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Home My WebLink About08-0366 r IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO NO. 0 8-- 3 66 CIVIL TERM Defendant : IN DIVORCE 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 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 Court House, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyers Referral Services Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO NO. 08--366 CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is Gennaro Tiano, who currently resides at 105 East Allen Street, Apt 307, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Roxanne Tiano, who currently resides at 5 Phelp, Bayville, New Jersey. 3. Plaintiff has been 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 September 8, 1992 at Bayville, New Jersey. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither plaintiff nor defendant is in the Armed Forces of the United States or any of its allies. 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, Gennaro Tiano, prays that a decree in divorce be entered dissolving the marriage between the two parties. Respectfully Submitted, f? m. C. Felker, Esquire Plaintiff ID # 67999 P.O. Box 1401 Camp Hill, PA 17001 717-512-0647 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. § 4904 relating to unsworn falsification to authorities. Date: Gennaro Tiano 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. § 4904 relating to unsworn falsification to authorities. Date: %-7'? .-,-Ico < -? Gennaro Tiano !v ? W cN W A n? --a -f1 =a i'., IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO NO. 08-366 IN DIVORCE CIVIL TERM Defendant NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties of this action separated in August 2001 and have continued separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do no 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. § 4904 relating to unsworn falsification to authorities. a- 0 ? lr?? r ' 6L?n? " Date: Gennaro Tiano -1 GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO NO. 08-366 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing Affidavit Under Section 3301(d) of the Divorce Code was served upon the party listed below via first class, United States mail, postage prepaid. Roxanne Tiano 5 Phelp Bayville, NJ 08721 February 15, 2008 William C. Felker, Esquire ? ? -r? ? _.- , -r-1 --'? -; ?' ? ?? . ? i ?X ?? >, t. ?.... ?..?.? r-^ ? -, 1 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO NO. 08-366 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AND NOW THIS 16th day of January 2008, I William Felker, Esquire, attorney for plaintiff, hereby certify that I have served a true and correct copy of the Complaint filed in the above-captioned matter along with a Notice to Defend and Claim Rights upon the defendant, Roxanne Tiano, by certified, return receipt, restricted delivery United States first class mail, to the following address: Roxanne Tiano 5 Phelp Bayville, NJ 08721 The signed receipt is hereto attached. A"I?' ?f ;74" Wm. C. Felker Attorney for Plaintiff 67999 P.O. Box 1401 Camp Hill, Pennsylvania 17001 717-512-0647 ¦ Cior"PMrle NWM 1, 2, and & Abo item 4 if Restricted Delivery is 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 mailpiece, or on the front If space permits. 1. Article Addressed to: ?a nr?Tno ? v?11e, ?T X ?Admit Addressee by (Printed Name) C. D o Delivery Tt &4- P, I D. Is delivery address different from item 1 ? ? Yes low: ? No RMU- DELIVERY 3. Type Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) es 2. Article Number 7006 3450 0003 4847 3165 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 . °rj ?y ?Q . a ` FZ5 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO NO. 08-366 CIVIL TERM Defendant : IN DIVORCE NOTICE IF YOU DO NOT WITH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COU NTERAFFI DAVIT COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2) Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 1 • understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them bE:fore a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. Date: a € G C.rf:_.,? Q? Roxanne Tiano -n C"y ? ?- ? ,?-?? -,?-? _,,,a, " t?_, _ C lj - t'S 1? iv^ ???'? ? rs? _,? ' 1 .?':. f.., C.T ,..-y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO Defendant NO. 08-366 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Affidavit Under Section 3301(d) of the Divorce Code. 3)---2-.,) Da Roxanne Tiano ? ?? n G ca ?a .--t ¢? ? ? ? ?-? ' " : ?? ,: ' : --? ' ? ' ? , ? ° _?: . y ?'=' ? ? ? ?r_ ? IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO Defendant NO. 08-366 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) 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 my 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 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. Date: -OQ? Gennaro Tiano ? ca -st ? ? ?_ ? ? v, ?:: ;? r?'t ,_„_ t w.? _ te, . ! ?"°' ??? y? r ' ' • 1 ??` s .??? ? ? r ?+. IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff V. : CIVIL ACTION - LAW ROXANNE TIANO Defendant NO. 08-366 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) 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 my 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 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. Date: 3 C1 d <1 CS r i! C.k--.- Roxanne Tiano c-n IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA GENNARO TIANO Plaintiff ROXANNE TIANO Defendant To the Prothonotary: V. : CIVIL ACTION - LAW NO. 08-366 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint January 16, 2008 by certified, return receipt, restricted delivery United States first class mail. 3. Date of execution of the affidavit required by section 3301(d) of the Divorce Code: February 4, 2008. Date of filing and service of the plaintiff's affidavit upon the respondent: February 15, 2008. 4. Related claims pending: none. 5. Date plaintiffs Waiver of Notice was filed with the prothonotary: March 17, 2008. Date defendant's Waiver of Notice in section 3301(c) Divorce was filed with the prothonotary: March 17, 2008. Date: March 17, 2008 A.m &C.Felker Attorney for Plaintiff 67999 P.O. Box 1401 Camp Hill, Pennsylvania 17001 717-512-0647 c ° CZ= r 'l; T" IN THE COURT OF COMMON OF CUMBERLAND COUNTY 4 i STATE OF PENNA. PLEAS J II ( 1 II Ndl(/ I IUI I/)i Pain-hffi 3L No. VERSUS V-4??-Tics no, Defej--dn rTf- DECIREE IN DIVORCE AND NOW, (A 21C'? k.1 DECREED THAT , IT IS ORDERED AND AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWIN CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; clan BY THE COURT: ATTE : v r7 J. PROTHONOTARY ., ? ?.., ,, ,