The URL can be used to link to this page

Home My WebLink About01-6473SHARON E. MAISANO, Plaintiff CHARLES R. MAISANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Charles R. Maisano 915 Holly Berry Joliet, IL 60435 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. 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 at the Cumberland County Courthouse, One Courthouse Square, 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 Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Document ti: 217945.1 SHARON E. MAISANO, Plaintiff Ve CHARLES R. MAISANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE COUNT I -DIVORCE 1. Plaintiff is Sharon E. Maisano, who curremly resides at 16 Mallard Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. Plaintiff's social security number 202-50-8742. 2. Defendant is Charles R. Maisano, who currently resides at 915 Holly Berry, Joliet, Illinois 60435. Defendant's social security number is 329-76-1080. 3. Plaimiff has been a bona fide residem in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 21, 1999, in Cumberland County, Pennsylvania. The parties separated on February 4, 2001. 5. There have been no prior actions of Divorce or for annulment between the parties. 6. 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. 7. The marriage is irretrievably broken. Document #: 217945.1 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff, Sharon E. Maisano, requests the Court to enter a Decree in Divorce and such other orders as may be just and appropriate. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By: 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document ii: 217945.1 VERIFICATION I, Sharon E. Maisano, do hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: Document #: 217945.1 SHARON E. MAISANO, CHARLES R. MAISANO, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-6473 : : CIVIL ACTION LAW - IN DIVORCE AFFIDAVIT OF SERVICE I, Steven C. Courtney, counsel for Plaintiff, hereby certify that a true and correct copy of the Complaint for Divorce was served upon the following, by certified mail, return receipt and regular mail on December 5, 2001. Charles R. Maisano 915 Holly Berry Joliet, IL 60435 Date: December 13, 2001 METZGER, WICKERSHA~~S & ERB, P.C. Steven C. Co'fl~ney~uire I.D. No. 746_69 ~ 3211 North Front Street "~ P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Document#:22279Zl · Complete iterns 1, 2, and 3. Also complete item 4 if p. estricted DelNee/is desired' · print your name and address o~ ~e reveme we ~m return t~e card ~o Y°U' · Attach this taxi3 to ur= A. Received by ~k~ase=P~'f~t C;~Hy) Date of C. Signature r-i ,e~gent O. is deliven/address dil~nt ~3~ item 17 I'~1 ¥~ I-~ Express MaB ~u~_ _ Receipt for MerchandiSe r-I insured Malt ~~ 4. Restricted De~ive~ ,(Extra Fee) _~ 2 ArticleNum yfmm · tabe0 oome~C Re~ Rece~ PS Form 3811, July 1999 SHARON E. MAISANO, Plaintiff VS. CHARLES R. MAISANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6473 CIVIL ACTION _ LAW IN DIVORCE ~AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed on November 14, 2001 and served upon Defendant on December 5, 2001. 2. The marriage ofplainfiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ora final decree of divorce after service &notice &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 o£ 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: Document it.. 227878.1 SHARON E. MAISANO, Plaintiff VS. CHARLES R. MAISANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6473 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER 3301 e OF THE DIVORCE CODE 1. I consent to the entry ofa finai decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 scm 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 unswom falsification to authorities. Document it: 227878.1 SHARON E. MAISANO, CHARLES R. MAISANO, Plaintiff : : ; : : Defendant : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6473 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I. Ground for divorce: Irretrievable breakdown under §3301 (c) of the Divorce Code. 2. Date and manner &service &Complaint: Served upon Defendant: via certified mail, on December 5, 2001. Affidavit of Service filed on December 17, 2001. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry ora Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to Pa.R.C.p. 1920.42(e)(1): Plaintiff- 05/15/02 and filed 05/17/02 Defendant - 05/15/02 and filed 05/17/02 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: rda (2) Date &service &the plaintiffs affidavit upon the defendant: n/a Document #.. 234503. ] Complete the appropriate paragraphs: (a) Related claims pending: None. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under §3301(d)(1)(i) of the Divorce Code: n/a METZGER, WICKERSHAM, KNAUSS & ERB, P.C. 3211 North Front StreetXX~ P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document # 145617 SHARON E. MAISANO, CHARLES R. MAISANO, Plaintiff : : : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6473 CIVIL ACTION _ LAW IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this ~ day of May, 2002 I, Steven C. Courtney, Esqu/re, of Metzger, Wickersham, Knauss & Erb, attorneys for Plaintiff, hereby certify that I served a copy of the Praeeipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Charles R. Maisano P.O. Box 3158 Joliet, IL 60434 METZGER, WICKERSHAM, KNAUSS & ERB Document #: 168260.1 By:'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY -~ARON ~.. ~ATSA~0STATE OF ~ PENNA. NO. -01-6473 VERSUs -_CHARLes g. MAISANO__ AND NOW, DECREE IN DIVORCE IT IS ORDERED AND DECREED THAT -_~har_on~. Maisa__no~ AND ' o 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; J? SHARON E. MAISANO, Plaintiff VS. CHARLES R. MAISANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6473 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed on November 14, 2001 and served upon Defendant on December 5, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Charles R. Maisano Document '#: 227878.1 SHARON E. MAISANO, Plaintiff VS. CHARLES R. MAISANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6473 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 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 fights concerning alimony, division of property, lawyer's fees or expenses ifI 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Charles R. Malsano Document #: 227878.1