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Home My WebLink About07-5117 KARF.'N PTTTELLI, : IN THE COURT OF COMMOT+t PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 07 - 5 Il'1 Civi t ~~ CIVIL ACTION -LAW GARRY BOLTON, IN DIVORCE Defendant. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. ff you wish to defend agar the claims set forth in the following pages, you must take prompt action. You are warned thy' if you fail to do so, the case may proceed without you and a decree in divorce or annulment maybe entered against you by the Court. A judgment may also be entered against you for another claim or relief requested in these papers by the Plaintiff. You ~y 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 br+eai~down of the marriage, you may request marriage counseling. A list of macrisge cswnselors is available is the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVLSION 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 COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, PA 17013 X917) 249-3166 KAREN PITT'ELLI, : IN THE COURT OF COM1biON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, CIVIL ACTION -LAW GARRY BOLTON, . IN DIVORCE Defendant. COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Karen Pittelli, by and through here. attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint in Divorce: I . The Plaintiff, Karen Pittelli, is an adult individual currently residing at 28 S. East Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant, Garry Bolton, is an adult individual curnently residing at 28 S. East Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of th+e Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiffand Defendant are husband and wife having been marriied on July 31, 2007, in Baltimore, Maryland. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. No children were born unto the marriage. 7. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 8. Plaintiff has been advised of the availability of counseling and that she has the right to request that the Court require both parties to participate in counseling. 9. The Plaintiff avers as grounds on which this action is based are: A. that the marriage is irnrtrievably broken pursuant to §3301(c) of the Divorce Code; and B. that the Defendant has offered such indignities to the person of the Plaintiff as to render the condition of the Plaintiff intolerable and life bw+densome. WHEREFORE, Plaintiffrequests this Honorable Covrt to enter a Decree in Divorce. Respectfully submitted, Manck,~, ~ Spreha ~` i~ . Richard~~gner, Esquire 2333 North Front Street Harrisburg, PA 17110 (71 ?} 2347051 Attorneys for Plaintiff Date: aS~ 07 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: ~ ~ ~ '~ 7 ~ C? ~ ~ W ~-~- ~k ~ ;~ ~ ~,. --i ` 7 G ~ ~ OHO O fU ~ G t f w _.-~ C~~ ~ _. tv ~ a =~ _ crs KAREN PITTELLI, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 2007-5117 - CIVII. TERM CIVIL ACTION -LAW GARRY BOLTON, IN DIVORCE Defendant. CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of Mancke, Wagner & Spreha, do hereby certify that on this date a copy of the Complaint in divorce was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Mr. Garry Bolton 28 S. East Street Carlisle, PA 17013 By ~ `~ ~ ~ c~~-- Debra K. Spinner, S Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff Date: y~o~~~ 7 7 # - ~' CERTIFIED Moi! ~, RECEIPT • (Domestic Mail Only; No Insurance Coverage Providec fO - - m m Poste $ 5~ O Certltied Fee , / . '' O Retum Receipt Fee (Endorsement Required) a~ / ,~ Postrnerk Here ~ `~ Restricted Delivery Fee (Endorsement Required) 'yi /Q r~ ~ TotelPostage 8 Fees $ ~ ~7 u7 O o O ~` --- ---~--` -------------------n---------- ----- --=---- ~J-( --------------°------ SYree4 Api' ; or PO Box No. ~~, s~~ ~~~~~ few r ~oi3 ^ caawe (Printed Name) C`Date of Delivery O -~(p.,c-7, address different from kem 1? ^ Yes enter delivery address below: ^ No ~ryG~~i~r / ~ /7~ ~ 3. e Type ified Mail ^ Fxpr~s Mail ^ Registered ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) Yes s. 'artsole Number 7 D 0 5 116 D D D D 1 .3 3 2 D 8 8 5 6 (Transfer from service later PS Form 3811, February 2004 Domestic Retum Receipt 102595-02-M-154® ^ Complete items 1, 2, and 3. Also complete A. ~ item 4 if Restricted Delivery is desired. ^ Print your narrRran~l9dress on the reverse so that:we erratum the card to you. B ^ A,ttach this to the back of the mailpiece, or on the if space permits. D. Is 1. Article Ad ~ to: ffjj~~ ~~ ~~yy~~,, ff ~.. ~ J~.~~'L60'~ ,s ~ --~ ~ ~ ~ ' ~ ~ ' ~` -~' '~ J c,._ ~, r F43 ~ KAREN PITTELLI, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 07-5117 - CIV1L TERM CIVIL ACTION -LAW GARRY BOLTON, Defendant. IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 27, 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. 4. 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. 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 unsworn falsification to authorities. DATE: ~~~~ ~Ct_c,e zz " f Karen Prttelli n n.~ cr_ '~ e~ ~„ 'rj t= ~, re•~:.- ~ --} ..... _,. ~r z~ ~ r "-C : ~ ~C7 . Cw~ _ ,~- . ~ ~ KAREN PITTELLI, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. GARRY BOLTON, Defendant. NO. 07-5117 CIVIL ACTION -LAW IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 axe ttue 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. ~~Z ~~ ~?.~~~ Karen Pittelli DATE: /~I/~/~7 KAREN PITTELLI, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, ~, : NO. 07-5117 -CIVIL TERM CIVIL ACTION -LAW GARRY BOLTON, Defendant. IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 27, 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. 4. 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. 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 unsworn falsification to authorities. DATE: 1a ~~~D ~ ~ ~ Garry Bo n ~? O '` ~ ~ m ~ ' `~ ~ ~ N .._. ~ ~: ~ ( ~ ._ ~_ "U t ~ ?., ~ ~ ~ .. „ '~ KAREN PITTELLI, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. GARRY BOLTON, Defendant. NO. 07-5117 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Garry Bol on DATE: /~ /y d ~° r a v .-~ ~~ t-~"' r~'~a: L'7 r~ N _Q Q ~ ~,:: ~ -~ ~ KAREN PITTELLI, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 2007-5117 -CIVIL TERM CIVIL ACTION -LAW GARRY BOLTON, IN DIVORCE Defendant. PRAECIPE TO TRANSMIT THE 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 Section 3301(c) , 3~ \d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: September 10, 2007 by certified mail, restricted delivery, return receipt requested, a copy of an Acceptance of Service is attached. 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: By Plaintiff: 12/14/07 By Defendant: 12/14/07 (b) (1) Date of Execution of the Plaintiff s Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs AflSdavit unto the Defendant: 4. Related claims pending: None 5. (Complete ether (a) or(b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1 xi) of the Divorce Code: .~ (b) Date Plaintiff s Wavier of Notice was filed with the Prothonotary: 12/20/07 (c) Date Defendant's Waiver of No ' as filed with the Prothonotary: 12/20/07 .Ric W er, Esq. tto ey fof Plaintiff N p -ri t ~ ~ ~ ~ ~~ t-,, ;:, r_ ,: _ :~µ ~ "% .~'c~ .. ~! ~ --t 1 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ ~ PENNA. _~- _ KAREN PITTELLI N o . ZQ(17-5 I 1 ~ - ~I~~-- VERSUS DECREE IN DIVORCE AND OW, `~e,ee,.,t,,.i ~~ ~ , took IT IS ORDERED AND KAREN PITTELLI DECREED T AT PLAINTIFF, CARRY BOLTON AND DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE CO RT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RATS D OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN NTERED; BY THE OURT: ~! ATTE :~ J, PROTHONOTARY ~~