HomeMy WebLinkAbout03-6649HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
94 SOUTH PITT STREET
CARLISLE PA 17015
(717) 2438090
ATTORNEY FOR PLAINTIFF
ANTONINO MARCHIANO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. OS -?41CIVIL TERM
FAITH A. MARCHIANO,
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
f RUE COPY FROM RECORD
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ANTONINO MARCHIANO,
PlalntIf
v.
FAITH A. MARCHIANO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 03 - _ CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION
3301(c) OF THE DIVORCE CODE
NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files
this complaint in divorce against the defendant, representing as follows:
1. The plaintiff is Antonino Marchiano, an adult individual residing at 149
Cedar Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Faith A. Marchiano, an adult individual residing at 149
Cedar Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The parties have been residents of the Commonwealth of Pennsylvania at
least six months prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on October 29, 1996, in Mt.
Holly Springs, Cumberland County, Pennsylvania.
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 he has been advised of the availability of
counseling and that she 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 two parties.
I verify that the facts contained herein 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.
December 7,, 2003 i' I4(11tq w J&<4 64X
ANTONINO MARCHIANO, Plaintiff
HAROLD S. IRWIN, II
Attorney for Plaintiff
64 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court ID No. 29920
ANTONINO MARCHIANO,
Plaintiff
v.
FAITH A. MARCHIANO,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. OS - -CIVIL TERM
: 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. 1 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.
December ;0, 2003 /inn c? I) A/ti(Nl P?jl t Ou0
ANTONIN0 MARCHIANO, Plaintiff
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ANTONINO MARCHIANO,
Plaintiff
V.
FAITH A. MARCHIANO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03 - 6649 CIVIL TERM
IN DIVORCE
NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does
depose and state:
is a competent adult and attorney for the plaintiff in the above
, That he
1
captioned action in divorce.
2. That a certified copy of the amended complaint in divorce was served
upon the defendant on or about January 2, 2004, by certified mail "restricted delivery",
addressed to the defendant at 149 Cedar Street, Carlisle, PA 17013, return receipt No.
7002 2410 0007 8504 4316.
3. That a copy of the sender's receipt and signed receipt for certified mail is
attached hereto.
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 10 authorities.
January 5, 2004 Harold- , 111
Attorney for plaintiff
¦ Complete items 1, 2, and 3. Also complete
item 4 a 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 beck of t l?l
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1. Article Addressed to:
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PS Form 3811, August 2001
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ANTONINO MARCHIANO,
Plaintiff
V.
FAITH A. MARCHIANO,
Defendant
: IN THE COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 03 - 6649 CIVIL TERM
: IN DIVORCE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was
filed in this matter on or about December 30, 2003. Service of the complaint was made
on or about January 2, 2004 (see Affidavit of Service filed on January 5, 2004).
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. 1 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.
APRIL -L, 2004 94 W"' //??
ANTONINO MARCHIANO
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ANTONINO MARCHIANO,
Plaintiff
V.
FAITH A. MARCHIANO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03 - 6649 CIVIL TERM
IN DIVORCE
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. 1 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.
April, 2004 A
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ANTONINO MARCHIANO
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ANTONINO MARCHIANO,
Plaintiff
v.
FAITH A. MARCHIANO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION.. LAW
: NO. 03 - 6649 CIVIL TERM
: IN DIVORCE
ENTRY OF A Di top
Xj_ a __It,
I consent to the entry of a final decree of divorce without notice.
2. 1 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. 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.
April _JL, 2004 -La osGU.Ub /I 64
ANTONINO MARCHIANO
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ANTONINO MARCHIANO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION- LAW
IN DIVORCE
FAITH A. MARCHIANO,
Defendant : NO. 03-6649 CIVIL TERM
AFFIDAVIT OF CONSENT
A complaint in divorce under § 3301(C) of the Divorce Code was filed on
December 30, 2003.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90)
days have lapsed 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 unworn
falsification to authorities.
Date: -13- 0?
Faith Marchiano, Defendant
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ANTONINO MARCHIANO,
Plaintiff
V.
FAITH A. MARCHIANO,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
IN DIVORCE
NO. 03-6649 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER § 3301(c) OF THE DIVORCE CODE
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. § 404 relating to unsworn
falsification to authorities.
Date: b 13 -0? ?1 / r I G C? act
Faith Marchiano, Defendant
C,
Curtis R. Long
Prothonotary
Office of the Protbonotarp
Cumberfanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
?3 - L L ?Q CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573