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Home My WebLink About09-0458r f Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 7634419 foschi@shumakerwilliams.com Attorney for Plaintiff Elisa Passalacqua, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. . NO. Oq - y58 Civi I T&,rm Angelo Candino, Defendant 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is l A available in the Office of the Prothonotary at Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. 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. Cumberland County Bar Association 32 S.Bedford St. Carlisle, PA 17013 (800)990-9108 ? N Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakervAlliams.com Attorney for Plaintiff Elisa Passalacqua., : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 09- q5k I .. Angelo Candino, , Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, Elisa Passalacqua, by and through her attorney, Anthony J. Foschi, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, Angelo Candino, upon the grounds hereinafter set forth. 1. Plaintiff is Elisa Passalacqua., an adult individual, who currently resides at 10 Rockledge Drive, Mechanicsburg, PA 17050. 2. Defendant is Angelo Candino, an adult individual, who currently resides at 72- 52 Furmanville Ave., Queens, New York 11379 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 29, 2006, in Gettysburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that he/she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. 2 WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce dissolving the marriage between the parties. DATE: ?117?4?1 a 9x00 q Respectfully sub AWHOZVJ. FOSCHI, ESQUIRE Supreme Court I.D. No. 55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff 3 VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce 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. DATED: '?rzx? a yaG?9 :218280 Elisa Passalacqua 4 O o - y s V ? r _ ::q (? ;} Z7 ? , .- ,+* Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff Elisa Passalacqua Plaintiff V. Angelo Candino, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-458 IN DIVORCE AFFIDAVIT OF SERVICE OF DIVORCE COMPLAINT I, Anthony J. Foschi, Esquire, being duly sworn according to law depose and say that on February 7, 2009, 1 served a Complaint In Divorce upon Defendant Angelo Candino by depositing a true and correct copy of same in the possession of the United States mail, certified mail, return receipt requested, addressed at 75-52 Furmanville Ave, Queens, New York 11379. A copy of the signed return receipV/ and is attached hereto. DATE: February, 11, 2009 ANTHONY V. FOSCHI, ESQUIRE Supreme Court ID # 55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff :218264 Cq-g58 W--?z+ ? svc ?w r CapieEe i 1, 2, and 3. Aiso ,y+ U inn # # RsEstricied D4*,ery is desired. ? 7 77 z;) ¦ Print your mfrs and address on the reverse C so that "-can return -the card to you. ¦ Attach ff?is card to the back of the malpi? X 7 t ? Addresses or on the front if space permits. a D. Is delivery address differoat t"n item 1? ? Yes 1. Article Addressed to: If YES, errter doWery addross belmr No [GA 7 20fl9 An eld ?'and?do T 4a r-64 rman01l/e_ ' m ?? Ut ?aye? I?upP/is lU ?/ 3` I 1137c 7r ?.ii i ? Registered `Cesm PmW for MwdwOm ? tns xed Mail ? C.O.O. 4. Restricted Debpryl X K" Fee) ? Ybe PS Form 38 1, j* 1999 Dorr>astic Return Receipt ttlsSiiS 90 M-0Y52 FEB 11 2009 n N f c r - _ t`tiJ 'E Anthony J. Foschi, Esquire Supreme Court 10 #5W5 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakervvilliams.com Attorney for Plaintiff Elisa Passaiacqua Plaintiff V. Angelo Candino, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-458 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 29, 2009. 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. 1 consent to the entry of a final Decree In Divorce after service of notice of intention to request entry of the decree. `% ... AL_D C) E OP THE 2009 MAY 22 All g: 2 1 ?NVfy Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi®shumakerwilliams.com Attorney for Plaintiff Elisa Passalacqua, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 09-458 Angelo Candino, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(C) AND 63301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree In Divorce without notice. 2. 1 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. 1 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 Waiver of Notice 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: May2009 An elo Candino :218282 OF :! P ) J'N,r 2009 M "IlY 22 iii 2 1 CUM" E z r e Anthony J. Foschi, Esquire Supreme Court ID 655895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakervAlliams.com Attorney for Plaintiff Elisa Passalacqua Plaintiff V. Angelo Candino, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-458 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 29, 2009. 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. 1 consent to the entry of a final Decree In Divorce after service of notice of 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 of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. DATE: May Q 1?, 2009 Elisa Passalacqua :218305 .lr THE €:. 1r ,IA''Y 2G99 hi AY 2 Z M 9: 2 CUM, w Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi®shumakerwilliams.com Attorney for Plaintiff Elisa Passalacqua, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 09-458 Angelo Candino, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) AND 633010 OF THE DIVORCE CODE 1. I consent to the entry of a final Decree In Divorce without notice. 2. 1 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. 1 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 Waiver of Notice 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: May , 2009 ?? cS s?J1JCZ Elisa Passalacqua :218283 OW IC E OF TH.- 2 0 0 9 AY 22 A "l '. 26 r t Anthony J. Foschi, Esquire Supreme Court ID #55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 fDschi@shumakervAlliams.com Attorney for Plaintiff Elisa Passalacqua, Plaintiff V. Angelo Candino, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-458 IN DIVORCE PRAECIPE TO TRANSMIT 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) or 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: February 7, 2009 by certified mail. (See attached signature card.) 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff on May 4, 2009; by Defendant on May 14, 2009. 4. Related claims pending: None 5. Date Plaintiffs Waiver Of Notice was filed with the Prothonotary: May 21, 2009. 6. Date Defendant's Waiver Of Notice was filed with the Prothonotary: May 21, 2009. Respectfully DATE: May 21, 2009 ANT4fON'Y J. FOSCHI, ESQUIRE Supreme Court ID # 55895 3425 Simpson Ferry Road Camp Hill, PA 17011 (717) 763-1121 FAX (717) 763-7419 foschi@shumakerwilliams.com Attorney for Plaintiff :218279 r , ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse Y so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ?n c(c) Ccirid(do _ -7 ?' 5 a r?t?m;:nv1 ?le 14 1U mIddle, W lajel &uelvns 1137j 2.' .' 7013V 194:D =31 -2184 8646 A. Received b ONea,PVnt Clearly) I B? t / ro,, fl. Si rf3`' r, (" i r ? Agent X ?Addressee D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: AA No ?w?a 7 2009 SVL) 7FEB 1 1 2009 3. rvice Type % Certified Mail ? Express Mail ? Registered Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes PS Form 381 1 , July 1999 Domestic Return Receipt 102595.00-M-0952 ,T rN THE RRY 2009 MAY 22 Ath 9: 2 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA a Passalacqua V. Candino NO. 09-458 DIVORCE DECREE AND NOW, IN 2::1 Z ? Z oa , it is ordered and decreed that Passalacqua , plaintiff, and Candino defendant, are divorced from the of matrimony. Any existing spousal support order shall hereafter be deemed an order for y pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for w$ich a final order has not yet been entered. Those claims are as follows: (if no claim$ remain indicate "None.") NONE By the Court, Jf. aq ?09 Y? • l? w ,t. Jy.,, J