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HomeMy WebLinkAbout09-3804 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff TONY DOUGLAS SAMENTO, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NANCI MARIKO SAMENTO, Defendant . No M- 39-O4/ &04,'4 CIVIL ACTION - AT LAW 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 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 Courthouse, One Courthouse Square, 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 32 South Bedford Street Carlisle, PA 17013-3308 (717) 249-3166 JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff TONY DOUGLAS SAMENTO, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No 0'? • 3 ?D C4?a- ?u^^ NANCI MARIKO SAMENTO, CIVIL ACTION - AT LAW Defendant DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the Tony Douglas Samento, by and through his attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Divorce: 1. Plaintiff, Tony Douglas Samento, is an adult individual currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Nanci Mariko Samento, is an adult individual currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 22, 1983, in Shiremanstown, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The grounds upon which this divorce action is based are: 1 Count I - Divorce Pursuant to 3301(a)(2) of the Divorce Code a. Defendant has committed adultery. Count II - Divorce Pursuant to 3301(a)(6) of the Divorce Code b. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. Count III - Divorce Pursuant to 3301(cl or 3301(d) of the Divorce Code c. The marriage is irretrievably broken. 7. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 10. There are three dependent children from this marriage, namely Ciara Marquis Samento, born November 28, 1992, Aidan Makai Samento, born May 31, 1999, and Elijah David Samento, born July 22, 2000. 11. This action is not collusive. WHEREFORE, Plaintiff, Tony Douglas Samento, respectfully requests this Honorable Court grant him relief from the bonds of matrimony and order a Decree in Divorce. 2 Respectfully Submitted: Date: By: JE B. COSTOPOULft; ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 ATTORNEY FOR PLAINTIFF VERIFICATION I, Tony Douglas Samento, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: in?ly Douglas Samento OF THE TMy 2009 JUIN -9 PM 12: 4 7 CUMgR 330F• Szy ,od JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff TONY DOUGLAS SAMENTO, Plaintiff VS. NANCI MARIKO SAMENTO, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No 09-3804 CIVIL CIVIL ACTION - AT LAW DIVORCE PLAINTIFF'S PETITION FOR SPECIAL RELIEF FOR EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE AND AN INTERIM ORDER OF CUSTODY Plaintiff, Tony Douglas Samento, by and through his attorney, Jeanne B. Costopoulos, Esquire, avers the following: 1. The Petitioner is the Plaintiff above-named, Tony Douglas Samento, hereinafter referred to as Husband, currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Respondent is the Defendant above-named, Nanci Mariko Samento, hereinafter referred to as Wife, currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The parties were married on September January 22, 1983 in Shiremanstown, Cumberland County, Pennsylvania. 4. There are three dependent children from the marriage of the parties, namely Ciara Marquis Samento, born November 28, 1992, Aidan Makai Samento, born May 31, 1999, and Elijah David Samento, born July 22, 2000. 5. The parties own a home and property located at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 6. Husband recently discovered that Wife has been secretly meeting and having sex with Corporal Thomas G. Tarsavage, a computer crime investigator with the Pennsylvania State Police who is believed to be residing at 494 Skyline Road, New Cumberland, Pennsylvania, with his wife and children. 7. Shortly after discovering Wife's extramarital affair, Husband filed a Complaint in Divorce at the above caption and number on June 9, 2009. Said Complaint was served on Wife on June 9, 2009. 8. Husband is filing a Petition for Related Claims for Equitable Distribution and a Complaint in Custody simultaneously with this Petition for Special Relief. The averments contained in said pleadings are hereby incorporated by reference as though fully set forth herein. 9. For the following reasons, it is appropriate that Husband be granted exclusive possession of the marital residence and interim primary custody of the children: A. Wife has serious alcohol problems. Wife often becomes intoxicated and berates husband in the presence of the children, which is upsetting to them. Wife's behavior has worsened since being confronted by Husband about her extramarital affair and being served the Complaint in Divorce. B. Husband fears permitting the children to ride in a car with Wife due to her excessive alcohol consumption. C. In recent months, Wife has lacked interest in the children and has been obsessively consumed with herself and her appearance. Wife patronizes tanning salons and receives various beauty treatments several times per week. D. After being confronted about her adulterous behavior, Wife attempted to downplay her actions as though Husband should accept and dismiss her behavior as unimportant to their relationship. E. After being served with the Complaint in Divorce, Wife's yelling and angry outbursts in the presence of the children have increased. The parties' older daughter, Brianne offered to keep the two youngest boys at her house for the night on the day Wife was served with the Complaint but Wife said no because Brianne did not specifically ask her but instead went through Husband when she made the suggestion. F. Wife's erratic behavior, mental instability, and intoxication are escalating and have created a toxic environment within the marital home. G. Husband believes the children will be irreparably harmed if the current situation is permitted to continue. H. Husband agrees to provide Wife with an advance on equitable distribution in the amount of $10,000.00 so that she may obtain suitable alternate housing pending final equitable distribution. Wife recently argued with Husband and the parties' older children regarding her habit of leaving the two young boys home alone. Husband believes and therefore avers that Wife did not want the children with her when she was talking to her paramour on the phone or meeting with him so she chose to left them home unattended. 10. No judge has yet been assigned to this case. 11. No attorney has yet entered an appearance on Wife's behalf and undersigned counsel has not contacted Wife directly to seek her concurrence. Husband expects that Wife will oppose the relief requested. A copy of this Petition has been mailed to Wife. WHEREFORE, Husband respectfully requests this Honorable Court to enter an Order in substantially the following form: A. Husband shall immediately provide Wife with an advance on equitable distribution in the amount of $10,000.00 to be used for her to obtain appropriate housing pending an agreement or order regarding equitable distribution. B. Effective ten (10) days from Wife's receipt of the $10,000.00 advance distribution payment from Husband, Husband shall have exclusive possession of the marital residence located at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. C. Husband shall have temporary primary physical custody of the parties' minor children, Ciara Marquis Samento, born November 28, 1992, Aidan Makai Samento, born May 31, 1999, and Elijah David Samento, born July 22, 2000, pending a custody conciliation conference. D. Neither party shall consume any alcoholic beverages within four (4) hours prior to being in the presence of either of the parties' children. E. Neither party shall drive with the children in the car after having consumed any amount of alcoholic beverage whatsoever. Respectfully Submitted: By: --I? JEANNE B. COSTOPOULOS, E Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: ?1??? Attorney for Plaintiff/Petitioner VERIFICATION I, Tony Douglas Samento, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn verification to authorities. Date: ?0-t1-49 T Douglas Samento CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Nanci Mariko Samento 1066 Park Place Mechanicsburg, PA 17055 By: JEANNE B. COSTOPOULOS, ESQ Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: ?, A?4/ Attorney for Plaintiff/Petitioner RLE.i -- 'h OF WE 2609 JfUll1 12 FM i 12: JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff TONY DOUGLAS SAMENTO, Plaintiff THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. : No NANCI MARIKO SAMENTO, CIVIL ACTION - AT LAW Defendant CUSTODY COMPLAINT IN CUSTODY AND NOW, comes Plaintiff, Tony Douglas Samento, by and through his attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Custody: 1. Plaintiff is Tony Douglas Samento, an adult individual currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Nanci Mariko Samento, an adult individual currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff filed a Complaint in Divorce against Defendant on June 9, 2009 at Cumberland County Civil Docket No. 09-3804. 4. There are three (3) dependent children from the marriage of the parties, namely Ciara Marquis Samento, born November 28, 1992, Aidan Makai Samento, born May 31, 1999, and Elijah David Samento, born July 22, 2000. 5. The parties are married. The two youngest children were adopted by the parties in 2005. The older minor child was not born out of wedlock. 6. The children are currently in the custody of both parties residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 7. The children have been in both parties' custody at their current address for the past several years. 8. Plaintiff is the natural father of Ciara and the adoptive father of Marquis and Aidan and he currently resides with Plaintiff and the children at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 9. Defendant is the natural mother Ciara and the adoptive mother of Marquis and Aidan and she currently resides with Plaintiff and the children at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 10. Plaintiff has not participated as a party or a witness, or in any other capacity in other litigation concerning the custody of the children in this or any other Court. 11. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 12. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 13. The best interest and permanent welfare of the children will be served by granting Plaintiff primary physical and shared legal custody of the parties' three (3) children. Plaintiff has filed a Petition for Special Relief at the divorce docket of 09-3804 simultaneously with this Complaint and the averments contained therein are incorporated herein by reference as though fully set forth herein. 14. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff, Tony Douglas Samento, respectfully requests this Honorable Court to grant him primary physical and shared legal custody of the parties' three (3) minor children. Respectfully Submitted: By: J NE B. COSTOPOULOS, ESQUIR? Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 ??2?? Attorney for Plaintiff Date: C.? VERIFICATION I, Tony Douglas Samento, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: b - l 1 - () ?el 7,;? f!z T Doug as Samento r ALEG-r OF 1141- 2009 J? _N 12 I'll It 2: `.;%8 vkj JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff/Petitioner TONY DOUGLAS SAMENTO, Plaintiff VS. NANCI MARIKO SAMENTO, Defendant THE COURT OF COMMON PLEAS' OF CUMBERLAND COUNTY, PENNSYLVANIA No 09-3804 CIVIL ACTION - AT LAW DIVORCE PLAINTIFF'S PETITION FOR RELATED CLAIMS PURSUANT TO PA.R.C.P. 1920.15(b) - EQUITABLE DISTRIBUTIQN AND NOW comes Plaintiff, Tony Douglas Samento, by and through his attoiney, Jeann6 B. Costopoulos, Esquire, and represents as follows in support of this Petition: 1. Petitioner is Plaintiff above, Tony Douglas Samento, hereinafter referred to as'Husband, an adult individual currently residing at 1066 Park Place, Mechanicsburg, Cumbe>iland County, Pennsylvania, 17055. 2. Respondent is Defendant above, Nanci Mariko Samento, hereinafter referred to as Wife, an adult individual currently residing at 1066 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Husband and Wife were married on January 22, 1983 in Shiremanstown, Cumberland County, Pennsylvania. 4. Husband filed a Complaint in Divorce on June 9, 2009. The averments contained therein are incorporated herein by reference as though fully set forth. COUNTI EQUITABLE DISTRIBUTION OF PROPERTY 5. Paragraphs 1 through 4 above are hereby incorporated herein be reference as though fully set forth. 6. During the marriage, the parties have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of!the Divorce Code. 7. In order to effectuate economic justice between the parties, Husband request: this Honorable Court to enter a fair and just determination and settlement of the parties' property rights. WHEREFORE, Husband requests this Honorable Court to equitably divide and distribute the marital property of the parties in accordance with the Divorce Code. RESPECTFULLY SUBMITTED: By: JEANN K B. COSTOPOULOS, ESQ IRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 / Telephone No. (717) 221-0900 Date: GP ?2?? Attorney for Plaintiff/Petitioner VERIFICATION I, Tony Douglas Samento, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: 6 -0-69 T y Douglas Samento CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Nanci Mariko Samento 1066 Park Place Mechanicsburg, PA 17055 By: JEANNE B. COSTOPOULOS, ESQ E Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 /Telephone No. (717) 221-0900 Date: (01112407 Attorney for Plaintiff/Petitioner 1 AILED-C DICE 4r THE Prk')I* ,,"!,!!NARY 2009 JUN 12 PM 12: 5 5 r _jY TONY DOUGLAS SAMENTO, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No &R- 3 NANCI MARIKO SAMENTO, CIVIL ACTION - AT LAW Defendant DIVORCE AFFIDAVIT OF SERVICE The undersigned hereby verifies and states that on the date and time indicated below I personally hand-delivered upon the person whom I know to be Nanci Mariko Samentd, Defendant above, a true and correct copy of the Complaint in Divorce filed on June 9, 2009. I further hereby swear and affirm that the above statement is true and correct land is made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. By: '6' ,- n Signature Name: L&O ?. v r t >4 NO (Print name) Address: P.0 Box. 9 Date: `Z - 4q Time: FILED-&T-ICIE OF THE F`R07:10NMA,RY 2009 JUN 12 PM 12: 5 5 PENNSYUJ NI 1% C TONY DOUGLAS SAMENTO IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-3804 CIVIL ACTION LAW NANCI MARIKO SAMENTO IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, June 16, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. , the conciliator, at 39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, July 22, 2009 at 3:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ Dawn S. Sunday, Esq. 41 Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 OF 7]q T??Y 2009 17 PH 2. wc.?' < os _ JUN 15 2009 C7 v JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff/Petitioner TONY DOUGLAS SAMENTO, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No 09-3804 CIVIL NANCI MARIKO SAMENTO, CIVIL ACTION - AT LAW Defendant DIVORCE ORDER OF COURT AND NOW this 14,y ?^ day of N?? , 2009, a Rule is hereby issued on Defendant to show cause why the relief requested in Plaintiff's Petition for Special Relief should not be granted. a0 Rule returnabladays from service. It is further Ordered that pending further Order of Court, n ' e any es' neither party shall drive with any of their minor children in the car after having consumed any amount of alcoholic beverage whatsoever. BY OUR J. Distribution: (Je_anne B. Costopoulos, Esq., 5000 Ritter Road, Suite 202, Mechanicsburg, PA 17055 /JNanci Mariko Samento, 1066 Park Place, Mechanicsburg, PA 17055 L F'.S Y}'4`? t lL ? j ? joy Al AnTARY 2009 JUN 17 AM 10: 18 CUP,! .'.. ?(jy ?s. ow JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Attorney for Plaintiff TONY DOUGLAS SAMF,NTO, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No 09-3804 NANCI MARIKO SAMENTO, Defendant CIVIL ACTION - AT LAW DIVORCE/CUSTODY PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the following pleadings completely withdrawn, discontinued and dismissed: 1. Complaint in Divorce filed on June 9, 2009 2. Complaint in Custody filed on June 12, 2009 3. Plaintiff's Petition for Related Claims filed on June 12, 2009 4. Plaintiff's Petition for Special Relief filed on June 12, 2009 By: JEANNIE B. COSTOPOULOS, ESQ RE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 6 Date: Aj 109 Attorney for Plaintiff l ? CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the PA Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Nanci Mariko Samento 1066 Park Place Mechanicsburg, PA 17055 By: JEANNE B. COSTOPOULOS, ESQUI -.. Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 Date: U ! Attorney for Plaintiff FILED'- Ai "-Y F TNc IT 2009 AN' 19 A 13 : 2 9 Gtr;, j ?.r? 4