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
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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.
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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
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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:
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Jan a L. Nigro
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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
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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
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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
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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
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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
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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
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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;
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JANINE L. NIGRO
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