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HomeMy WebLinkAbout07-3508Tina E. Marchesano, Plaintiff V. William R. Marchesano, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 07- 3508 CIVIL TERM 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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. Tina E. Marchesano, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE William R. Marchesano, Defendant : NO. 07- 3 6"' CIVIL TERM DIVORCE COMPLAINT The plaintiff, Tina Marchesano, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S $$33010 AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Tina Marchesano, who currently resides at 504 North Bedford Street, Apartment 2, Carlisle, Cumberland County Pennsylvania since March 17, 2007. 2. Defendant is William R. Marchesano, who currently resides at 79 E Street, Carlisle, Cumberland County Pennsylvania since April 1, 2007. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on February 10, 1998 in Carlisle, Cumberland County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since March 17, 2007. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. oae'A??arla Corwin Certified Legal Intern ROB "RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date j(:;n3? i Plainti Tina Marchesano c.? ?:- ''" ?? o - t, =' ? , ?, ? r , ' -- ?: .? ??-? '? ?? 4 ?? ? ', C.J '.--) `?{ •+ ?? -T} ?? L..I •{ Tina E. Marchesano, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE William R. Marchesano, : Defendant :NO. 07- 3508 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Tina Marchesano, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Respectfully submitted, 0 Go, r Charla Corwin Certified Legal Intern ROBE INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?? ? c: ? ? o -n _ _,-, ?-- - ??°= ;-x-s r= _ ?rn - _ <" ??" <.s `^6s Cdi C=: p `"< Tina Marchesano, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07- 3508 William R. Marchesano, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Charla Corwin, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Defendant, William R. Marchesano, residing at 79 E Street, Carlisle, Pennsylvania, 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by William Marchesano, on the 20th day of June 2007 as evidenced by the attached green card. C) 0"Q_ a Ctmta---Corwin Certified Legal Intern ROBE T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 -W .. - ¦Pdrit ? w. ufootl Nib owd l* fe Malt cf Vw? , _ ar an ih. *ornt ? ? p t. ArMde 1x ZV3 l? t l1 AOW OA-wom" . a DOW W y &-.1"-7 Nip Odom fti irwn Own 11 E3 Ya M VW oft d*my addnee bol w. 0 No & ate. A" -'OwOl;d Mal 0 awm Mel 0 RNpletared la Retum Reow for M. on 13 koged man © C.O.D. 4. PA*icW D*mr (Extra Fee) [ Nee 2' "'teeNum 7005 0390 0003 2632 5638 ('?lansub. fio PS Form 3811, February 2004 Domoft lbbsA R 0 lpi 102595-02-M-1540; (7- ra pQ C; M ; T l 7 y rnm Fn t", Pa 1 ? ?.' ' jy l l C_ O TINA MARCHESANO, Plaintiff V. WILLIAM R. MARCHESANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE AND CUSTODY : No. 07-3508 CIVIL TERM CERTIFICATE OF SERVICE I, Candace McCauley, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving Plaintiff's Waiver of Notice of Intention to Request Entry of a § 3301 (c) Divorce Decree, Plaintiff's Affidavit of Consent, Praecipe to Transmit Record, and Divorce Information Sheet on the following person by first class U.S. Mail, postage prepaid, this 1st day of October, 2007: William R. Marchesano 79 E Street Carlisle, PA 17013 CA1rN&a1'A_' C111--_111 Candace McCauley Certified Legal Intern Anne Id-Fox, E Supervisi g Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 S 0. _ i TINA MARCHESANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. MARCHESANO, Defendant : NO. 07-3508 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on June 14, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. 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 Q" q -V Tina Marchesano, Plaintiff 0 uo ,. TINA MARCHESANO, Plaintiff V. WILLIAM R. MARCHESANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE NO. 07-3508 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I 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. I 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. 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 unworn falsification to authorities. q o9 Date Tina Marchesano, Plaintiff ;Y 0 } f -71 TINA MARCHESANO, Plaintiff V. WILLAIM R. MARCHESANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE NO. 07-3508 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on June 14, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. 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 - -O wrGx'cw K-. yaju-yuc William R. Marchesano, Defendant ? °, C`- _._, o'r's c =. _?? ..--t '? ?r t .- . ? _. ; z, =-;-' ,? J,. :. ? , ..? ,? ?: c `.# " ? ? ? `. ?. TINA MARCHESANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE WILLIAM R. MARCHESANO, Defendant : NO. 07-3508 CIVIL TERM 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. I 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. I 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. 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 q - -CJ? WdA-Lt-, t William R. Marchesano, Defend-nt r-a e €-? `? ? rt ?:-- r` , rvl t ' om . TINA MARCHESANO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW V. : IN DIVORCE AND CUSTODY WILLIAM R. MARCHESANO, Defendant : No. 07-3508 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: June 20, 2007 via U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff September 19, 2007; by defendant September 18, 2007. 4. Related claims pending: None. 5. Date plaintiff s Waiver of Notice was filed with the Prothonotary: October 1, 2007. Date defendant's Waiver of Notice was filed with the Prothonotary: October 1, 2007. kD l 10-1 Date Candace McCauley C rtified Legal Intern Anne ald-Fo"sq ire Supervising Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff IJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. VERSOS WILLIAM R.IMARCHESANO DECREE IN 2007 DIVORCE AND NOW, Oc A-ce ??? ZQO7 IT IS ORDERED AND DECREED THAT TINA MARCHESANO PLAINTIFF, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF ?ECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTER D; BY THE COURT: ATTES ROTHONOTARY NO. 3508 ? ??' ?-.1`?. ???' ? ?" ;? ?6? C ?. Q,/ ?1 ?? ?? TINA MARCHESANO, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : No. 07-3508 CIVIL TERM WILLIAM R. MARCHESANO, Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the October 10, 2007, hereby elects to retake and hereafter use her previous name of Tina Morrow, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND -1m,j))ah(iobanD Tina Marchesano Tina Morrow SS. On the Q ay of i 66LA)2007, before me, a Notary Public, personally appeared Tina Marchesano, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal. Not ow Seat Laurie L, WoK Not" ftblic Carlisle flora. Cumberland County My Cam?mission Expires Feb. 14, 2010 t -!??kjz 4TtARY C C _.? art vr`? t