HomeMy WebLinkAbout99-07556
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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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
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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.
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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
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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
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Date: April 10, 2000
99.684/6511
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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
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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
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Exhibit A
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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
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CUs?:.r.'v' vJ (.GU\TY
PENNSYLVANIA
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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
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Exhibit A
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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
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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
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Kevi A. Hess, J.
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