The URL can be used to link to this page

Home My WebLink About01-0819CAROL SUE PARTILLA, Plaintiff VS. GEORGE MICHAEL PARTILLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 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 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 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, Room 101, Dauphin County Court House, Front and Market Streets, Harrisburg, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted Debe presentar una apariencia escrita o en persona o por abogado y archivar en la cor~e en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo a viso o notificacion, y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO Tlr:NE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 CAROL SUE PARTILLA, Plaintiff VS. GEORGE MICHAEL PARTILLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DOMESTIC RELATIONS CODE COUNT I - DIVORCE 1. Plaintiff is Carol Sue Partitla, an adult individual who resides at 609 Alison Avenue, Borough of Mechanicsburg, County of Cumberland, Pennsylvania, 17055. 2. Defendant is George Michael Partilla, an adult individual who resides at 3 Highland Drive, Lower Allen Township, Cumberland County (Camp Hill), Pennsylvania, 17011. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 27, 1995 in Cumberland County. There have been no prior actions in divorce or annulment between the padies. The Defendant is not a member of the armed forces of the United States or any of 6. its allies. 7. 8. The Plaintiff avers that the marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. The Plaintiff does not desire counseling. Plaintiff avers that there are no children of the parties under the age of 18. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 above are incorporated herein by reference. 12. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Section 33502 of the Domestic Relations Code. WHEREFORE, Plaintiff requests Your Honorable Court to: Enter a Decree in Divorce; B. Equitably distribute all property, both personal and real, owned by the parties; C. Grant such further relief as the Court may deem equitable and just. CALDWELL & KEARNS 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 I. D. #07268 Attorney for Plaintiff 11655 VERIFICATION I, CAROL SUE PARTILLA, verify that the averments made in this Complaint are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Carol Sue Partilla 11660 CUMBERLAND REOORD OF ~ DIVORCE OR ANHULMEHT George 3 Highland Drive L. Allen Twp ~ 1 [] [] Carol 609 Alison Ave. 1 ~ Cumberland HUSBAND Michael Partilla ~m 7 9 1966 Cumberland PA e~m PA 0T.~ .... Comm. of Penna. Dept. of Public Welfare [] Sue Mechanicsburg Cumberland Salmon e~m 1 9 1 967 ~A '" ~ ~ ~wMD ,4.~ Sales Assistant - Stock Brokerage Firm ~ 5 27 1995 Section 3301(c) or (d) CAROL SUE PARTILLA, Plaintiff VS. GEORGE MICHAEL PARTILLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 -819 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I do hereby accept service of and acknowledge receipt of a certified copy of the Complaint in Divorce in the above case. Date:-?//~/OJ 20776 CAROL SUE PARTILLA, Plaintiff, VS. GEORGE MICHAEL PARTILLA, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-819 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 9, 2001. 2. Plaintiff acknowledges that a copy of the Complaint was served on the Defendant on March 13, 2001. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed, both from the date of the filing of the Complaint, and from the service of the Complaint. 4. I consent to the entry of a final Decree of Divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. Carol Sue Partilla, Plaintiff SS# 589-22-8901 00399/54311 CAROL SUE PARTILLA, Plaintiff VS. GEORGE MICHAEL PARTILLA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-819 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 9, 2001. 2. Defendant acknowledges that a copy of the Complaint was served March 13, 2001. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed, both from the date of the filing of the Complaint, and from the service of the Complaint. 4. I consent to the entry of a final Decree of Divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. Dated: March 2S"-, 2003 rge M. Partilla, Defendant SS# 130-60-1615 00399/54309 CAROL SUE PARTILLA, Plaintiff, VS. GEORGE MICHAEL PARTILLA, Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-819 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW COUNT II (EQUITABLE DISTRIBUTION} OF THE DIVORCE COMPLAINT To the Prothonotary of Cumberland County: Please withdraw Count II (Equitable Distribution) as set forth in the Divome Complaint originally filed on February 9, 2001. Date: ~.~,~. -z ~, , 2003 By: Respectfully submitted, Attorney I. D. # 07268 Caldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Plaintiff, Carol Sue Partilla CAROL SUE PARTILLA, Plaintiff, VS. GEORGE MICHAEL PARTILLA, Defendant, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-819 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary of Cumberland County: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: March 13, 2001, by Acceptance of Service from Defendant. 3. (Complete either paragraph (a) or (b)) (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, March 25, 2003; by Defendant, March 25, 2003. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 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: __ (a) Decree to be entered under 3301 (d)(1)(i) of the Divorce Code; ~ (b) Decree to be entered under 3301(c) of the Divorce Code; X (c) Not applicable. See Waiver in Consent forms. 6. Plaintiff's Social Security number: 130-60-1615 Defendant's Social Security number: 589-22-8901 Date: ~tJ,.~¢~¢. "z~ , 2003 Attorney for (X) Pla'hi,tiff ( ) Defendant 00399/54569 1N The COURT Of COMMON PLEAS CAROL SUE PARTILLA Plaintiff Of CUMBERLAND COUNTY STATE OF PENNA. NO. 01 -81 9 VERSUS GEORGE MICHAEL PARTILLA Defendant DECREE IN DIVORCE AND NOW, DECREED THAT AND /~ IS ORDERED AND / 2003 ~T Carol Sue Partilla _, PLAiNTIFf, George Michael Partilla , DEFENDANT, ARE DIVORCED FROM 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 by ThE COUrt: / PROTHONOTARY