HomeMy WebLinkAbout09-6676CHRISTI W. CATALANO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. N- 00(0 CIVIL TERM
JOSEPH E. CATALANO
Defendant IN DIVORCE
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NOTICE TO DEFEND AND CLAIM RIGHTS t?
You have been sued in Court. If you wish to defend against the claims
following pages, you must take prompt action. You are warned that if you fail to e,
may proceed without you and a decree of divorce or annulment may be entered ?st yM b
the Court. A judgment may also be entered against you for any other claim or relief r ues j?o in
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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 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, 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
TELEPHONE: (717) 249-3166
CHRISTI W. CATALANO
Plaintiff
VS.
JOSEPH E. CATALANO
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes CHRISTI W. CATALANO, by and through her attorney, Dawn S.
Sunday, Esquire, who respectfully avers as follows:
1. Plaintiff/Wife is CHRISTI W. CATALANO who resides at 424 East Winding Hill
Road, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant/Husband is JOSEPH E. CATALANO who resides at 102B South Market
Street, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Husband and Wife have been bona fide residents in the Commonwealth for at least six
months immediately prior to the filing of this Complaint.
4. Wife and Husband were married on June 2, 2001 in Cumberland County,
Pennsylvania.
5. Husband and Wife separated on or about January 10, 2009.
6. There have been no prior actions for divorce or annulment between the parties.
7. Neither party is a member of the Armed Forces of the United States of America or any
of its Allies.
8. The marriage is irretrievably broken.
9. Wife has been advised of the availability of marriage counseling and that she may
have the right to request that the Court require the parties to participate in such counseling.
Being so advised, Wife does not request that the Court require the parties to participate in
counseling prior to a Divorce Decree being issued by the Court.
10. Wife requests that this Court enter a Decree in Divorce from the bonds of matrimony
under Section 3301(c) or Section 3301(d) of the Divorce Code.
WHEREFORE, Plaintiff/Wife requests that this Honorable Court enter a Decree
dissolving the marriage between the Plaintiff/Wife and the Defendant/Husband.
Respectfully submitted,
Dawn S. Sunday
39 West Main Street
Mechanicsburg, PA 17055
(717) 766-9622
I.D. # 41954
Attorney for Plaintiff/Wife
AFFIDAVIT
I, Christi W. Catalano, 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. Section 4904, relating to unsworn falsification to authorities.
1010(0109
Dat
Christi W. Catalano
FILM-40IFFICE
OF THE PROTHONOTARY
2009 OCT -7 PM 2: a 1
CUM ' ' . ,j: LINTY
PENNSYLVANIA
4335.-W P4 ATJ
ex* 4(09
2,r* ot3(563
CHRISTI W. CATALANO IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 09-6676 CIVIL TERM
JOSEPH E. CATALANO
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint on behalf of the Defendant, Joseph E. Catalano, and
certify that I am authorized to do so.
fa /50
Date
Maryann M rphy, Esquire
PMB 246
4902 Carlisle Pike
Mechanicsburg PA 17050
?E THE p ,1 nt\lf0 TRY
2009OCT 30 Fn I: 25
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTI W. CATALANO
V.
JOSEPH E. CATALANO NO 2009 - 6676
DIVORCE DECREE
AND NOW, rlw., ~ ` z o iv , it is ordered and decreed that
CHRISTI W. CATALANO plaintiff, and
JOSEPH E. CATALANO ,defendant, are divorced from the
bonds of matrimony.
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. All claims have been resolved by the terms of the Marital Settlement Agreement
signed by the parties on January 21.2010 which are incorporated but not merged into this
Decree for purposes of enforcement only. o
By the Court,