan S. Lostraglio marks on the list below
those Items applicable to the case at bar and itemizes the assets of the following pages.
If an item has been appraised, a copy of the appraisal report is attached.
( ) 1. Real Property
(X) 2. Motor Vehicles
( ) 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
(X) 5. Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
6
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
( ) 9. Life Insurance policies (Indicate face value, cash surrender value and current
beneficiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
( ) 13. Patents, copyrights, Inventions, royalties
( ) 14. Personal property outside the home
( ) 15. Business (list all owners, Including percentage of ownership, and officer/director
positions held by a party with company)
( ) 16. Employment termination benefits - severance pay, workmen's compensation
claim/award
( ) 17. Profit sharing plans
( ) 18. Pension plan (Indicate employee contribution and date plan vests)
( ) 19. Retirement plans, Individual Retirement Accounts
( ) 20. Disability payments
( ) 21. Litigation claims (matured and unmatured)
( ) 22. MIIItaryN.A, benefits
( ) 23. Education benefits
( ) 24. Debts due, Including loans, mortgages held
( ) 25. Household furnishings and personalty (Include as a total category and attach
itemized list if distribution of such asset is in dispute)
( ) 26. Other
Plaintiff, Susan S. Lostraglio , marks on the list below
7
those Items applicable to the case at bar and itemizes the assets of the following pages.
SECURED
( ) 2.
( ) 3.
( ) 4.
UNSECURE
(X) 5.
( ) 8.
(X) 7.
( ) 8.
( ) 9.
CONTINGEI
( ) 10.
( ) 11.
( ) 12.
( ) 13.
( ) 14.
( ) 15.
Mortgage
Judgments
Liens
Other secured liabilities
iD
Credit card balances
Purchases
Loan Payments
Notes payable
Other unsecured liabilities
4T OR DEFERRED
Contracts or Agreements
Promissory Notes
Lawsuits
Options
Taxes
Other contingent or deferred liabilities
8
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i
SUSAN S. LOSTRAGLIO IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,
PE NNSYLVANIA
V. CIVIL ACTION - LAW
ROBERT R. LOSTRAGLIO NO. 99 - 6495 CIVIL TERM
Defendant IN DIVORCE
PRAECIPE TO WITHDRAW ECONOMIC CLAIMS
To the Prothonotary:
Please withdraw the following Counts in the above captioned matter:
1. Count III: Divorce - Equitable Distribution
2. Count IV: Alimony Pendente Lite, Alimony, Counsel Fees and Costs
These counts were added to the original Complaint in an Amended Complaint
filed on June 19, 2000. The original Complaint should stand. Thank you.
Very truly yours,
S' 8/01
Peter J. Russo, Esq.
?gv?.xiemv-.<?,er+-:mo-.: ??vmxF.?em?„?.mre .F .n>.?sr+» _...:.:.:._ .._.. :¢ .<.«....
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(7
SUSAN S. LOSTRAGLIO,
Plaintiff
VS.
ROBERT R. LOSTRAGLIO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 6495 Civil
IN DIVORCE
ORDER OF COURT
h
AND NOW, this _? day o
2001, the economic claims raised by the Pla,
equitable distribution, alimony, alimony pendente lite, and
counsel fees and costs, having been withdrawn by praecipe
filed with the Prothonotary on August 8, 2001, and there
being no other issues pending before the Master, the
appointment of the Master is vacated.*
cc:
*
Peter J. Russo
Attorney for Plaintiff
Robert R. Lostraglio ?c./ht??lci( S /7•cl
Defendant
See letter from Peter J. Russo, counsel for Susan S.
Lostraglio, dated August 14, 2001.
BY THE COURT,
U I ?,??r, I 1 iu? II: (14
F
?
,
SUSAN S. LOSTRAGLIO
Plaintiff
V.
ROBERT R. LOSTRAGLIO
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PE NNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6495 CIVIL TERM
IN DIVORCE
PRAECIPE TO WITHDRAW ECONOMIC CLAIMS
To the Prothonotary:
Please withdraw the following Counts in the above captioned matter:
1. Count III: Divorce - Equitable Distribution
2. Count IV: Alimony Pendente Lite, Alimony, Counsel Fees and Costs
These counts were added to the original Complaint in an Amended Complaint
filed on June 19, 2000. The original Complaint should stand. Thank you.
Very truly yours,
Peter J. Russo, Esq.
*'da
1
.
., P4
Y Siwl$
j[
i
v
Suite 200.5010 Fast Trindle Road
Mechanicsburg, PA 17050
Off ers in Carlisle, PA
E. Robert Ellcker, II
Divorce Master
9 N. Hanover Street
Carlisle, PA 17013
ATTORNEY AT I.AW
Tuesday, August 14, 2001
RE: LOSTRAGLIO v. LOSTRAGLIO
Dear Mr. Elicker.
PHONE: (717) 591.1755
FAX: (717)$91.1756
Enclosed, please find a Praecipe to Withdraw Economic Claims. I
represent the Plaintiff in the above mentioned case, and she will be filing for
bankruptcy. There are no outstanding Issues, pending the divorce, therefore I
write, requesting you to vacate the Appointment of Master.
Should you have any questions or concerns, please feel free to contact
me.
Very truly yours,
Peter J. Russo
cc: Susan Lostraglio
Pharr Reppv b: 31ECHANICS11M OFFICE
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SUSAN S
Plaintiff
File No 1999-6495
.
VS. IN DIVORCE
ROBERT R. LOSTRAGLIO
Defendant
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
1*? day of /)(-1 , XX2001 , hereby elects to resume the
prior surname of SUSAN RENEE SHELLER and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE : A' )W
SeAD
Signature
• ,?aSn?? ?. ?SG? II???
Signature of name being resumed
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On On the J day of XkX2001, 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
sea l . _
CLAUDIAA.BREWBAkER,NOTARY PUBLIC
Carlisle Boro, Cumberland County
My Commission Expires April 4, 2005
t.,