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HomeMy WebLinkAbout07-4072c LAW OFFICES OF PETER J. RUSSO, P.C. BY: SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 stein@pjrlaw.com JENNIFER A. ALBRIGHT Plaintiff v. DAVID M. ALBRIGHT Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW : NO. 2007 - va 7~CIVIL TERM IN DNORCE 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 n:lief 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 man iage, you may request marriage cainseling. A list of marriage c~unsebrs is available in the Office of the Prothonotary at Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 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, 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. Gumberiand County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 ! ~ LAW OFFICES OF PETER J. RUSSO, P.C. BY: SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 PH: (717) 591-1755 F: (717) 591-1756 sstein@pjrlaw.com JENNIFER A. ALBRIGHT Plaintiff v. DAVID M. ALBRIGHT Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007 - yo ~z.CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff by and through her attorney Scott A. Stein, Esquire and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is Jennifer A. Albright, an adult individual who has resided at 41 Brentwood Road, Camp Hill, Cumberland County, Pennsylvania since October of 1995. 2. Defendant is David M. Albright, an adult individual who has resided at 1916 Kent Drive, Camp Hill, Cumberland County, Pennsylvania since January of 2007. 3. Plaintiff and Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at lease six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 25, 1991 in Onondaga County, New York. R 5. Plaintiff and Defendant were separated on January 9, 2007. 6. The marriage is irretrievably broken. 7. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 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, but does not request the same. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff, Jennifer A. Albright, prays that a decree be entered in favor of the Plaintiff and against Defendant dissolving the marriage between the two parties. The Law Offices of Peter J. Russo, P.C. ,~ Scott A Stein, Esq ire Attorney I.D. No. 81738 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Attorney for Plaintiff Date: 7 - 3 ~ ~` "( VERIFICATION I, Jennifer A. Albright, verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date. Wife .Albright c~'`, ''~ .R _., v ~ jJ -r7 f i "1 C . ('~ ~'(`} ~ ~ .~ ~- a -f' J _, C J vi G LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com JENNIFER A. ALBRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW DAVID M. ALBRIGHT, N0.2007-4072 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on July 9, 2007, and served on Defendant on July 11, 2007. 2. The marriage of plaintiff and defendant is irretrievable broken and ninety 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: (~"~"~ c ~~`_ J ni a A. Albright ~IL~G-- _ _ ,.. LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com JENNIFER A. ALBRIGHT, Plaintiff, v. DAVID M. ALBRIGHT, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-4072 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301 (d) 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 statement 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: ~ -~ - GT ~ ~ ~;" ~~~,~ .~ ~ ~.--__. ,~ enni r=.A. Albright ~F The ~?~='l`~~~~j~t~t~~[Y 10D9 X19 -9 A~ ~~ 0~ MARIA P. COGNETTI & ASSOCIATES KELLY A. SPARVIERI, ESQUIRE Attorney I.D. No. 200864 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (.717) 909-4060 Attorneys for Defendant JENNIFER A. ALBRIGHT, IN THE COURT OF COMMON PLEAS Plaintiff v. DAVID M. ALBRIGHT, Defendant CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 2007-4072 CNIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 9, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the 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: ~ f L /a~ ~~~~ DAVID M. ALBRIGH 4~ THc" ~~~]~-~n~,fn~4f~Y 2(tQ9 J~1N -9 A~1 3~ 09 rJ MARIA P. COGNETTI & ASSOCIATES KELLY A. SPARVIERI, ESQUIRE Attorney I.D. No. 200864 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Defendant JENNIFER A. ALBRIGHT IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v• :DOCKET NO. 2007-4072 CIVIL TERM DAVID M. ALBRIGHT :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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: ~~z ~04 (~~`~ DAVID M. ALBRIGHT F{L~~`'J~~=iC~ ~7E THE F~;?~-'; ~~'JTA;FI 209 JUG _~ ~~9 9~ 49 CUM+~~:.;_ ~:..;~ ~NTY PE~Rdt~SYLb'l~NCA. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com JENNIFER A. ALBRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW DAVID M. ALBRIGHT, NO. 2007-4072 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the Defendant's Affidavit of Consent, Defendant's Waiver of Notice, Plaintiff's Affidavit of Consent, Plaintiff's Waiver of Notice, Praecipe to Transmit Record, and Proposed Divorce Decree upon the person(s) and in the manner indicated below: U.S. Mail addressed as follows: Kelly A. Sparvieri Maria P. Cognetti & Associates 210 Grandview Ave, Suite 102 Camp Hill, PA 17011 Date: (~~p (©9 ~ O ~j L. ~ \'. Ashley .Sipe, Pa alegal ~L-' ~``'~1~'`' ~r , u~. t~ 't'H~ ~~r3~, ,xs~{~1'A~Y ,~. ~: 1009 J~#~ -9 A~ 9~ ~~ LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com Attorneys for Plaintiff JENNIFER A. ALBRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v• CIVIL ACTION -LAW DAVID M. ALBRIGHT, NO. 2007-4072 CIVIL TERM Defendant IN DIVORCE AFFADAVIT OF SERVICE I, Ashley R. Sipe, hereby certify that on July 11, 2007 the Divorce Complaint was served upon defendant in the manner indicated below: Certified Mail, Restricted Delivery, Return Receipt Requested and addressed as follows: David M. Albright 1916 Kent Drive Camp Hill, PA 17011 ~~b ~ Date i _. Ashley R Sipe i ~, ~.~ LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com JENNIFER A. ALBRIGHT, Plaintiff, v. DAVID M. ALBRIGHT, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.2007-4072 CIVIL TERM IN DIVORCE ^ Complete Items 1, 2, and 3. Also complete Hatt 4 ff Restricted !Je{ivery fs desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the maiipiece, or on the front ff space permits. 1. Artk~e Addressed to: 1°i1~ ~~~C~v~ A. Signature ~ ~+ / B. Received ~ (PrlMed 1 C. Data of Delhrory ~'~~-7 D. Is delivery address diRerent from Item 1? ^ ~ K YES, eater delivery address Gelow: ^ Quo 3. Certllbd Mail O Mali ^ Registered ~i Receipt fa Men;Fandlee ^ Insured Mail ^ C.O.D. 4. ReshiCted Deliveryl (ExOra Fee) Y~ 2. Article Number - - (iienekr rro-rr servioeMb~l3 7 f7 0 6 0 81 ~ 1] 0 i] 6 10 5 2 717 3 PS Form 3811, Fetxuery 2004 Domestic Return Receipt tom-ra.tsw ; ~F THE P~ ~~-rc,.,r~~,',,~?'RPY 2Qfl9 Jt1~ -9 ~ 9: U~ s LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com JENNIFER A. ALBRIGHT, Plaintiff, v. DAVID M. ALBRIGHT, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007-4072 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: 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 filed on July 9, 2007: Certified Mail, Return Receipt Requested, Restricted Delivery to Defendant, who accepted service on July 11, 2007. 3. Date of execution of the Affidavit of Consent and Waiver of Notice required by § 3301(c) of the Divorce Code: (a) By Plaintiff Jennifer A. Albright, on June 5, 2009; (b) By Defendant David M. Albright, on June 1, 2009 4. No other related claims are pending. 5. Plaintiff's Affidavit of Consent and Waiver of Notice were filed on Tuesday, June 9, 2009. Defendant's Affidavit of Consent and Waiver of Notice were filed on Tuesday, June 9, 2009. LA_1~1(QF~CES OF PETER J. RUSSO, P.C. Attorn s for Pla -- Peter J. Russo, Esquire ID # 72897 Elizabeth J. Saylor, Esquire I D # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: CQ (4 109 ~ • LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com JENNIFER A. ALBRIGHT, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW DAVID M. ALBRIGHT, N0.2007,407Z CIVIL TERM Defendant !N DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the Praecipe to Transmit Record, and Proposed Divorce Decree upon the person(s) and in the manner indicated below: U.S. Mail addressed as follows: Kelly A. Sparvieri Maria P. Cognetti & Associates 210 Grandview Ave, Suite 102 Camp Hill, PA 17011 Ashle . Sipe, P ralegal Date: ~y,(~Q, 9 ~ ?~lJ6`~ F~~}-'~~rIL~ f3~ 7Hc P~~~~F~?'~~7T~RY 2Q~9 sU~ ! 0 P~ 1 ~ 29 ~'~;N4~~Y'~.1,r'~~iA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jennifer A. Albright V. David M. Albright NO 2007-4072 DIVORCE DECREE AND NOW, ~'/yn.~.. /L ~ zso'I , it is ordered and Giecreed that Jennifer A. Albright plaintiff, and David M. Albright ,defendant, are divorced!from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an prder for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties td this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") Parties stipulated property settlement agreement dated May 28, 2009 is incorporated but not merged. By the Court, ~1~ ~ o~ ~~1~~09 ~x - ~~ ~ ~ ~~ ~~~ ~.. ~ a