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Home My WebLink About08-2230 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff v PAUL ROMANO, Defendant No. 2008 - x1130 CIVIL ACTION - LAW 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 proceed against you and a decree of 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 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OR PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 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 at 717-240-6100. 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff No. 2008 - as 9D v PAUL ROMANO, Defendant CIVIL ACTION - LAW DIVORCE NOTICE OF AVILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 1'3 North Hanover Street, Carlisle, Pennsylvania, 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff No. 2008 - ,a a 3o v PAUL ROMANO, Defendant CIVIL ACTION - LAW DIVORCE COMPLAINT IN DIVORCE UNDER 23 P.S. 4§ 3301(c) and (d) OF THE DIVORCE CODE AND NOW, this ?? day of April, 2008, comes Plaintiff, Sheri Romano, by and through her attorney, Suzanne Spencer Abel, Esq., and who files the following Complaint for Divorce, and in support thereof avers as follows: The Plaintiff is Sheri Romano, currently residing at 22 East Street, #5, Mt Holly Springs, Pennsylvania, Cumberland County. 2. The Defendant is Paul Romano, currently residing at 324 North Street, Boiling Springs, Pennsylvania, Cumberland County. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 24,1993, in Cumberland County, Pennsylvania; and separated on January 1, 2002. The parties have four children from the marriage. 5. On or about December 19, 2002, the instant Defendant filed a Complaint for Divorce in Cameron County. On March 6, 2008, the parties executed an Agreement for Discontinuance, which was docketed with the Cameron County Prothonotary's office concurrently with the instant Plaintiff's Praecipe to Discontinue on March 14, 2008. The matter was marked by the Cameron County Prothonotary as Discontinued on March 14, 2008. There have been no other prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that defendant may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff respectfully requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, Spencer Abel Law Office Su e Spen er Abel, Esq. Att ey ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 (717) 323-0345 FAX spencer_abel_esq@fastmail.fm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff v PAUL ROMANO, Defendant No. 2008 - CIVIL ACTION - LAW DIVORCE VERIFICATION I VERIFY that I have personal knowledge of all facts not of record set forth in the foregoing pleading, and that such statements are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 44904 relating to unsworn falsification to authorities. Date: Mal C7- Sheri Romano IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff No. 2008 - v CIVIL ACTION - LAW PAUL ROMANO, Defendant DIVORCE CERTIFICATE OF SERVICE I certify that, concurrent with filing the foregoing Complaint forDivorce, I am this day serving a copy of same via Certified First Class U.S. Mail, to the following Defendant: Paul Romano 324 North Street Boiling Springs, PA 17007 Date: 4'?6 e Suzan Spencer Abel, Esq. Attorhe? ID #202443 22 East Street, #6 Mt Holly Springs, PA 17065 (717) 323-0046 (717) 323-0345 FAX Spencer_Abel_Esq@fastmail.fm J N" C? o e Oo E L [u y Lrl _?l P P'1 ??Ct D vs. In In the Court of Common Pleas of Cumberland County, Pennsylvania No. as civil. 7? ? Vey To Prothonotary 19 Attorney for Plaintiff No. Term, 19 vs. PRAECIPE Filed 19 Atty. (7) r n .? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff v PAUL ROMANO, Defendant : No. 2008 - 2230 CIVIL ACTION - LAW DIVORCE PRAECIPE to FILE AFFIDAVIT OF SERVICE To the Prothonotary: Kindly file the attached Affidavit of Service in the above referenced matter. Respectfully Submitted, Date: 42b?- lp Suz a Spe cer Abel Sup a Ct. No.: 202443 Spencer Abel Law Office 22 East Street, #6 Mt. Holly Springs, PA 17065 (717) 323-0046 (717) 323-0345 FAX SpencerAbel@comcast.net s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERI ROMANO, Plaintiff No. 2008 - 2230 v CIVIL ACTION - LAW PAUL ROMANO, Defendant DIVORCE AFFIDAVIT OF SERVICE the undersigned, hereby state that I have se copy of the Complaint fo Divorce in the above captioned action upon Defendant by handing the papers to , at the following address: c2a C39&f- s"?A ALI 'SOC-64 , J -- l - , on the day of , 2008, at approximately O- o'clock .m. 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.A. §4904, relating to unsworn falsification to authorities. (Signature) (Title) (Address) (Date) I hereby accept service and acknowledge receipt of the document. Signed: °-'-'? Date: / Address: