HomeMy WebLinkAbout09-6320ti
KIMBERLY A. IANNUZZI,
Plaintiff
V.
BIAGIOIANNUZZI ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009- /, ? CIVIL TERM
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 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 available in the
Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. 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 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
i
KIMBERLY A. IANNUZZI,
Plaintiff
V.
BIAGIOIANNUZZI ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009- 63oZb CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
DIVORCE COMPLAINT
1. Plaintiff is Kimberly A. Iannuzzi, an adult individual who currently resides at
920 Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013.
2. Defendant is Biagio Iannuzzi, an adult individual who currently resides at 920
Armstrong Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 9, 1989 in Chambersburg,
Franklin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of counseling and that she may
have the right to request that the court require the parties to participate in Counseling.
8. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the
Plaintiff and against the Defendant.
Vft.
COUNT II -EQUITABLE DISTRIBUTION
9. Plaintiff hereby incorporates by reference paragraphs 1 through 8 above.
10. The parties have acquired real estate, personal property, including automobiles,
bank accounts and other items of miscellaneous property during the course of their marriage,
some of which is marital property.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree
which effects an equitable distribution of marital property.
Date: ? If G?
Respectfully submitted,
RIEN, C S RER
David A. Baric, Esquire
I.D.# 44853
19 West South Street
Carlisle, PA 17013
(717) 249-6873
Attorney for Plaintiff
i 1 `
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: I o l
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Itmberly A. Iannuzzi
(J
()c THE OP-6 rARY
2099 SEP 23 AM I I *- 10
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KIMBERLY A. IANNUZZI, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009- 06320 CIVIL TERM
BIAGIO IANNUZZI, CIVIL ACTION-LAW
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
AND NOW, this2,'?,0,4ay of September, 2009, I, Biagio Iannuzzi, Defendant above,
hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1930 (d) and
acknowledge receipt of a true and attested copy of said Complaint.
i
Biagio iannuzz
OF ?fir F"70T ?`?',!OT Y
2009 SEP 24 M 11: G !
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