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HomeMy WebLinkAbout03-5390 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 64 SOUTH PITT STREET CARLISLE PA '170'13 (7'17) 243-6090 ATTORNEY FOR PLAINTIFF TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW FRANK C. LAQUITARi~_, JR., : NO. 03 - ~'-3~0 CIVIL TERM Defendant : IN DIVORCE NOTICE 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 in 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 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 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 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, Pennsylvania 17013 717-243-3166 TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ; v. : CIVIL ACTION - LAW : FRANK C. LAQUITARA, JR., : NO. 03 - ~;~) CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Terri S. Laquitara, an adult individual residing at 544 North Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The defendant is Frank C. Laquitara, Jr., an adult individual residing at 214 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on June 15, 1991, in West Warwick, Rhode Island. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this complaint 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. October ~ ,2003 /-~ ~- ~.~._.~ ~ Terri $. Laquitara, PI~i~tT~ N;~'~~'~E SQU I RE I,~NI~W OFFICE ~JJl~reme Court ~D #87380 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Attorney for Plaintiff TERRI $. LAQUITARA, : IN THE COURT OF COMMON pl_~__a_$ OF Plaintiff : CUMBERLAND COUNT~ PENNSYLVANIA : CIVIL ACTION - LAW F~NK C. LAQUITA~ JR., : NO. 03 - 5390 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Mark F. Bayley, Esquire, hereby certify that I represent the defendant, Frank C. Laquitara, Jr. and that I am authorized to accept service on his behalf. Furthermore, hereby certify that on (:~N?.~{~.~' ~'~ , 2003, I received a certified copy of the divorce complaint filed in this action. October ~.~, 2003 Mark F. Bayley, Esquire Counsel for Defendant NATHAN C. WOLF~ ESQUIRE A3'rORNBY ID NO. 87380 64 SOUTH PITT STREET CARLISLE PA t70t3 (7t7) 243-6000 ATTORNEY FOR PLAINTIFF TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW ., FRANK C. LAQUITARA, JR., : NO. 03 - 5390 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about October 10, 2003 and served upon defendant on October 23, 2003 (see acceptance of service November 18, 2003). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verifl/ that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. TERRI S. LAQUITARA ~-~"" NATHAN C. WOLF, ESGUIRE AI'TORNEY iD NO. 87380 84 SOUTH PII'T STREET CARLISLE PA 17013 (717) 243-GOG0 AI'rORNEY FOR PLAINTIFF TERRI S. LAQUITARA~ : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND GOUNTY~ PENNSYLVANIA : v. : CIVIL ACTION - LAW FRANK C. LAQUITARA, ~/R.~ : NO. 03 - s3g0 CIVIL TERM Defendant : 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. Section 4904 relating to unsworn falsification to authorities. NATHAN C. WOLF~ ESQUIRE ATTORNEY ID NO. 87380 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6000 ATTORNEY POR PLAINTIFF TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v, : CIVIL ACTION - LAW .. FRANK C. LAQUITARA, JR. : NO. 03 - 53g0 CIVIL TERM Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about October 10, 2003 and served upon defendant on October 23, 2003 (see acceptance of service November 18, 2003). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. I~RANK C. LA~I~.JIT,~RA, JR. TERRI $. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW FRANK C. LAQUITARA, JR., : NO. 03 - 5390 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330t(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. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. FRANK C. LA~UI'~I[RA, JR. ,~ TM TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW ., FRANK C. LAQUITARA, JR., : NO. 03 - ~ (~ CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. October ._~, 2003 TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; FRANK C. LAQUITARA~ JR., : NO. 03 - 5390 CIVIL TERM Defendant : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F~ank C. Laqui[ara~r. Defendant NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF TERRI S. LAQUITARA, : IN THE COURT OF COMMON PLEAS OF Plaimiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : CML ACTION - LAW FRANK C. LAQUITARA, JR., : NO. 2003 - ~390 CML TERM Defendant : IN DIVORCE PRAECIPE TO T1LANSMIT RECO~T~ To the Prothonotaay. decree: Transmit the reco~ together with the following ioform~;nn, to the court tcor entry otc a divorce 1. Ground tcor divorce: Irretrievable brealztown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the compJaiot: On or about October 23, 2003, defendant's counsel was served with a copy otc the divorce complaint via regular mail, addressed to the defendant's counseL (See fl~cceptance otc Service previouslytciled.) 3. Complete either paragraph (a) or CO): (a) Date of execution of consent requited by Section 3301 (c) of the Divorce Code: Bythe plaintiff: Ma~h 1,2004. By the defendant: February 26, 2004. CO)(1) Date of execution of the affidavit required bySection 3301(d) of the Divorce Code: N/A. CO)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/ 4. Re~ed clah~ penc~g: None 5. Complete either (a) or Co): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. Co) Date plaintiff's Waiver of Notice ia Section 3301(c) divorce was fiLM with the Prothonotary:. March 2, 2004. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:. March 2, 2004. August .~, 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Terri S. Laquitaza N O. 2003 5390 VERSUS Frank C Laq.;~,~, Jr. DECREE IN 01 . AND NOW, September q , . 200,41T IS ORDERED AND Terri $. Laquima DECREED THAT Frank C Laqui~-~ Jr. ., P-AINt~ff. AND . DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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 BEEN ENTERED; BY THE COURT: