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HomeMy WebLinkAbout08-2926 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF C CUMBERLAND COU1 NO. D$ -.MV, CIVIL ACTION - LAW IN DIVORCE YOU HAVE BEEN SUED IN COURT. If you wish to defend again,, in the following pages, you must take prompt action. You are warned that if y( case may proceed without you and a decree of divorce or annulment may be er the Court. A judgment may also be entered against you for any other claim or these papers by the Plaintiff. You may lose money or property or other rights including custody or visitation of your children. PLEAS PA . (,LUG the claims set forth i fail to do so, the :red against you by :lief requested in iportant to you, When the ground for divorce is indignities or irretrievable breakdown ?f the marriage, you may request marriage counseling. A list of marriage counselors is available in e Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION O LAWYERS'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULD GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT NOT HAVE A LAWYER OR CONNOT AFFORD ONE, GO TO OR OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN ( CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD PROPERTY, ENT IS CE. IF YOU DO ,EPHONE THE LEGAL HELP. CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 20M OM CSC'' &U TAB Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff IN THE COURT OF CUMBERLAND CO PA PLEAS V. NO. 6 F" ANTONIETTA FIORILLO, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Strato M. Della Ragione, who currently resides at 1225 R Cumberland County, Pennsylvania. I tt-'-M Highway, Carlisle 2. Defendant is Antonietta Fiorillo, who currently resides at an UNKNOWN ADDRESS. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 11, 2003 in Rome Italy. COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated erein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between a parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, §§ 3 01(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since 26, 2005 and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff tray have the right to request that the court require the parties to participate in such 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Respectfully submitted, ABOM & KvTULAKrs, DATE ?I gIO? Michelle L. Sommer; Esc Supreme Court ID No. 9 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff I, STRATO M. DELI.A RAGIONE, verify that the statements Complaint are true and correct to the best of my knowledge, information, that false statements herein are made subject to the penalties of 18 Pa. unsworn falsification to authorities. Date s V STRATO M. DELLA RA in this Divorce belief. I understand §4904 relating to W _v L p c K f"1"1 C? i ???r' .? L ; :A? t ? C? V I I & KU Alom LAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, A V. NO. ANTONIETTA FIORILLO, CIVIL ACTION - LAW Defendant IN DIVORCE TO THE HONORABLE JUDGE OF THE SAID COURT: AND NOW comes the Petitioner, Strato M. Della Ragione, by and L. Sommer, Esquire, of the law firm of Abom & Kutulakis, L.L.P., and rest 1. Petitioner and Defendant were married August 11, 2003 in Rome, Italy. 2. After their marriage in Rome, Italy, the parties resided in Cumberland C 3. Petitioner and Defendant have lived separate and apart since December 4. A Complaint in Divorce is concurrently being filed with the Cumberland County. 5. Petitioner is unaware of the present location of the Defendant, his counsel, Michelle represents: 2005. of Common Pleas of Fiorillo, and has been unaware since December 26, 2005 when she left the marital residence in a Yellow Cab. V 6. Due to the Petitioner's inability to personally serve the Divorce the Petitioner hereby requests permission to publish the Divorce Sentinel and the Cumberland Law Journal. WHEREFORE, Petitioner prays this Honorable Court to enter an Della Ragione to serve the Divorce Complaint upon the Defendant, Antonietta Date Respectfully submitted, ABOM & KUTULAKIS, L.L.P. WK V?- Michelle L. Sommer, 4C 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID No. 93034 upon the Defendant, Laint in the Evening authorizing Strato M. llo, by publication. A , I, STRATO M. DELLA RAGIONE, verify that the statements made in f Notice of Publication are true and correct to the best of my knowledge, int understand that false statements herein are made subject to the penalties of 18 unsworn falsification to authorities. Date C-.:, TOM DELLA RAGI( Petition for Service of and belief. I .S. X4904 relating to N ?;e:'. mm STRATO M. DELI- A RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant MAY 0 Y2008K IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. va - aPe2 (S CIVIL ACTION - LAW IN DIVORCE AND NOW, this / 2 ' day of ) 2008, following review and consideration of the attached Petition for Service of Notice of Publication, IT IS HEREBY ORDERED AND DECREED that the location of the Defendant, Antonietta Fiorillo, is unknown. Leave is hereby GRANTED to notify the Defendant, Antonietta Fiorillo, of the filing of a Divorce Complaint by publication Z time(s) in The Evening Sentinel and time(s) in the Cumberland Law journal. y ,c lo 14, n-s , l da ?,y?e. G? o?i..? !.v /C.,.«.? rd eL?.-? . BY THE COURT, --?w?os ? ? ltd 9 0 :6 wv C ! ? vw g001 ?t 1Uti 1 ci 3HI ?O AM & .IILILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF CUMBERLAND ) Strato Della Ragione, being duly sworn according to law, deposes and says that she is the Plaintiff in the above matter; that the personally knows the Defendant, Antonietta Fiorillo, is over the age of 18 years; and that Antonietta Fiorillo has a last known address of 109 Meals Drive, Carlisle, Pennsylvania 17013. Plaintiff further avers that Defendant is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940 and its amendments. Strato Della Ragione, Plaintiff Sworn to and subscribed before me this day of , 2008. Jhd",g KI / 1171,1uma Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial seal ro, Qxnbrid County EMember,PennSyivsnJa Freeman, Notary Public icx? Expires Apra 7,2669 Association of Notarles C ° .'.r.J 4) -?kJ ` pia ]OM & u,ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. ANTONIETTA FIORILLO, Defendant : NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit 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 December 26, 2005 and have continued to live separate and apart for a period of at least two (2) 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. q% 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: .TO DELLA RAGIONE -r1 N -EST ?'T _ P-1 6x.r ..C 0 OM & &U ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. C7?r-75a-1.? CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. 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. 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. ? (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. I verify that the statements made in this Counter-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: ANTONIETTA FIORILLO, Defendant NOTICE: IF YOU DO NOT WISH 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 COUNTER-AFFIDAVIT. rv c c _ as y "^r! { ?A "1- ' .._ 8. DD -ABOM &U ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 ST'RATO M. DELI.A RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve Notice of Divorce under Section 3301(d) of the Divorce Code, upon the Defendant, by Publication in The Sentinel on May 29, 2008 and June 1, 2008. A copy of the Proof of Publication is attached as Exhibit "A". Date: ABom & KUTULAKi,S LLP L- &WaRk- Michelle L. Somme squire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 93034 i PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 131h, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): May 29, June 1, 2008 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 1St day of Tune, 2008. Notary blic My commission expires: (a `8 )©9 NOiM?Kam 80MACOW IlW"Pift emmeonOMNt IMO M?I"* .Aw ?. JUN ?008 2 M;p t BM N s f r % OM & u ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA V. ANTONIETTA FIORILLO, Defendant NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve Notice of Divorce under Section 3301(d) of the Divorce Code, upon the Defendant, by Publication in the Cumberland Law journal on June 6, 2008. A copy of the Proof of Publication is attached as Exhibit "A". Date: ABom & KUTULAKi4 LLP Vr, Miche lle L. Squire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 93034 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz June 6, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, ditor V- Ir SWORN TO AND SUBSCRIBED before me this 6 day of June, 2008 / r Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 08-2926 STRATO M. DELLA RAGIONE V. ANTONIETTA FIORILLO IN DIVORCE TO: ANTONIETTA FIORILLO YOU HAVE BEEN SUED IN COURT, the Plaintiff Strata M. Della Ragione, by his attorney, Michelle L. Sommer, Esquire, of Abom & Kutula- Ids, L.L.P., has filed a Complaint for Divorce and Plaintiff's Affidavit under §3301(d) of the Divorce Code. If you wish to defend against this claim, you must enter a written appearance personally or by attorney and file your defenses or objections in writ- ing with the Court. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce may be entered against you by the Court. You may lose property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA- TION ABOUT HIRING A LAWYER. 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 RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 June 6 ,klN ?. o I II N ' ?- '? CI f'Tl CO fW} n P 0-1 OM & TAB N ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF CUMBERLAND ) Strato Della Ragione, being duly sworn according to law, deposes and says that she is the Plaintiff in the above matter; that She personally knows the Defendant, Antonietta Fiorillo, is over the age of 18 years; and that Antonietta Fiorillo has a last known address of 109 Meals Drive, Carlisle, Pennsylvania 17013. Plaintiff further avers that Defendant is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940 and its amendments. Strato Della Ragione, Plaintiff Sworn to and subscribed before me this day of , 2008. Jhbwa ,Y-' Notary Public [COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shannon L Freeman. Notary public Carlisle 80M, CunbelaW Cotxrty MV Commission E)ires AprN 7, 2009 Member, Pennsylvania Association of Notaries C ?4 -04 46 TAB 2OM CSC" &U l UI AKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve Notice of Divorce under Section 3301(d) of the Divorce Code, upon the Defendant, by Publication in The Sentinel on May 29, 2008 and June 1, 2008. A copy of the Proof of Publication is attached as Exhibit "A". DateMikin k ABOM&KUTULAKi4 LLP iwuwj'-k? Affl?- Michelle L. Somme squire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 93034 i PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): May 29, Tune 1, 2008 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 1St day of Tune, 2008. Notary blic My commission expires: !? I S ?09 MO?IA NAl ? AC. 110WO AMC C?90@00ft Ilrf:?lleu??1r1?. ? A` 1 I N m nim F r"n V L OM & LITUI AKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve the Notice of Intent to Request Entry of Divorce Decree under Section 3301(d) of the Divorce Code, upon the Defendant, by Publication in the Cumberland Law journal on June 27, 2008. A copy of the Proof of Publication is attached as Exhibit "A". Date:: ABom& KUTULAKtB, LLP Michelle L. Sommer, Esquire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 93034 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz June 27, 2008 L' a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 27 day of June, 2008 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 08-2926 STRATO M. DELLA RAGIONE V. ANTONIETTA FIORILLO IN DIVORCE TO: ANTONIETTA FIORILLO YOU HAVE BEEN SUED IN AN ACTION FOR DIVORCE. You have failed to answer the complaint or file a counter-affidavit to the §3301(d) af- fidavit. Therefore, July 19, 2008, the other party can request the court to enter a final decree in divorce. If you do not file with the Protho- notary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final de- cree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter- affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAN- NOT AFFORD ONE, GO TO OR TELE- PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Carlisle, PA 17013 (717) 249-3166 or (800)990-9108 June 27 2 co c:2 s co ?Y v .Y ? co C ,. o.. OM & LITULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve Notice of Intent to Request Entry of Divorce Decree under Section 3301(d) of the Divorce Code, upon the Defendant, by Publication in The Sentinel on June 22, 2008 and June 25, 2008. A copy of the Proof of Publication is attached as Exhibit "A". Date: ::61-A 101 Awm&KUTVLAKrs? LLP Michelle L. Somat6r, Esquire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 93034 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Erica Peterson, Classified Manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): Tune 22, 25, 2008 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement,.and that all allegations in the foregoing statement as to time, place and character of publication are true. zw" pu-6?1 q4l( Sworn to and subscribed before me this 25th dax of Tune, 2008. • Notary Pulblic My commission expires: (18/61 NO?MIIIL NAl MDlRMACMNN? fafto NBC CARL PU BOROYOM. CI?UlU COM Mr CammMNon IWW Jun i, 2009 COPY OF NOTICE OF PUBLICATION O.. a? '*r tv 5 G co C? J 7 3 4 ?. rrrrr ?M '4UWAD A ANHM ~VIDW Y1 M )O C1WUM301A O .HBO OWM IA NO "OS <4 rw, augx9 nok*ftvo:) VM .0 -ABOM CSC' UTLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 STRATO M. DELLA RAGIONE, Plaintiff V. ANTONIETTA FIORILLO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 08-2926 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for Divorce: a. Irretrievable Breakdown under 53301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: a. Service attempted to last known address by Certified Mail, Restricted Delivery on May 29, 2008, returned as unclaimed, unable to forward on June 20, 2008 b. By Publication in the Cumberland Law journal on June 6, 2008; c. By Publication in The Sentinel on May 29, 2008 and June 1, 2008 3. Date of execution of the Affidavit required by §3301(d) of the Divorce Code: a. Signed by Plaintiff. May 19, 2008; 4. Related claims pending: a. None. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree: a. Served by Publication in the Cumberland Law journal on June 27, 2008 and in The Sentinel on June 22, and 25, 2008. Respectfully submitted, ABOM & KUTULAKi,S L.L.P JI&W V ?- Awnyp Michelle L. Somm , Esquire Supreme Court ID #93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaintiff c? -rt Mr- -OM rye am y , < IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STRATO M. DELLA RAGIONE, Plaintiff No. 08-2926 CIVIL VERSUS ANTONIETTA FIORILLO, Defendant DECREE IN DIVORCE AND NOW, 2?- 2008 IT IS ORDERED AND DECREED THAT STRATO M. DELLA RAGIONE PLAINTIFF, AND ANTONIETTA FIORILLO DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; None PROTHONOTARY -,P, kvu? 4v --v-r-r "