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HomeMy WebLinkAbout10-3830 CINDY ANN C. PAGANO, Plaintiff v. ZOl~ ~v~3 I0 ~4 ~~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW DONALD L. PAGANO, JR., NO. /~"~~3D CIVIL TERM Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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. CUMBERLAND COUNTY BAR ASSOCIATION .35~ -d~ ~„(. 32 South Bedford Street ~" Carlisle, Pennsylvania 17013 ~ .~' ~/ ~~' Phone: (717) 249-3166 or (800) 990-9108 ~ ~3 ~S..Sr CINDY ANN C. PAGANO, Plaintiff v. DONALD L. PAGANO, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Cindy Ann C. Pagano, an adult individual currently residing at 383 Limestone Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Donald L. Pagano, Jr., an adult individual currently residing at 4172 Antelope Court, Apartment 115, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 6, 1995, in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 7. Plaintiff and Defendant are citizens of the United States of America. 8. The parties' marriage is irretrievably broken. 9. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: ~~ 1 ~.O \~ CIND ANN C. PAGANO, Plaintiff CINDY ANN C. PAGANO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DONALD L. PAGANO, JR. NO. 2010-3830 DIVORCE DECREE 1?1? . ?06- 4-0J.-I (, ?. M. 0, 9AV© , it is ordered and decreed that AND NOW, CINDY ANN C. PAGANO plaintiff, and DONALD L. PAGANO, JR. , 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.") None. The parties' Separation and Property Settlement Agreement entered into June 1, 2010 is incorporated herein, but not merged. By th urt, Attest: J. b /e? 11, P othonotary dew. A;K "??