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HomeMy WebLinkAbout07-2093JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW AARON C, NIGRO, NO. D -7 ?.p93 c ; ,,, ( 4 erlst - Defendant IN DIVORCE NOTICE TO DEFEND 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 FLOWER & LINDSAY ATNIQ M AT IAW 26 West High Street Carlisle, PA SAIDIS, F E & LINDSAY `Robe C. Saidis Es it qu e Attorney Id. 21458 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW AARON C, NIGRO, : NO. 6 7 - °2093 ?gv°l ft?? Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Janine L. Nigro, an adult individual residing at 1216 Brandt Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Aaron C. Nigro, an adult individual residing at 107 Spruce Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 7, 2006 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the FLOWER & LINDSAY nrrowve?s.,truw 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. r WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOVVER/& LINDSAY (Robert V. Saidis, E9quire Attorney Id. No. 21458 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: 4-n-o Counsel for Plaintiff FLOWER ? LINDSAY ;NMW 'VS AT-UW 26 West High Street Carlisle, PA r VERIFICATION I verify that the statements made in the foregoing document are true and correct. I SAIDIS, FLOWER & LINDSAY Artotuvets.AT uw 26 West High Street Carlisle, PA understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. Date: r -afjwlflm/? Jan a L. Nigro Q q l!\ V V 2-1 ,F71 , W W = V Q JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 07-2093 -CIVIL TERM AARON C, NIGRO, ; Defendant IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the attached Divorce Complaint originally filed in the above captioned case on April 13, 2007. Respectfully SAIDIS; Fj, & LINDSAY Robert/C. Saidis`, Esquire Attorney Id. 21458 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff FLOWER & I ENDSAY MIMMATMIAW 26 West High Street Carlisle, PA ra ' A ' t tt ? c C" 33T C«:' 33 ll. W co -< JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 01-A, 0q3 AARON C. NIGRO, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Aaron C. Nigro, accept service of the Complaint in Divorce in the above-captioned matter. Date Aaron C. o FLOWER & LINDSAY nrrowvE?•xruw 26 West High Street Carlisle, PA c? c fil ; Fu G? r , ? JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2093 AARON C. NIGRO, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on April 13, 2007. 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. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: nine L. Nigro PLAINTIFF'S 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. 1 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the SAIDIS, FLOWER & LINDSAY AMFNMartww 26 West High Street Carlisle, PA Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn fats' cation to author i Date: Ja a L. Nigro CD U-) lL4J K:X 0 C`j [ Er- C3.. y F-- CD r r i wi f C= JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2093 AARON C. NIGRO, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on June 13, 2007. An Acceptance of Service was filed with the Court on June 27, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: September 18, 2007 and filed with Prothonotary on October 12, 2007 By Defendant: October 21, 2007 and filed with Prothonotary contemporaneously herewith. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: September 18, 2007 and filed with Prothonotary on October 12, 2007 By Defendant: October 21, 2007 and filed with Prothonotary contemporaneously herewith. SAIDIS, FLOWER & LINDSAY ArroRNUS.Ar[AW 26 West High Street Carlisle, PA SAIDIS, FLOWER,$t LINbSAY Robert C. Saieris, Esquire Attorney Idr No. 21458 26 West High Street Carlisle, PA 17013 717-243-6222 ;-... ? ?. ,.; - -? s ?...tl ? ; .?. ?.?. f, ,? ?;`e' " } ?, ''-? _ ? . --?. ¦ V. CIVIL ACTION -- LAW NO. 07-2093 AARON CHARTS NIGRO, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on April 13, 2007. 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. 1 consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 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. JANINE LEA GUIDO, Plaintiff Date: J I I on IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA - / ? , /1? ?? Aar n C. Nigro DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER§ 3301(c) OF THE DIVORCE CODE 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsiT authorities. 26?' Date: G 1/077 A4 6n C. Nigro _ CD ? - . r?te"? JANINE L. NIGRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2093 - CIVIL TERM AARON C, NIGRO, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that Janine L. Nigro, the Plaintiff in the above matter, having filed a Complaint in Divorce on April 13, 2007, hereby intends to resume and hereafter use the previous name of JANINE L. GUIDO, and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. - I mdal Ja L. Nigro TO BE KNOWN AS: 4 Ja ne LDljmAa-11J'? . Guid SAIDIS, FI-OVVFR & LIlVDSAY ffi1URNM1 U uW 26 West High Street Carlisle, PA COMMONWEALTH OF PENNSYLVANIA COUNTY OF C LLnL -b er)0-A--0 .- ss. ON this, the th day of 021-0 b e,,C , 2007, before me, a Notary Public, personally appeared Janine L. Nigro, also known as Janine L. Guido, known to me or satisfactory proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOMMALSM BARBARA B. SUM, Notry PARe Caftb Borg, Jxind Jy, PA otary Public Commb" im J 7 1011 C ? ? -rt :zz tJ'.f 4.i 1 V VV IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JANINE L. NIGRO VERSUS AARON C. NIGRO N 07-2093 O. DECREE IN DIVORCE AND NOW, DECREED THAT AND AARON C. NIGRO ,'O?7, IT IS ORDERED 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 EEN ENTERED; v k-jQ- oa4vi4, -jj JANINE L. NIGRO - Al?v 7 ir7,,m r ?- Q- -C - ii •