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Home My WebLink About10-3063 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI, V. JESSICA LYNN PASTUCCI, Defendant CASE NO. 10 -.5063 Civi I Tdr+ : CIVIL ACTION -LAW : IN DIVORCE NOTICE TO DEFENDANT 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 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 Defendant. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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 WHEY& YOU C:D CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 170 Telephone (717) 2 _166„ She D. Coover, Esquire A rneyID 93285 S. Hanover Street Carlisle, PA 17013 c? C f? r .f35a.0o po ATTY C01 3759 l2Ir agIV6 AMRICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. BY THE COURT: Date: J. t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI, V JESSICA LYNN PASTUCCI, Defendant CASE NO. : CIVIL ACTION -LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Joseph Pastucci who currently resides at 1051 Cranes Gap Road, Carlisle, Pennsylvania. 2. Defendant is Jessica Pastucci, who currently resides at 78 Tip Top Circle, Carlisle, PA 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on August 24, 2002. 5. Plaintiff and Defendant separated in September 2009. 6. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that she may have the right to request the Court to require the parties to participate in counseling. COUNT 1 3301(c) IRRETRIEVABLE BREAKDOWN 7. Paragraphs 1 through 6 are incorporated herein by reference. 8. The marriage is irretrievably broken and the parties are estranged due to marital difficulties with no reasonable expectation of reconciliation. 9. Plaintiff requests the Court to enter a decree in divorce. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolving the marriage between the parties. he D. Coover, Esquire orney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI9 V. JESSICA LYNN PASTUCCI, Defendant : CASE NO. : CIVIL ACTION -LAW : IN DIVORCE VERIFICATION I, Joseph Pastucci hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Jose h P cci Date: S -16-10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI, Plaintiff CASE NO. 10-3063 V. CNIL ATION -LAW IN DIVORCE JESSICA LYNN PASTUCCI, Defendant ~ a o ~..~ : ~ , ~ €7? ~ AFFIDAVIT OF SERVICE ~° s ~ ~ ~: l 1,, I, Sheri D. Coover, Esquire hereby certify that I did serve a true and corr~t~'copy~., ' a of the Com Taint in Divorce u n the Defendant Jessica L `'" P Po ynn Pastucci, by depo~g o~ ` ' _ ~~ ` causing to be deposited in the U.S. mail certified restricted delivery p g p p~d osta a re orr- Jessica Lynn Pastucci at Cazlisle Pennsylvania addressed as follows: ~ uz , ..~ Jessica Lynn Pastucci 78 Tip Top Circle Cazlisle, PA 17013 Return card acknowledging receipt on May 14, 2010 is attached as Exhibit "A. ly submitted, ~oover, Esquire ID 93825 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI, CASE NO. 10-3063 Plaintiff v. JESSICA LYNN PASTUCCI, Defendant CNIL ATION -LAW IN DNORCE CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certifies that on this 1 ?th day of May, 20 i 0, I caused the foregoing AFFIDAVIT OF SERVICE to be served upon the Defendant by United States First Class mail addressed as follows: Jessica Lynn Pastucci 78 Tip Top Circle Cazlisle, PA 17013 submitted, ,~heri D. Coover, Esquire Attorney ID 93825 44 S. Hanover Street Cazlisle, PA 17013 1 ~ , g N 0 ~ ~ m m C IL ~ ~ O ~ O ~ O ~ O IU O O rl Q M1 N ~ ~~ ~ r E ~ *' Z~ ~ M U ~~~ CV d Sheri D. Coover, Esquire PA Attorney ID 93285 Scaringi & Scaringi, P.C. 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff L1µ THE p NOS 110E 2012 JAM 12 AM' A CUMBERLAND COUNTY PERMS YLVA?IJOSEPH PASTUCCI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CASE NO: 10-3063 JESSICA LYNN PASTUCCI, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Sheri D. Coover, Esquire hereby certify that I did serve a true and correct copy of the PLAINTIFF'S AFFIDAVIT §3301(D) OF THE DIVORCE CODE and COUNTER- AFFIDAVIT UNDER §3301(D) OF THE DIVORCE CODE upon the Defendant Jessica Lynn Pastucci by depositing or causing to be deposited in the U.S. mail, certified, restricted delivery, postage prepaid on Jessica Lynn Pastucci addressed as follows: Jessica Lynn Pastucci 78 Tip Top Circle Carlisle, PA 17013 Return card acknowledging receipt on December 12, 2011 is attached as Exhibit "A". Ily submitted, SOeri D. Coover, Esquire caringi & Scaringi, P.C. Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Sheri D. Coover, Esquire PA Attorney ID 93285 Scaringi & Scaringi, P.C. 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff JOSEPH PASTUCCI, Plaintiff V. JESSICA LYNN PASTUCCI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO: 10-3063 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 12th day of January, 2012, 1 caused the foregoing AFFIDAVIT OF SERVICE to be served upon Defendant by United States First class mail addressed as follows: Jessica Lynn Pastucci 78 Tip Top Circle Carlisle, PA 17013 Ily submitted, ?heri D. Coover, Esquire Scaringi & Scaringi, P.C. Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 a Complete items 3, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: L -\i t ? C'If, A. Signature s X Agent _? f 13 Addressee B. F46ceived by ( Printed Name) G, Date of Delivery D, is delivery address different from Item I1 0 Yes If YES, enter delivery address below: 0 No Pk -7E Z; P s ice Type t rtlfieid Mail 0 Express Mail ? Registered etum Receipt for Merchandise 0 insured Mail ? C.O.D. 4. Restricted DeWe (Extra Fee 0 yes 2. Article Number j?013 0 0 { }? 85137 (r=srer from wrvics Jabeq >? ? ? `.^ ? ? ? ? _ PS Form 3811. February 2004 -- D6 esm is Return Receipt 702595.02-M-1540 Sheri D. Coover, Esquire PA Attorney ID 93285 Scaringi & Scaringi, P.C. 44 S Hanover Street Carlisle, PA 17013 (717) 960-0075 (telephone) (717) 960-0074 (facsimile) Attorney for Plaintiff 4rl ? ?`r.Z ?- JOSEPH PASTUCCI, Plaintiff v. JESSICA LYNN PASTUCCI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO: 10-3063 CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF $3301(D) DIVORCE DECREE TO: Jessica Lynn Pastucci 584 S. Louther Street Carlisle, PA 17013 You have been sued in divorce. You have failed to answer the complaint or file a counter-affidavit to the §3301(D) complaint or file a counter-affidavit to the §3301(D) affidavit. Therefore, on or after February 2, 2012, the other party can request the Court to enter a final decree in divorce. If you do not file with the prothonotary of the Court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the Court is attached to this notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. Respectfully submitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 JOSEPH PASTUCCI, Plaintiff V. JESSICA LYNN PASTUCCI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CASE NO: 10-3063 CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFI DAVIT UNDER 3301D OFT E D1 QRCE CODE Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (check (i), (ii), or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ______ (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking {b} above, I must also file all of my economic claims with the prothonotary in writing to serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me and I shall be unable thereafter to file any economic claims I verify 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. JENNIFER LYNN PASTUCCI Dated: NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU ISO NOT t+'tIISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT !FILE THIS COUNTER-AFFIDAVIT. U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: Scqr(ixqi4Sr&rinqi. P.C. iO kc.inr ??PA n t t o One piece of ordinary mail addressed to: f ?rce??lSictc lJnn `(d ilkzl a'l s. LoUAN)Qr S? -, Ss?r-LiSl.c , PA- L-wl3 -1. JV 11 , Jdl ludlY LVV 1 .U U ? ? M W a C _ .j o a U .3j J C6 N N 0 CU U U ?O 0 ? ~' f v ° v 3 • ? ? e C r '•? rd a??alo a rum . a R3 I r ? o0 U LZ w ca o? as S = Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for current fee. ?142012t w c C O ID Oy C r L 8 ? a E E w p d a?So_m O ? Z J_ Q p Z 0 O a V ^ LU < o `L. ' • W Q Z cc s ` V Z (o Z~ C m OJ s -? W Fa U) - a > Q? C E .? .i to J 00 rn u.? ` , o i a O d WO D U) LL W W p 0 >- U W U a d C c rn } 0 2a p i t V 7 6 0 i I L/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI, CIVIL ACTION AT LAW MM ? r- Plaintiff Case No. 2010-3063 ,,? r !<;= -,; 77 r-- > JESSICA LYNN PASTUCCI, Defendant IN CUSTODY PRAECIPE TO TRANSMIT RECORD To the prothonotary: Please transmit the record together with the following information to the court for entry of a divorce decree: 1. Ground for-divorce: irretrievable breakdown under §3-301(e ), (3301(d)(1) of the Divorce Code (strike out inapplicable section). 2. Date and manner of service of the complaint: Defendant accepted service of the divorce complaint by certified mail on May 14, 2010. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c ) of the Divorce Code: by plaintiff on ; by defendant on (b) Date of execution of the affidavit required by §3301(d) of the Divorce Code: 10/20/2011 ; (2) Date of filing and service of the plaintiff's attornev upon the respondent: Filed with Cumberland County Prothonotary on 12/6/11. Service upon Defendant via certified mail on 12/12/2011. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached; Notice of Intention to File Praecipe was served upon the Defendant via United States first class mail and was not returned as undeliverable on February 14, 2012. (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: Date defendant's Waiver of Notice was filed with the Prothonotary: Respocjfu I ly_uLl?m fitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOSEPH PASTUCCI V. JESSICA LYNN PASTUCCI No. 2010-3063 DIVORCE DECREE AND NOW, Mac l aN W-A Ph_, SDI ?, it is ordered and decreed that JOSEPH PASTUCCI plaintiff, and JESSICA LYNN PASTUCCI bonds of matrimony. , defendant, are divorced from the 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 By the Court, Attest: ! J. othonotary j -'?, Ie - Hofy 07,9,14al ,/, #t15 roover- oh Ic e W ccf /M/ AO d 7'0 ?p"?l