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HomeMy WebLinkAbout08-25370 KELLY J. LAMANCUSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DANIEL J. LAMANCUSA, :NO. 08- c` 53'7 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 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 Cumberland County Court House, High and Hanover Streets, Carlisle. 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 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 KELLY J. LAMANCUSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DANIEL J. LAMANCUSA, :NO. 08- .?S3 7 CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kelly J. Lamancusa, who currently resides at 1280 Hunter's Ridge Drive, Mechanicsburg, Hampden Township, Cumberland County, Pennsylvania, 17050. 2. Defendant is Daniel J. Lamancusa, who currently resides at 4699 Charles Road, Mechanicsburg, Hampden Township, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 28, 2006, in Harrisburg, Pennsylvania. 5. Plaintiff and Defendant separated on or about January 27, 2008. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. 9. Neither party is now serving in the United Armed Forces, nor have ever served in the United States Armed Forces. 10. Plaintiff requests the Court to enter a Decree in Divorce. By: Q9 ? Paul Bradford Orr, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 71786 VERIFICATION I verify that the statements made in the foregoing Divorce 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:--?, IOU 4 i fJO) / e ly J. m cusa, Petitioner e W W r? 00 Lr - ) J 00 O crti •< b KELLY J. LAMANCUSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. DANIEL J. LAMANCUSA, Defendant : CIVIL ACTION - LAW NO.08-? CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Daniel J. Lamancusa, in the above-captioned action. Date: h? By: behalf of myself, the Defendant, J. Lamancusa, Defendant ? ? rt -,-? i`: -? -r ?' rea -? --? -? SX ?, - ,?? _.. ?a =-c KELLY J. LAMANCUSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DANIEL J. LAMANCUSA, : NO. 08-2537 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) & (d) of the Divorce Code was filed on April 21, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 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 unsworn falsification to authorities. Date: I - cl'a 'Clb e ly J. a n sa, Plaintiff Co !1- KELLY J. LAMANCUSA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DANIEL J. LAMANCUSA, : NO. 08-2537 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) & (d) of the Divorce Code was filed on April 21, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 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 unsworn falsification fp/c*torities. Date: Z8 Da a J. amancusa, Defendant G ,. - ETi co l: --fit tV CD KELLY J. LAMANCUSA, Plaintiff V. DANIEL J. LAMANCUSA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-2537 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) & (d) OF THE DIVORCE CODE 1. 1 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. §4904, relating to unsworn falsification to authorities. -X4 )J Z-M44?1? Date: ?' ' a8 08 Xeily J. L an sa, Plaintiff ?'"? ? ?, r__ -?, ? -r;, f" 3 i .:? i? . t3"J _ ? ti ? ? ? KELLY J. LAMANCUSA, Plaintiff V. DANIEL J. LAMANCUSA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 08-2537 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) & (d) OF THE DIVORCE CODE 1. 1 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 unsworn falsification to authorities. Date: ?l? MS o of 18 Pa. C.S. §4904, relating to r-> Co -t ? KELLY J. LAMANCUSA, Plaintiff V. DANIEL J. LAMANCUSA, Defendant NO. 08-2537 IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: CIVIL TERM 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(c) & (d) of the Divorce Code. 2. Date and manner of service of the complaint: April 24, 2008, via Hand Delivery, Acceptance of Service filed on April 29, 2008. 3. Date of execution of the affidavit of consent required by Section 3301(c) & (d) of the Divorce Code: by the Plaintiff on July 28, 2008; by Defendant on July 28, 2008. 4. Related claims pending: NONE 5. Date Plaintiff's Waiver of Notice in §3301(c) & (d) Divorce was filed with the Prothonotary: July 28, 2008. 6. Date Defendant's Waiver of Notice in §3301(c) & (d) Divorce was filed with the Prothonotary: July 28, 2008. n /i? Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW By: Paul Bradford Orr, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 co s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KELLY J. LAMANCUSA, y I I a Plaintiff No. 2537 of 2008 VERSUS DANIEL J. LAMANCUSA, Defendant DECREE IN DIVORCE AND NOW, .IJ?? ZMSS , IT IS ORDERED AND DECREED THAT KELLY J. LAMANCUSA AND DANIEL J. LAMANCUSA ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, DEFENDANT, 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: ATTEST: J. it- -E4?94 c" e--- ( -I / PROTHONOTARY ,,IV 't 0 * .