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HomeMy WebLinkAbout08-1651COURTNEY J. CORICA, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2008- CIVIL TERM MICHAEL D. CORICA, 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 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. COURTNEY J. CORICA, Plaintiff, V. MICHAEL D. CORICA, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2008 - 16 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C) AND MD OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Courtney J. Corica, by and through her attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Michael D. Corica, representing as follows: 1. The Plaintiff is Courtney J. Corica, an adult individual residing at 405 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Michael D. Corica, an adult individual currently residing at 41 Brian Drive, Carlisle, Cumberland County, Pennsylvania 17015. 3. The Plaintiff and Defendant 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 September 23, 1996 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 7. 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 respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN & McKNIGHT By: Marcus[A. Mc III, A Supreme I.D. No. 25476 West omfret Professional Bui 60 West Pomfret Street (717) 249-2353 17013-3222 Date: March 11, 2008 VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: ?? ??? COURTNEY J. CORICA, Plaintiff, V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2008 -1651 CIVIL TERM MICHAEL D. CORICA, 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 Prothonota y'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. Date: March 11, 2008 W c .: ? ? ?, ?, ?. .-- N ? f ? 'T:) y .? "t ? ?+ N ;? ?... 6 ...? 4 COURTNEY J. CORICA, Plaintiff, V. MICHAEL D. CORICA, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2008 - 1651 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA . . SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Michael D. Corica, on April 4, 2008, by certified, restricted delivery mail, addressed to him at 41 Brian Drive, Carlisle, Pennsylvania 17013, with Return Receipt Number 7003 3110 0004 5768 0957. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. 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 8 Pa. C. S. Section 4904, relating to unworn falsification to authorities. MARC A. Mc HT, III, ESQUIRE Attornev for Plaintiff Date: April 17, 2008 r- Ln Q. 0 , GEHTIFIED-RIAIL • (Domestic Only; . delivery -UX . , u] Postage $ r r ° Certified Fee (j , v UNIT > o r r N ?S? M •? 9 C3 C:1 Return Redept Fee (Endorsement Required) 1 f *-1 c) Tau O Restricted Nil F ?r V t N r? very ee (Endorsement Requ COy rx m Total Postage & Fees $ O > M -Cz O Sent To r?j f E3 MICHAEL,D„_ CORICA . .. ................. ..ua?.0 O a ate' BRIAN DRIVE ° °o O ¦ CompisteN items 1, 2, and 3. Also Complete Item 4 H ReaftMed DeWery Is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the tack of the mallpiece, or on the front If space permits. 1. Article Addressed to: Ar X (0-M 0 Agent ? AddmM B. by Name) C. Date of D*vwy D. Is del very address dtifererd from Item 1? ? Yes tf YES, enter delivery address below: W No MICHAEL D,40RICA 41 BRIAN DRIVE CARLISLE PA 17013 3. Service Type 1A Certified Mall 0 Express Meal ? Regilaillered E Retum He)elpt for Mar?cttarrdise 0 Insured Mail ?j C.O.D. 2. 7003 3110 0004 5768 0957 (Aanaibr tnxn servke fabe!) PS Form 3811, February 2004 Domestic Return Receipt 102595.02-M-1540 ; Y. rQ _=t COURTNEY J. CORICA, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 2008 - 1651 CIVIL TERM MICHAEL D. CORICA, Defendant. IN DIVORCE NOTICE OF INTENTION TO RETAKE AND USE PRIOR NAME I, COURTNEY J. CORICA, hereby give notice, avowing my intention to resume and hereafter use my prior surname, to wit: COURTNEY J. LEINBERGER, in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704(a) (54 Pa. C.S.A. 704(a). My divorce is docketed to 2008-1651 Civil Term. I verify that the statements made in this document 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. 3 pA IN WITNESS WHEREOF, I have hereunto set my hand and seal this day of BE KNOWN AS;? j / 1 (SEAL) CO RTWT. f"ERGER 2008. COMMONWEALTH OF PENNSYLVANIA . SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this r day of 2008, a Notary Public, in and for the Commonwealth of Pennsylvania and County Cumberland, COURTNEY J. CORICA, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Notice of Intention to Retake and Use Prior Name, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Martha L. Noel, Notary Pubic CwlWe Boro, Cumberland County My Commission E)ires Sept 18, 2011 Member, Pennsylvania Association of Notaries 1 In, t? 7 ' :F COURTNEY J. CORICA, :IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-1651 CIVIL TERM MICHAEL D. CORICA, :CIVIL ACTION -- DIVORCE Defendant T' c NOTICE CA:. If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty (20) 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 to this action separated on or about February 4, 2007, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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: a0?? rt?Lh Michael D. rica COURTNEY J. CORICA, Plaintiff V. MICHAEL D. CORICA, Defendant :IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1651 CIVIL TERM : CIVIL ACTION -- DIVORCE CERTIFICATE OF SERVICE -G •: N , Vi I hereby certify that I have this date served a copy of the Notice and Affidavit Under section 3301(d) of the Divorce Code on the person in the manner stated below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Marcus A. McKnight, III West Pomfret Professional Building 60 West Pomfret Street Carlisle, PA 17013-3222 of J Date: Mayz , 2010 Respectfully submitted, 46 ='? a F. Blair COURTNEY J. CORICA, : IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANYA V : NO. 2008-1651 CIVIL TERM XM < M -,,, . cn r- r MICHAEL D. CORICA, : CIVIL ACTION -- DIVORCE ' w Defendant - RY f c?? •• -Z yy-- CIS'! AFFIDAVIT OF CONSENT ? ° ' 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on March 12, 2008, and served on April 4, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing of the Complaint and service of the Complaint on Defendant. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of Divorce Decree or at any time after the signing of this Consent if I have also signed a Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code. 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. DATED: G V,,c6 MICHAEL D. C =CA Defendant A COURTNEY J. CORICA, Plaintiff v MICHAEL D. CORICA, Defendant :IN THE COURT OF COMMON PLEAS, : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-1651 CIVIL TERM : CIVIL ACTION -- 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 Decree of Divorce 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. DATED: S( ?O10 Jut m1k. O?t;a MICHAEL D. C CA Defendant I COURTNEY J. CORICA, : IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYWANIA V. : NO. 2008-1651 CIVIL TERM' C` =rn MICHAEL D. CORICA, : CIVIL ACTION -- DIVORCE, CF Defendant, z o CD -?-?' c? .> c WAIVER OF NOTICE OF INTENTION TO REQUES''F 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 Decree of Divorce 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 Waiver 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 i DATED: I l _ l zo ?a a COUR Lf/k/intiff COURTNEY J. CORICA, Plaintiff V. MICHAEL D. CORICA, Defendant IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008-1651 CIVIL TERM : CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on March 12, 2008, and served on April 4, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing of the Complaint and service of the Complaint on Defendant. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of Divorce Decree or at any time after the signing of this Consent if I have also signed a Waiver of Notice of Intention to Request Entry of a Divorce Decree Under Section 3301(c) of the Divorce Code. 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. % DATED: (! _ (2)- ZL (v Ca J. ERGE COUR J. CORICA Plaintiff Or . FILED-OFFICE 2010 NOV 19 AM 9:179 CUMBERLAN 0 ?t"N i?THE COURT OF COMMON PLEAS COURTNEY J. CORICA, n YLVANIA LEINBERGER, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. MICHAEL D. CORICA Defendant To the Prothonotary: CIVIL ACTION - LAW NO. 2008-1651 IN DIVORCE PRAECIPE TO TRANSMIT RECORD Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on April 4, 2008, via certified restricted mail. Proof of service was filed with the Court on April 17, 2008. 3. Date Affidavit of Consent required under Section 3301(c) or (d) of the Divorce Code was signed: By Plaintiff: November 18, 2010 and filed with the Prothonotary on November 19, 2010. By Defendant: November 18, 2010 and filed with the Prothonotary on November 19, 2010. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed: SAIDIS SULLIVAN LAW 26 West High Street Carlisle, PA By Plaintiff: November 18, 2010 and filed with the Prothonotary on November 19, 2010. By Defendant: November 18, 2010 and filed with the Prothonotary on November 19, 2010. SAIDIS SULLIVAN LAW Ma s, Esquire Supreme Gebrt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff COURTNEY J. CORICA n/k/a LEINBERGER . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL D. CORICA No. 2008-1651 DIVORCE DECREE AND NOW, ,&"A14, ;Z3 , o?-01a , it is ordered and decreed that COURTNEY J. CORICA n/k/a LEINBERGER plaintiff, and MICHAEL D. CORICA , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, Attest: J. 7thonotary (20? )4-? N . t72Z6S7 - Al t:l:ey?