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Home My WebLink About09-03924 ~ Thomas D. Gould, Esquire I.D. # 36508 2 East Main Street Shiremanstovm, PA 17011 (717) 731-1461 DEBRA G. ANDIORIO, PLAINTIFF v. DAVID F. ANDIORIO, DEFENDANT IN THE COURT OF COMMON PLEAS CUI~ERLAND COUNTY, PENNSYLVANIA NO. 20G4 - ~ 9~'" CIVIL TERM 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 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Third floor, Cumberland County Courthouse, Hanover and High Streets, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION 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 REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 .. DEBRA G. ANDIORIO, PLAINTIFF v. DAVID F. ANDIORIO, DEFENDANT IN THE COURT OF CO~Il~N PLEAS CtA~ERLAND COUNTY, PENNSYLVANIA NO. b9- 39.Z IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Debra G. Andiorio who resides at 230 Bosler Avenue, Apartment B, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The Defendant is David F. Andiorio who resides at 2 Countryside Place, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 28, 1980 in New Cumberland, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. There were two children born of this marriage Cara Andiorio, born August 25, 1981 and David Andiorio, born June 26, 1983. 7. The parties have been living separate apart since September 4, 2007. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States and or any of its allies. 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. ~-~ Q~ Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this 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 ~ " a~ ^ ~~~N~ ~ W~ Debra G. Andiorio NOTICE ~ AVAILABILITY OF COUNSELING TO THE WITHIN~NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. C7 ~ { 6t mo -~ ' 'w ~-}~ ~ ,; CY1 ~. .~ ` i ~ L7 ~ , ( ., .:. Lie "`j -~ ' ' V " OF TyE PROTHp i Frank C. Sluzis, Esquire NO TART' SCARINGI & SCARINGI, P.C. A 1`110: S4 2000 Linglestown Road, Suite 106 C"BERL A Harrisburg, PA 17110 PEN f, ?! CGUNTY (717) 657-7770 S YL VA P11A (717) 657-7797 -facsimile frank@scaringilaw.com Attorney for Defendant DEBRA G. ANDIORIO, Plaintiff V. DAVID F. ANDIORIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009-392 CIVIL TERM : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Frank C. Sluzis, Esquire of Scaringi & Scaringi, P.C. as counsel for the Defendant, David F. Andiorio, in the above-captioned matter. Respectfully submitted, Date: -1 " ( 1 ?C C. Sluzis, Esquire #43829 Attorney for Defendant Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 CERTIFICATE OF SERVICE I hereby certify that I served the foregoing Praecipe to Enter Appearance by first class mail, postage prepaid, to the following individuals: Debra G. Andiorio c/o Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 Respectfully submitted, -T Date: -'-J?Ald? FMAUSIPA Desiree Brougher, La Clerk Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106 Harrisburg, PA 17110 (717) 657-7770 r , DEBRA G. ANDIORIO, Plaintiff V. DAVID F. ANDIORIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2009-392 CIVIL TERM IN DIVORCE ORDER AND NOW THIS day of , 2011, upon consideration of the foregoing Petition to Withdraw as Counsel it is hereby ORDERED that `4° Petition t&*44&aw y =m rni-- == r•c -am <D jr CSC? r -+O ' C = n C ) rn w ? Distribution: ? Frank C. Sluzis, Esquire, Scaringi & Scaringi, P.C. 2000 Linglestown Road, Suite 106, Harrisburg, PA 17110 s BY T URT: J s tep-leaue.tn with dra?x? frnm this mattar ae rn..++?al fnr Defendant .e eT ` ^ s " j 140V Thomas Gould, Esquire, 2 East Main Street, Shiremanstown, PA 17011 ? David Andiorio, 2 Countryside Place, Camp Hill, PA 17011 6 p; es , i'q -Sbq l I 04G Frank C. Sluzis, Esquire fLED f=fL,C ?t ?'O?H?Nd?A?? v PA Attorney ID No. 43829 SCARINGI & SCARINGI, P.C. ' j JUN 28 AN 10: 9 2000 Linglestown Road, Suite 106 v Harrisburg, Pennsylvania 17110 CUMBERLAND COUNTY Tele: (717) 657-7770 PENNSYLVANIA Fax: (717) 657-7797 frank@scaringilaw.com Attorney for Defendant DEBRA G. ANDIORIO, Plaintiff V. DAVID F. ANDIORIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009-392 CIVIL TERM : IN DIVORCE MOTION TO MAKE RULE ABSOLUTE AND NOW COMES, Frank C. Sluzis, Esquire and Scaringi & Scaringi, P.C. who respectfully requests that this Honorable Court grant him permission to withdraw as counsel on behalf of Defendant David F. Andiorio and in support thereof avers as follows: 1. On May 13, 2011, the undersigned filed a Petition to Withdraw as Counsel on behalf of Defendant, David F. Andiorio, in the above-captioned matter. 2. On May 23, 2011 this Honorable Court entered a Rule to Show Cause upon Plaintiff Debra G. Andiorio and Defendant David F. Andiorio, to show cause why, if any, said Petition should not be granted. The rule was returnable 10 days after service. 3. On June 2, 2011 the undersigned caused the Rule to Show Cause to be served upon Plaintiff and Defendant's counsel Attorney Thomas Gould via first class mail, postage prepaid. 2 4. More than ten (10) days have elapsed since the Rule to Show Cause was served upon the Plaintiff and Defendant's counsel. 5. To the best of the undersigned's knowledge, the Plaintiff and Defendant have not responded to the Rule to Show Cause nor objected to the undersigned's request to withdraw as counsel on behalf of Mr. Andiorio. WHEREFORE, Frank C. Sluzis, Esquire and Scaringi & Scaringi, P.C. respectfully requests that this Honorable Court grant the request to immediately withdraw as counsel on behalf of David F. Andiorio in the above-captioned matter. submitted: Date: 2-5 (( Sluzis, Esquire GI & SCARINGI, P.C. DEBRA G. ANDIORIO, Plaintiff V. DAVID F. ANDIORIO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 2009-392 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Desirde A. Brougher, law clerk for Scaringi & Scaringi, P.C. do hereby certify that a copy of the foregoing Motion to Make Rule Absolute in the above-captioned case has been duly served upon the following individual(s) by depositing same in the United States Mail, First Class, Postage Prepaid, addressed as follows: Thomas Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 David Andiorio 2 Countryside Place Camp Hill, PA 17011 Date: ti/ ?,q W j( esirde A. Brougher 4 4 FILEU -OFFICE OF THE PROTHONOTARY 1011 JUN 30 PM 3: 35 CUMBERLAND COUNTY PENNSYLVANIA DEBRA G. ANDIORIO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 2009-392 CIVIL TERM DAVID F. ANDIORIO, IN DIVORCE Defendant ORDER AND NOW THIS 0$_ day of 2011, upon consideration of the Petition to Withdraw as Counsel, Motion to Make Rule Absolute, and noting that no response or objection was filed by Plaintiff or Defendant to the Petition, it is hereby ORDERED that said Petition is GRANTED. Scaringi & Scaringi, P.C. and Frank C. Sluzis, Esquire, are withdrawn as counsel for Defendant David F. Andiorio in the above-captioned matter. BY T J. Distribution: Frank C. Sluzis, Esquire, 2000 Linglestown Road, Suite 106, Harrisburg, PA 17110 ? Thomas Gould, Esquire, 2 East Main Street, Shiremanstown, PA 17011 t/ David F. Andiorio, 2 Countryside Place, Camp Hill, PA 17011 pies n-. led h13011t C, k(, David ED. Buell Prothonotary Office Of the Prothonotary Cum6erfancfCounty, Pennsylvania rkS. Sohonage, ESQ SoCicitor 69-392_0 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 0 CarCisCe, TA 0 1 Hone 717 240-6195 0 Fax 717 240-6573