HomeMy WebLinkAbout10-2066LOUIS J. BIANCO, : IN THE COURT OF COMMON PLEAS N
Plaintiff : CUMBERLAND COUNTY, PENNSYWAl?
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SHANNON M. BIANCO, : CIVIL ACTION - LAW -T,
Defendant : IN DIVORCE _
NOTICE
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You have been sued in Court. If you wish to defend against the claims set forth in the
following papers, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a Decree in 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 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, Pennsylvania 17013
Phone: (717) 249-3166
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LOUIS J. BIANCO,
Plaintiff
V.
SHANNON M. BIANCO,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
. NO.
CIVIL ACTION - LAW
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
To the Within Named Defendant:
You have been named as the Defendant in a divorce proceeding filed in the Court of
Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section
3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend
marriage counseling prior to a divorce decree being handed down by the Court. A list of
professional marriage counselors is available at the Office of the Prothonotary, One Courthouse
Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from this 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.
Prothonotary
LOUIS J. BIANCO,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO.
SHANNON M. BIANCO, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT UNDER SECTION 3301
OF THE DIVORCE CODE
Plaintiff is Louis J. Bianco, who currently resides at 1734 Fulton Street, Harrisburg,
Dauphin County, Pennsylvania 17110.
2. Defendant is Shannon M. Bianco, who currently resides at 624 4°i Street, New
Cumberland, Cumberland County, Pennsylvania 17070.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 16, 2009, in Lancaster,
Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The Plaintiff is a citizen of the United States of America.
7. The Defendant is not a member of the Armed Services of the United States of
America or its Allies.
8. The marriage is irretrievably broken. The parties to this action have been physically
separated within the marital residence since December 16, 2009.
9. The Plaintiff has 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.
10. Plaintiff requests the Court to enter a Decree in Divorce.
11. This action is not collusive.
WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the
marriage between the Plaintiff and Defendant.
Respectfully submitted,
JAMES, SMITH, DIETTERICK
& CONNELLY, LLP
Dated: J-A?-Io By:
J' J 'Conn lly, Jr.
tto ey I. 55_ 15615
P.O. 6 0 ?_..__
Hershey, PA 17033-0650
(717) 533-3280
Attorneys for Plaintiff
Louis J. Bianco
VERIFICATION
I verify that the statements made in this Pleading 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
unworn falsification to authorities.
Date:
Louis J. Bianco, Plaintiff
LOUIS J. BIANCO,
Plaintiff
V.
SHANNON M. BIANCO,
Defendant
AFFIDAVIT OF SERVICE
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 10-2066
CIVIL ACTION - LAW
IN DIVORCE
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
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AND NOW, this 29th day of March, 2010, personally appeared before me, a Notary Public
in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly
sworn according to law, deposes and says that a copy of the Divorce Complaint was served on the
Defendant, Shannon M. Bianco, on March 27, 2010, by certified mail number 7008 1300 0001 8218
0847, as evidenced by the return receipt card attached hereto and made a part hereof.
Sworn to and subscribed
before me this J?
day of March, 2010.
otary Public
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Louis J. Bianco
v.
Shannon M. Bianco NO, 10-2066
DIVORCE DECREE
AND NOW, ~ J ~ y 7 ~.~~~ , it is ordered and decreed that
LOUIS J. Bianco ,plaintiff, and
Shannon M. BIanCO ,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.")
The attached Marital Settlement Agreement is hereby incorporated, but not
mere , m is ecree m ivorce.
By the Court,
Attest: J.
Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff ~ ~ ~ ~ ~ ~ ~/'
p~ Vs File No. (~
e~ /i 1 l y~ ~ ~ ~ ~ j n ~ ~ ~1 IN DIVORCE
J 1 `LL f I lDl/efUe lndanlJt
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /defendant in the above matter,
[select one by marking "x"]
prior to the entry of a Final Decree in Divorce,
or ~ after the entry of a Final Decree in Divorce dated ~ ~ ~~
hereby elects to resume the prior surname of ~~,-'Q.~~ ,and gives this
written notice avowing his /her intention pursuant to the provisions of 54 P.S. 70
Date: (~
Signature
~e ( .
Signature of name being resumed
COMMONWE TH OF PENNSYLVANIA }
COUNTY OF
On the ~~day of , 20QQ, before me, the Prothonotary or the
notary public, personally appeared e above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he /she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal,
Kotary P lic
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