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HomeMy WebLinkAbout08-4834SMIGEL, ANDERSON & SACKS, LLP Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3`d Fir. Harrisburg, PA 17110-1778 (717) 234-2401 alevin@,sasllp.com Attorney for Plaintiff DANIEL CHIRICO, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08 . N g3q aw i 1e'M DONNA CHIRICO, DEFENDANT CIVIL ACTION - 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 without you and a decree of divorce or annulment may 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, 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, 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. All arrangements must be made at least 72 hours prior to any hearing of business before the Court. SMIGEL, ANDERSON & SACKS, LLP Ann V. Levin, Esquire ID #70259 4431 North Front Street, 3nd Flr. Harrisburg, PA 17110-1778 (717) 234-2401 alevinnsasllp.com Attorney for Plaintiff DANIEL CHIRICO, PLAINTIFF V. DONNA CHIRICO, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Daniel Chirico, by and through his attorneys, SMIGEL, ANDERSON & SACKS, LLP, and represents as follows: COUNTI DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Daniel Chirico, who currently resides at 394 Palmyra-Bellegrove Road, Annville, Lebanon County, Pennsylvania 17003, and has resided there since on or about June 27, 2008. 2. Defendant is Donna Chirico, who currently resides at 227 Parker Street, Carlisle, Cumberland County, Pennsylvania 17013 and has resided there since on or about September 2003. 3. Both 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 June 5, 1993, at Doylestown, Pennsylvania. 5. There have been no 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 Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff avers that there are children of the parties under the age of 18, namely: Noah Daniel, born September 30, 1996; Cameron Leah, born July 17, 1998 and Sean Donato, born October 3, 2001. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. SMIGEL, ANDERSON & SACKS, LLP Date: 8 By: V Ann V. Levin, Esquire I.D. #70259 4431 North Front Street, 3`d Flr. Harrisburg, PA 17110-1778 (717) 234-2401 Attorney for Plaintiff VERIFICATION I, Daniel Chirico, verify that the statements contained in the foregoing pleading are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Date: 2JOCO ??7 WanieChirico., Plaintiff dchi ri c. oft- W C- ^a C--Z 00 rn ?.. ?? ??• re 4', ? Z: f) Vp SMIGEL, ANDERSON & SACKS, LLP Ann V. Levin, Esquire ID #70259 4431 North Front Street, and Fir. Harrisburg, PA 17110-1778 (717) 234-2401 alevin asasilo.com Attorney for Plaintiff DANIEL CHIRICO, PLAINTIFF V. DONNA CHIRICO, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4834 CIVIL TERM CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I, Theresa B. Male, counsel for Defendant, Donna Chirico, accept service of the Complaint Under Section 3301(c) or 3301(d) of the Divorce Code on behalf of Defendant and certify that I am authorized to do so. Date: Theresa B. Male, Esquire 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 4 > 1 ? ? . T1 i m1 DANIE=L CHIRICO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-4834 DIVORCE DECREE AND NOW, A?eaay , -1, ©// , it is ordered and decreed that DONNA CHIRICO DANIE=L CHIRICO DONNA CHIRICO bonds of matrimony. , plaintiff, and defendant, are divorced from the 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. Prothonotary a/a,/?? • Oert. 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