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Home My WebLink About08-6277LORI RYERSON PRONTI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, n / V. :NO: O g ?..Z.7 7 Cu 1. ?rRrYL DAVID A. PRONTI, Defendant. : CIVIL, ACTION - LAW : IN 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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. 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 (717) 249-3166 LORI RYERSON PRONTI, Plaintiff, V. DAVID A. PRONTI, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: DP- Gz'M : CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Lori Ryerson Pronti, by and through her attorneys, Mancke, Wagner, Spreha & McQuillan, and files the following Complaint in Divorce: 1. The Plaintiff, Lori Ryerson Pronti, is an adult individual residing at 10 Beaver Road, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant, David A. Pronti, is an adult individual having an address P.O. Box 65, Pillow, Dauphin County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. The parties are husband and wife having been married on September 3, 2005, at Liberty Forge, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. There were no children born unto the marriage. 8. Plaintiff has been advised of the availability of counseling and that she has the right to request that the Court require both pasties to participate in counseling. 9. The Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken pursuant to §3301(c) of the Divorce Code; and B. that as of June 13, 2010, the parties will have been separated for a period of at least two (2) continuous years pursuant to §3301(d) of the Divorce Code. Respectfully submitted, Mancke, Wagner, Spreha & McQuillan chard W , Esquire . #23103 2 33N Front Street sburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: D D 3 w VERIFICATION I verify that the statements made in the foregoing document 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 uhsworn falsification to authorities. , ? 6A" -, ? A ? ?, Date: `7 ./6? - U j CT ? '' yy 7D G C:D c-I I T> P. Richard Wagner, Esquire PA Supreme Court ID# 23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax (717) 234-7080 Attorney for Plaintiff LORI RYERSON PRONTI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : V. DAVID A. PRONTI, Defendant. : NO: 2008-6277 CIVIL ACTION - LAW : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that the PLAINTIFF in the above matter, being a party to a divorce action at the above number filed on October 22, 2008, hereby intends to resume and hereafter use the previous name of Lori Ryerson and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. Section 702 (effective July 1, 1980). ri Ryersdh Pronti TO BE KNOWN AS: F, 4?-'? ri Ryerson COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF .?cJ ON THE-Af?- day of , 20 O7 before me, a Notary Public, personally appeared Lori Ryerson Pronti, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. ?u:1iW?b-Zfic Notary My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Debra K. Spinner, Notary Public CRY Of Harrisburg, Dauphin County ?'tY Commission Expires; Sept 3, 2011 Member, Pennsy;uar:ia 4esoc i,al;,?r, of Notaries Ul d3 't F"? LORI RYERSON PRONTI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 08-6277 -CIVIL TERM : CIVIL ACTION -LAW DAVID A. PRONTI, Defendant. : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 22, 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 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. Section 4904, relating to unworn falsification to authorities. DATE: 2?0 ` O e0&riRyy4ersPronti i ?^ ? l k ?, . { \ 13"? ?.? ? A M y ? : ?< .. ..t.. + ?.• ? "l. ??? . ? r ? r • .'` r ^f .1j ?? tf ? LORI RYERSON PRONTI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff, : NO. 08-6277 - CIVIL TERM DAVID A. PRONTI, Defendant. : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO RF(U ST ENTRY OF A DIVORCE I CREE UNDER SECTION 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 rights concerning alimony, division of property, lawyer's fees or expenses if I 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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. - 11 111,11API-7xi, er4iRyye4" Proud DATE: Z ' 2q' d t-I ` i -r :_ J-1 ?'a9 LORI RYERSON PRONTI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 08-6277 - CIVIL TERM : CIVIL ACTION -LAW DAVID A. PRONTI, Defendant. : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 22, 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 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. Section 4904, relating to unworn falsification to authorities. DATE: a` )-A bc? ?- N David A. Pronti C N 71 cT LORI RYERSON PRONTI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. DAVID A. PRONTI, Defendant. : NO. 08-6277 - CIVIL TERM : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 1301(m) 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 rights concerning alimony, division of property, lawyer's fees or expenses if I 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 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. David A. Pronti DATE: 2A-a?\ ( :)C? rrt ?,. "? aS LORI RYERSON PRONTI, V. Plaintiff, DAVID A. PRONTI, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO: 2008-6277 - CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSIVIIT THE RECORD TO THE PROTHONOTARY: 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), 3301(d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: November 3, 2008, by certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 2/20/09 By Defendant: 2/27/09 (b) (1) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1)(i) of the Divorce Code: (b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: 2/26/09 (c) Date Defendant's Waiver of Noti as filed with the Prothonotary: 3/6/09 Gagner, Esq. for Plaintiff 4r Zx V LORI RYERSON PRONTI V. DAVID A. PRONTI DIVORCE DECREE AND NOW, or 10 , 1.6001, , it is ordered and decreed that LORI RYERSON PRONTI DAVID A. PRONTI 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6277 By the Court, 'V? `QA! Attest: J. Prothonotary *;lilt a