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Home My WebLink About01-0810Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHY DIPATRIZIO, Plaintiff V, DANIEL G. DIPATRIZIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- ~11~ 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 pages 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 THE 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHY DIPATRIZIO, Plaintiff DANIEL G. DIPATRIZIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 200% ~'/o CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPI AINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Kathy DiPatrizio, by and through her attomeys, Johnson, Duffle, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Daniel G. DiPatrizio: 1. The Plaintiff is Kathy DiPatrizio, an adult individual, residing at 56 Oliver Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Daniel G. DiPatfizio, an adult individual, residing at 303 Blue Jay Drive, Red Lion, York County, Pennsylvania 17356. 3. The Plaintiff and Defendant were marded on April 2, 1994 in Enola, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately pdor to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7, The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301(c) or 3301(d) of the Divorce Code. JOHNSON, DUFFLE, STEWART & WEIDNER Keirsten W. Davidson Mark C. Duffle :142989 VERIFICATION I verify that the statements made in this Divome Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A {}4904, relating to unsworn falsification to authorities. ~ Kathy/DiPatrizio Johnson, Duffle, Stewart & Weidner By: K¢irsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyn¢, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHY DIPATRIZIO, Plaintiff DANIEL G. DIPATRIZIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- ~)Z) CIVILTERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT KATHYDIPATRIZIO, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the ~enalties of 18 Pa.C.S. {}4904, relating to unsworn falsification to authorities. Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHY DIPATRIZIO, Plaintiff V. DANIEL G. DIPATRIZIO, Defendant IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-810 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICe. I hereby certify that on the 4th day of April, 2001, I served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant, Daniel G. DiPatrizio, by certified mail, restricted delivery, to his mailing address at 303 Blue May Drive, Red Lion, Pennsylvania 17356, return receipt requested, attached hereto and made a part hereof. :142989-6 JOHNSON, DUFFLE, STEWART & WEIDNER Keirsten W. Davidson Mark C. Duffle SENDER: delivered. 3. Article Addressed to: DANIEL G. DiPATRIZIO 303 BLUE MA~r DRI-v'E RED LION, P~ 17356 ~a~E'~re (Addres~ee-erAg99t) - ¥8 Form 3811, December 1994 I also wish to receive the follow- ing services (for an extra fee): 1. [] ~dressee's Address 2. [~'Restricted Delivery 4a. Article Number 4b. Service Type [] Registered [~edified [] Express Mail [] Insured [] Return Receipt for~rcha~e [] COD 7. Date of D 8. Addresse if requested and fee is paid) 102595~gS-B-0223 Domestic Return Receipt Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attomeys for Plaintiff KATHY DIPATRIZIO, Plaintiff V. DANIEL G. DIPATRIZIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 200%810 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on or about February 9, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Coud maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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: St/~./~ / ////~u/~ ~/' .~..~ I Kath~DiPatrizio, Plaintin :144997 KATHY DIPATRIZIO, IN THE COURT OF CC~MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-810 CIVIL TE~M Plaintiff vs. DANIEL G. DIPATRIZIO, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following inform~tion~ to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the cc~plaint: Certified mail, restricted delivery to the Defendant on April 4, 2001 and received by Defendant on April 9, 2001. 3. Cc~plete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff August 2, 2001 ; by the defendant August 2, 2001 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: ; (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code Waivers of Notice filed concurrently herewith and signed by Plaintiff on August 2, 2001 and by Defendant on August 2, 2001. Attorney for' Plaintiff~~ Keirsten W. Davidson Arty ID #78243 Johnson, Dnffie,.Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attomeys for Plaintiff KATHY DIPATRIZIO, V. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-810 CIVIL TERM DANIEL G. DIPATRIZIO, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 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. 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. Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHY DIPATRIZIO, Plaintiff DANIEL G. DIPATRIZIO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-810 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on or about February 9, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divome becoming final. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the 2enalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: August 2, 2001 ~~~~._~~" · G. DiPatrizio, Defend Johnson, Duffie,.Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attomeys for Plaintiff KATHY DIPATRIZIO, Plaintiff V. DANIEL G. DIPATRIZlO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-810 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 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. 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. Daniel G. DiPatrizio, Def~r~nt :144997 Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff KATHY DIPATRIZlO, Plaintiff DANIEL G. DIPATRIZIO, : : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-810 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint filed by the Plaintiff on February 9, 2001, in the above captioned action. JOHNSON, DUFFLE, STEWART & WEIDNER Keirsten W. Davidson Mark C. Duffle :144746 IN THE COURT OF COMMON PLEAS KATHY DIPATRIZIO, Plaintiff Of CUMI3ERLAN D COUNTY STATE Of ~-~1~ PENNA. NO. 2001-810 CIVIL TE~M VERSUS DANIEL G. DIPATRIZIO, Defendant AND NOW, DECREED THAT AND DECREE IN DIVORCE KATHY DIPATRIZIO DANIEL G. DIPATRIZIO 2001 , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED PROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BeEN ENTERED; None ~Z~ ARY