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Home My WebLink About04-3384 II VICTOR DiANGELANTONIO, Plaintiff : IN TIffi COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. N 1\ L/ - .3 441.{ /' i",:1 T....~,.. : o. v -J oJO '- . KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - AT LAW IN DNORCE 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 papers by the Plaintiff. You may lose money or property or other rights important 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, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE TIffi RIGHT TO CLAIM ANY OF TIffiM. 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 LmERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (800) 990-9108 II VICTOR DiANGELANTONIO, Plaintiff : IN TIffi COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - AT LAW IN DNORCE COMPLAINT IN DIVORCE The Plaintiff, Victor DiAngelantonio, through his attorneys, The Law Offices of Patrick F. Lauer, Jr., L.L.C. makes the following Complaint in Divorce and, in support thereof; avers as follows: 1. Plaintiff is Victor DiAngelantonio, an adult individual, who currently resides at 428 Orrs Bridge Road, Camp Hill, County of Cumberland, and State of Pennsylvania. 2. Defendant is KatWeen Gail Fisher, an adult individual, who currently resides at 42 Anthony Way, County of Ocean, and State of New Jersey. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married in 2001, at Ocean City, Ocean County, New Jersey. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. The 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. II COUNT 1- REOUEST FORA NO FAULT DIVORCE UNDER SECTION 3301 OF THE DIVORCE CODE 8. The prior paragraphs, one (1) through seven (7) of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. This action is not collusive as defined by Section 3309 of the Divorce Code. WHEREFORE, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to 9 3301 of the Divorce Code. DateD? ( p/O 1 -' . Caraciolo, squire ket Street, Aztec Building p Hill, Pennsylvania 17011-4706 90919 Tel. (717)763-1800 II VICTOR DiANGELANTONIO, Plaintiff : IN TIffi COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - AT LAW IN DNORCE VERIFICATION I verifY that the statements made in this Complaint for Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904, relating to unsworn falsification to authorities. Date: '1 \ \ '2\ ~ Signature:~~ V.z, ~ A~O t~ Victo~~a:~oniO II VICTOR DiANGELANTONIO, Plaintiff : IN TIffi COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - AT LAW IN DNORCE CERTIFICATE OF SERVICE I hereby certifY that I am this day serving a copy of the foregoing Divorce Complaint upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by delivering the same to the person named as follows, delivery certified and regular mail, addressed as follows: KatWeen Gail Fisher 42 Anthony Way Jackson, NJ 08527 Date:O?!';)..../o'1 Respe lly submitted, , /1 !/{ JO: t~JciolO,~ v 21t~ket Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID#90919 Tel.(717)763-1800 ~(\ " '-.. v, ~ ~ ~ I-' i (; Sl ~~-~ \ ~- , ~ ~\2 ~ ~ ~. ~ '\k ~ ~ V\ ~" 0" l;-"; '. VICTOR DIANGELANTONIO, plaintiff : IN TIm COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-3384 CIVIL TERM KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - AT LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 13, 2004. . t 2. The marriage of the Plaintiff and the D€:fendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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 fulsification to authorities. DATE: M<1-l Signature: ~~~~~ VICTOR DIANGE ONIO f, q ~-?,: f'-o,) = = J;:'" o r""'l n I N o -11 --I -r:-n fnp "r,f1"1 -'19 C~~ '(> 2~ -v ::"t: - ., U1 -J II VICTOR DIANGELANTONIO, plaintiff : IN TIllE COURT OF COMMON PLEAS OF : CUMBERLAND COUNlY, PENNSYLVANIA vs. : No. 04-.3384 CIVIL TERM KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION -AT LAW IN DNORCE I 11 Ii 1 ' I PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE Ul\1>ER SECTION 3301(c) OF TIlE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concel1l1ing 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. 4. 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: \~~q\~ . S~:~~ VICTOR DIAN LANTONIO ( ~..~~ ~~.J -< q C \ ': '. r--.) = c..:--" .c- o r~" ("') I N o -r1 ~"'n \'11--: IT\ ::go (", 1.. .,-;C) -;:: ::H ;0!:~ o _.~ ~~~ -0 ::I:': (Jl -l I . VICTOR DiANGELANTONIO, , I Plaintiff vs. KATHLEEN GAIL FISHER, Defendant : IN TIffi COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. ,j~ - 333'fC"~f/7~ : CIVIL ACTION - AT LAW IN DIVORCE ACCEPTANCE OF Sli'RVICE I accept service of the foregoing Complaint in Divorce, I certifY that I am authorized to accept service on behalf of the above captioned defendant. (;. (' ,-, c>.' :;:) C..: en ("', 1" ,0 -(, -;J ::l.~ - <;'-J ,.> 0') II VICTOR DlANGELANTONI0, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : No. 04-3384 CNIL TERM KATHLEEN GAlL FISHER, Defendant : CNIL ACTION - AT LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE L A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 13, 2004. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of fi1ing and service of the Complaint. 3. 1 consent to the entry of a fina1 decree of divorce after service of notice of intention to request entry of the decree. 4, 1 verifY that the statements made in this affidavit are true and correct, 1 understand that fulse statements herein are made subject to the penalties of 18 Pa. C.S, ~ 4904 relating to unsworn fulsification to authorities. DATE:mnc4 Signature: ~~.~ [~~~~~ VICTOR DlANGE ONIO ,- t",) - I' \- , I II I VICTOR DiANGELANTONIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs, : No. 04-3384 CIVIL TERM KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - AT LAW IN DIVORCE DEFENDANT'S AFFIDA VIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 13, 2004. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Comp1aint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree, 4. I verifY tha1 the statements made in this affidavit are true and correct. I understand tha1 fulse statements herein are made subject to the penalties of 18 Pa. e.S. ~ 4904 relating to unsworn fulsification to authorities, Date:~~ \""'~"' c'::-- ~:. (--j -1-, -<, c::; r'i- 0:-) ......) \.D - \:~ Co) (,.;:; <, -<------ I' VICTOR DlANGELANTONlO, plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-3384 CIVIL TERM KATHLEEN GAlL FISHER, Defendant : CIVIL ACTION - AT LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE mmER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2, I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees, or expenses ifl do not claim them before a divorce is granted. 3, 1 understand that 1 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. 4. 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: ~4- Signa ') 0 .-.' "j ,c? c~ :? ':n CJ ":;1 \",,- c-) r-...., ...0 -() :3: - 1:'] L.) c/.:: VICTOR DiANGELANTONIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO.: 04-3384 KATHLEEN GAIL FISHER, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAF,(,TPF, TO TRANSMIT RF,C'ORn To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: L Ground for Divorce: Irretrievable breakdown under 9 3301(c) S JJ01(J)(l) ofthe Divorce Code. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Defendant signed an Acceptance of Service on August 16,2004. See attached Acceptance of Service. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by the Plaintiff Nov"mh"r)9 )004 by the Defendant n"""mh"r 1, )004 (b) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: Date of filing of the Plaintiff's affidavit upon the respondent: Date of service of the Plaintiff's affidavit upon the respondent: _. 4. Related claims pending: Non" No d"im, r";,,,eJ 5. (Complete either paragraph (a) or (b).) (a) Date and mmmer of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, (b) Date Plaintiff's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: n"""mh"r, )004 Date Defendant's Waiver of Notice in 9 3301(c) Divorce was filed with the prothonotary: fiJ"eJ ,imlllt"n"oll,ly w/Pr""ci[l" Respecf~IJY{ubmittyd, ..' / / .,/' tfvf-- Date: /).. /). 7/0 '1 ( : J eph D. araciolo, Esquire tLaw Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID#90919 Tel. (717)763-1800 (') f:";; ,--> c:;:. C'.> x- c) \"1'\ c: -:> C'~ -"i" ,"" .-' i'l1 ,,> .....0 -[1 r:? W c::..:; . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '''If.;+:''' . . . ~ ~~ ;+:~ ~~;+:~;+: ~ ~ ;+:~;+:;+: ;Ii"''''''':+: "':to: :+::+: "',., :Ii;!;'" if. :+;",:+;;I; .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY VICTOR DiANGELANTONIO, PENNA. STATE OF Plaintiff No. 04-3384 VERSUS KATHLEEN GAIL FISHER, Defendant DECREE IN DIVORCE .:rt:,~<,tyI. }cor , IT IS ORDERED AND ....:- 3JM,4--~ r AND NOW, Victor DiAngelantonio , PLAINTIFF, DECREED THAT Kathleen Gail Fisher , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION F'OR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. '\ \ B~E~...OU'.. ...... , ,.c.' j' ATTEST: PROTHONOTARY ~~ . .. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J, . . . . . . . . . . . '" ;f. ~ ,.,-'+' (:1 ,77 7- //(/'~?W/ ~!Pt/., ':T'.7r''''? ~ ~ 1Tvw4Wrf) ~;f]. )/, / ,;>(}(jl'/ ." .