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HomeMy WebLinkAbout99-07556 I d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. woz?- ARENA II No. 99-7556 VERSUS ROXANNE AREN& 1I DECREE IN DIVORCE AND NOW, 01 / , IT IS ORDERED AND DECREED THAT MAURIZIO ARENA _, PLAINTIFF, AND ROXANNE ARENA , 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; None. BY ATTEST: D J. PROTHONOTARY .. 1 i y •• ( w , 1 __? __ _.r..??_. l MAURIZIO ARENA, Plaintiff V. ROXANNE ARENA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-7556 CIVIL ACTION - LA W IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary ofSnid Court: Transmit the record, together with the following in formation, to the Court for entryofa Divorce Decree: Ground for divorce: irretrievable breakdown tinder Section 339-" 3301(d)(I)ofthe Divorce Code. (Strike out inapplicable section.) 2• Datc and manner of service of the Conmplaint: April 9, 2000 by Acceptance of Service. 3. (ComPlete either paragraph (a) or (b)) (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code. (b) (I) Dale of execution Of tile Plaintiffs Affidavit required bySection 3301(d) ofthe Divorce Code: June 8, 2001 (2) Date of service of the Plaintiff's Affidavit upon the Defendant: June 12, 2001 (Certificate of Service Filed) 4. Related claims pending: None. rt 1 'i t i r r 5. Date and manner of service of the notice of intention to file praccipe to transmit record, a copy of which is attached: (check one) X (a) Decree to be entered under 3301(d)(1) of the Divorce Code; (b) Decree to be entered under 3301(c) of the Divorce Code; - (c) Not applicable. 6. Plaintiff's Social Security number: 181-64-8707 Defendant's Social Security number: 542-92-4866 Date: 36 99.6841268114 r (X) P9. muff / ( ) Defendant ouglas K. Marsico, Esquire CALDWELL & KEARNS Attorney ID9 69804 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 ????? ., ?; ?' .? ? ? ' J ' . 1 J : + ' n ; '-. " L ,,? , 5z _ ? ??' riti .::: :?_ =' O U - ? I -?.'I ?_?=mac.!-+.? :::-<::s^-^"`°'"^^ .17 - MAURIZIO ARENA, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * Q V. * NO. _l q - 75 SG * * ROXANNE ARENA, * CIVIL ACTION - LAW 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 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 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 Courthouse, One Courthouse Square, Carlisle, PA 17013. 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 Comity Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 98-684/5466 MAURIZIO ARENA, * IN THE COURT OF COMMON PLEAS Plaintiff * CUMBERLAND COUNTY, PENNSYLVANIA * V. NO. * * ROXANNE ARENA, * CIVIL ACTION - LAW Defendant * IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DOMESTIC RELATIONS CODE Plaintiff is Maurizio Arena, an adult individual who resides at 4341 Carlisle Pike, Apartment B-7, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Roxanne Arena, an adult individual with a last known address of 3134 NE 50th Street, Portland, Oregon, 97213. 3. The Plaintiff and Defendant were married in Cumberland County in 1996. 4. There have been no prior actions in divorce or annulment between the parties. 5. The Defendant is not a member of the armed forces of the United States or any of its allies. 6. The Plaintiff avers that the marriage is irretrievably broken. 7. The Plaintiff and Defendant have been separated since May 28, 1999. 8. 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. The Plaintiff does not desire counseling. 9. The Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 10. The Plaintiff avers that there are children ofthepartiesundertheageofeighteen(18), namely: Name Date of Birth Angela Arena May 11, 1993 Monica Arena January 28, 1997 11. Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, CALDWELL & KEARNS ByC / D . Marsico, Esquire omey ID No. 69804 Attorney for Plaintiff 3631 North Front Street Harrisburg, Pennsylvania 17110-1533 (717) 232-7661 Q Date: 12-15-99 99.684/5462 VERIFICATION I, MAURIZIO ARENA, do verify that the statements made in the foregoing document are within the personal knowledge of the undersigned, are true and correct, and as to the facts based on the information of others, the undersigned, afler diligent inquiry, believe it to be true. And further, that I signed this Verification on the recommendation of my attomeys, who advise me that the allegations and language in this document are required legally to raise issues for resolution at trial, by the Court, or by continuing investigation and preparation for trial. I understand that some of these allegations may prove inappropriate after investigation and trial preparation are complete and I leave determination of these matters to my attorneys on their advice. I understand that all statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unswom falsifications to authorities. CMQ AA I&J/A 0 AQ OA Q- MAURIZIO ARENA Date: ) Z l6 I r MAURIZIO ARENA, Plaintiff * * V. * * ROXANNE ARENA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. q4 - 955c, CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I do hereby accept service of and acknowledge receipt of a copy of the Complaint Under Section 3301 (c) or (3301 (d) of the Domestic Relations Code in the above case. ROXANNE ARENA Date: 99.684/5463 MAURIZIO ARENA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ROXANNE ARENA, Defendant NO. 99-7556 CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action have been separated since May 28, 1999, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights conccming alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 unswom falsification to authorities. Date. 9 Q/ __1 ?Q R 6^ Q (SEAL) 99.484 242'6) Mauririo Arcna CERTIFICATE OF SERVICF. ANDNOW,this 01" day of June, 2001,1 hereby certify that I have servedacopy of tile within document on the following by depositing a true and correct copy ofthe same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Ms. Roxanne Arena 6324 SE 142"' Avenue Portland, OR 97236 CALDWELL & KEARNS By: MAURIZIO ARENA, Plaintiff V. ROXANNE ARENA, Defendant TO THE PROTHONOTARY: * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, PENNSYLVANIA * * * NO. 99-7556 Civil * * CIVIL ACTION - LAW * IN DIVORCE PRAECIPE PLEASE reinstate the attached Complaint in the above-captioned matter which was originally filed on December 17,1999. Respectfully submitted, CALDWELL & KEARNS BYE ????' ?jC as K. Marslco-Esquire _ Attorney ID No. 69804 Attorney for Plaintiff 3631 North Front Street Harrisburg, Pennsylvania 17110-1533 Date: (717) 232-7661 99-684/6511 MAURIZIO ARENA, * IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA * * V. * NO. 99-7556 Civil * * ROXANNE ARENA, * CIVIL ACTION-LAW Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY: PLEASE reinstate the attached Complaint in the above-captioned matter which was originally filed on December 17,1999. Respectfully submitted, CALDWELL & KEARNS A3v Marsi?- / ttorney ID No. 69804 Attorney for Plaintiff 3631 North Front Street Harrisburg, Pennsylvania 17110-1533 (717) 232-7661 I•: 1 IE li 'i j.: Date: April 10, 2000 99.684/6511 ., ?,k,?,,;_......,....w.,,...?.,..... MAURIZIO ARENA, V. ROXANNE ARENA, IN'rl IE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA No. 99-7556 : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE Personally appeared before me, a Notary Public in and for said County and State, DOUGLAS K. MARSICO, ESQUIRE, who deposes and states that on the 12" day of June 2001, he mailed a true and correct copy ofthc Plaintiffs Affidavit. Ile also mailed a blank Counter-Affidavit tinder Section 3301(d) of the Domestic Relations Code, which was served on the same day, June 12, 2001. Ile fimher served a copy ofthe Notice of Intention to Request Entry ofa Divorce Decree and a copy of the Praecipe to Transmit Record on July 9, 2001, by United States first class mail, with attached Certificate of Mailing, addressed to Defendant at Defendant's last known address, as follows: Ms. Roxanne Arena, 6324 SE 142i' Avenue Portland Oregon, 97236 A copy of the Certificate of Mailing (PS Form 3817) is attached hereto, marked as Exhibit "A" and made a part hereof by reference thereto. Sworn to and subscribed this ?'Ai dayofJuly,2001. ? arsic?,L•sgtarc-- ey for Plaintiff; Maurizio Arcna 4r v blic My Commission Expires: NOTARIAL SEAL TAMARA S. HAIR, fJotery pubic mi.ox?,+exm City of liarrlst urg, Uauphh CW* My Commission Expires Aug, 26 2004 I ?i i !' Exhibit A N 0i - t. ti ri c C .; ,. ?c'• V.S. PI+.Ci?A ?:' ?a 07 ILU ?J J r I g y E 'I E P m ^, Q 11 I ? y a ?; -rya MAURiZ10 ARENA : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROXANNE ARENA : NO. 99-7556 CIVIL TERM ORDER OF COURT AND NOW, this Ir4h4 day of AUGUST, 2001, plaintiff is directed to comply with Pa. Rule of Civil Procedure 1920.42(d)(1)(2). We will then reconsider his request for the entry of a decree in divorce. e Cou , Edward E. Guido, J. Douglas K. Marsico, Esquire For the Plaintiff I / iw? a 2 ?( /r a 9- ?I ? i CUs?:.r.'v' vJ (.GU\TY PENNSYLVANIA ii . L _ MAURIZIO ARENA, Plaintiff V. ROXANNE ARENA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-7556 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary of Said Cottrt. Transmit the record, togetherwith the following information, to the Court forentryofa Divorce Decree: I . Ground for divorce: irretrievable breakdown under Section 3301(cj 3301(d)(1) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: April 9, 2000 by Acceptance of Scrvice. 3. (Complete either paragraph (a) or (b)) (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code. (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: June 8, 2001 (2) Date of service of the Plaintiffs Affidavit upon the Defendant: June 12, 2001 (Certificate of Service Filed) 4. Related claims pending: None. 5. Date and manner ofservice of the notice of intention to file praccipe to transmit record, a copy of which is attached: (check one) X (a) Decree to be entered under 3301(d)(1) of the Divorce Code; served by United States First Class Mail on July 9, 2001. See filed Affidavit of Service. - (b) Decree to be entered under 3301(c) of the Divorce Code; - (c) Not applicable. 6. Plaintiffs Social Security number: 181-64-8707 Defendant's Social Security number: 542-92-4866 Date: o9-6sannaw .AYtonid" (X) Plainti '/ ( ) Defendant Douglas K. Marsico, Esquire CALDWELL & KEARNS Attorney ID# 69804 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Li-a 11. rl .1 [V L.. J F 1 J •II U 7 0 Exhibit A ,. MAURIZIO ARENA, Plaintiff IN THECOURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ROXANNE ARENA, Defendant No. 99-7556 Cl V1L ACTION - LA W IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Ms. Roxanne Arena 6324 SE 142"' Avenue Portland, OR 97236 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the Plaintiffs Affidavit. Therefore, on or after July 30, 200 1, the Plaintiff can request the Court to enter a Final Decree in Divorce. If you do not file with the Prothonotary of the Court an Answer with your signature notarized or verified or a Counter-Affidavit by the above date, the Court can enter a Final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 99.684/26800 MAURIZIO ARENA, Plaintiff IN TIIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ROXANNE ARENA, Defendant No. 99-7556 CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Ms. Roxanne Arena 6324 SE 142"' Avenue Portland, OR 97236 Maurizio Arena, Plaintiff, intends to file with the Court the attached Praecipe to Transmit Record on or after July 30, 2001, requesting that a final Decree in Divorce be entered. Respectfully submitted, CALDWELL & KEARNS Dated: / 99-684/2680 GI703&-marstco mey ID# 69804 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 c. I-) q7 c7 U a t THOMAS T. MILLER., Plaintiff V. KATHERINE K. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99-7566 CIVIL TERM DIVORCE IN RE: MOTION FOR BIFURCATION ORDER OF COURT AND NOW, this 17th day of April, 2003, this matter having been called for hearing, on agreement of the parties, the motion for bifurcation is granted, and a decree reserving economic issues will be entered upon submission of a proposed decree to the Court in the normal form. The existing spousal support order will be converted to an order for alimony pendente lite upon the entry of the decree. Any costs which the wife hereafter incurs for health insurance for her and/or the child of the parties will be shared by the parties in such proportion as shall be determined by the Domestic Relations Office. By the Court, Melanie L. Erb, Esquire 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 For the Plaintiff Diane G. Radcliff, Esquire 3448 Trindle Road Camp Hill, PA 17011 For the Defendant • X? Kevi A. Hess, J. :mae l ;,r . " ., ??? ?: . -:?,.: