Loading...
HomeMy WebLinkAbout01-0214F/User Folder/Finn DocslGendoc~2001\1994 Idivorce complaint wpd 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, Plaintiff JOHN D. CUNEO, Defendant CIVIL ACTION - LAW NO. 2001- o~/~/ 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 divome is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, Plaintiff V. JOHN D. CLrNEO, Defendant CiVIL ACTION - LAW NO. 2001- ,~ / 7 IN DWORCE COMPLAINT IN DIVORCE AND NOW, this 10th day of January, 2001 comes Plaintiff, Tanya L. Cuneo, by and through her attorneys, the Law Office of Michael J. Hanft, azad files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Tanya L. Cuneo, who currently resides at 1228 North Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is John D. Cunco, who currently resides at 83 East Main Street, Apartment 1, Newville, Cumberland County, Pennsylvarda 17241. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divome. The parties were married on June 4, 1994 in Carlisle, Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Sections 3301(c) of the Divorce Code of 1980, as amended. 6. The Plaintiffhas been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, LAW OF~CE OF MICHAEL J. H~ANFT Micha l~j.~H~ft, ~''? Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013~9142 (717) 249-5373 VERIFICATION I VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief. [ understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating~lsification to authorities, © Z > X~ TANYA L. CUNEO, Plaintiff V. JOHN D. CUNEO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-214 IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this /ot~//~ day of '~Jtv~v'~-/t~ , 2001, I, Michael J. Hanft, Esquire, hereby certify that the following person was served with a True and Correct copy of the Complaint in Divome filed in the above-referenced matter. The Complaint in Divorce was mailed on January 10, 2001, but actual service took place on January 12, 2001, by Defendant signing for a copy of the Complaint in Divorce which was mailed in the United States Mail, Certified Mail-- Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: John D. Cuneo 83 East Main Street Newville, PA 17241 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. Respectfully submitted, L~EL J. HANFT Michael J!Hanft, Esq~fiire ~ Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 SENDER: I also wish to receive the follow- a Complete items 1 and/or 2 for additional services. ~'"~'~'-~""_r v~l~ S (for an extra fee,~ Complete items 3, 4a, and 4b. ' D Pdnt your name and address on the reverse of th~s form s~ that we can returr?hi~ D Attach th's f°rm t° the 'r°nt °' tbe ma'lpiece' °r °n the beck if ~aee dce$ n°tipermit. [3 The Return Receipt will show to whom the article ~ ~ellver~i and the date~ · o aa. Article Number ~ Registered ~dffie~ ~ ~ Expre~ Mail ~ Insur~ ~ 7. Date of Deltve~ ~ 5. ~d By: (Pfi~Name) ~ 8. Addressee's ~dress (~ly if r~uest~ and g ~ (Addle or Ag~) PS Form 3~11~ ~ember 1994 102595-99-0-0223 Domestic Return Receipt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, Plaintiff V. JOHN D. CUNEO, Defendant CIVIL ACTION - LAW NO. 2001-214 IN DIVORCE AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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., Section 4904 relating to unsworn falsification to authorities. ~ ~__~. ///--/~?//~ d/~ Tanya L.~,Cuheo, Plaintiff Sworn to and subscribed before me this //-rt~ dayof /~/o,4~2~ ,2001. Notary li~cc ' Notarial ~eal Terry E. Walker, Notary Public . .So~t_ h Mldclleton TWp,, Cumbel'land County My ~ommlsslon Explrea Mar. 31, 2003 Member, P~-nnsylvenl~ ~.~ciation 0t N0tarles IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, Plaintiff V. JOHN D. CUNEO, Defendant CIVIL ACTION - LAW NO. 2001-214 IN DWORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C~ OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I 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 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: /~,/0 ~ //o~ Od)/ Tanya L.c~uneo, Plaintiff TANYA L. CUNEO, Plaintiff V. JOHN D. CUNEO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-214 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C~ OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer' s fees or expenses if I do not claim them before a divorce is granted. 3. I 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 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 unsworn falsification to authorities. Date: John D. Cuneo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, Plaintiff V. JOHN D. CUNEO, Defendant C1VIL ACTION - LAW NO. 2001-214 IN DIVORCE AFFIDAVIT OF CONSENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are hue 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. Date: lllOOmlield Bo~, Sworn to and subscribed before me this o~77~4t ~ dayof ~/P~l ,2001. Nothry Public 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, Plaintiff JOHN D. CUNEO, Defendant CIVIL ACTION - LAW NO. 2001-214 IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter having been granted a Final Decree in Divorce from the bonds of matrimony on the 17th day of May, 2001, hereby elects to retake and hereafter use her previous name of TANYA L. SCHAEFER and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 2, 54 Pa. C.S.A. Section 704. Tanya L. C~un~ Tanya L. Schaefer COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) On the~J0t~v day of ~ ~t)~ ,2001, before a Notary Public, personally appeared TANY~. SCHAEFER, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Notarial Seal My Comrmssion Expires Aug. lB, 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TANYA L. CUNEO, : Plaintiff : JOHN D. CUNEO, : Defendant : CIVIL ACTION - LAW NO. 2001-214 IN DIVORCE To the Prothonotary: decree: Code. PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the complaint: via certified mail, return receipt requested, restricted delivery - Complaint was mailed on January 10, 2001 and received on January 12, 2001. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; April 11,2001; by the Defendant; April 27, 2001. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301 (d)(1)(i) of the Divorce Code: Date Plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: May 7, 2001; Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: May 7, 2001. By~~LAW O FICE OF MICHAEL . HANFT Attorney I.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Date: Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. Plairitif~laintiff Versus .... D~fegdant DECREE IN DIVORCE AND NOW,. .... .............. ['7 , ~1-9.~. .... , it is ordered and decreed that ...............~ .~_]_]_]_]_]_]_]_A~..& .~...~ .................... plaintiff, and ......................... 49.~.. D,. ~ .................... defendant, are divorced from the bonds of matrimony. The court retains jurisdiction ot the following claims which have been raised of record in this action for which a final order has not yet been entered;