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Home My WebLink About01-2035 LEONARD A. ARNABOLDI : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERL~ COUI~Y, PENNSYLVJ~IA v. : NO. ~/~ ~2~35~ Civil : NANCY ARNABOLDI : Defendant : IN DIVORCE COMPLAINT AND NOW comes Plaintiff, by his attorney, Kent H. Patterson, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, Leonard A. Arnaboldi, is an adult individual residing at 295 Sled Drive, Apt# 2, Shermans Dale, Perry County, Pennsylvania 17090. 2. Defendant, Nancy Arnaboldi, is an adult individual residing at 115 Hillside Road, Silver Spring Township, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been a bona fide resident in the Commonweal th of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 20, 1973 in Yonkers, New York. 5. There have been no prior actions for divorce or annulment between the parties. 6. Plaintiff and Defendant are both citizens of .the United States of America. 7. Defendant is not a member of the Armed Services of the United States or any of its allies. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 VERIFICATION I, Leonard A. Arnaboldi, verify that the statements in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penal ties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. ~'~eo~ard A .-' Ar-nabo~ldi~ Date LEONARD A. ARNABOLDI, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 01-2035 CIVIL NANCY ARNABOLDI · : Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Kent H. Patterson, attorney for Plaintiff, hereby certify that I served Defendant with the Complaint in Divorce on April 10, 2001 by mailing a copy of same by U.S. Certified Mail, postage paid, addressed to Defendant as follows: Nancy Arnaboldi 115 Hillside Road Mechanicsburg, PA 17050 Attached hereto is the sender's receipt and the return receipt card which is signed by Nancy Arnaboldi and indicates a date of delivery of April 16, 2001. Kent H. Patterson Attorney for Plaintiff 221 Pine Street Harrisburg, PA 17101 (717) 238-4100 LEONARD A. ARNABOLDI, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : V. : No. 01-2035 CIVIL : NANCY ARNABOLDI , : Defendant : IN DIVORCE Postage Certified Fee ," ~ Return Receipt Fee Indorsement Required) ~estricted Del/very Fe · .~ndorsement Required~ .: Total Postage & Fees , SENDER: · Complete items 1 and/or 2 for additional · . · Co.m lete ~ services. SO wish to receive the · Pnnt your name and address on the revers I P 'terns 3, 4a, and 4b. followin serv' · Attach this iorm to the front of the mailniece. - a,, re[urn this extra Tee): i form to t e front of the ailpiece, r on the bac dressee Address · The Return Recmpt will show to whom the article was dellverei and the date I~ss :TWhr~tR~/nU~eRc~p~iPw~llR~hqoUwe~tne~'~°~,,,th,,e~rn_ai{~!ecebel0~the rticl;~~i I ;:~ ~;s°~r~cStSe~e;eAli~ed delivered. 3. Article Addressed to: Consult postmaster for fee. ype · E] Registered Certified o .n u e, for Merchandise E] COD .. and fee is paid) ss (Only requested nature: ~r 1994 10as95-98-8-0229 Domestic Return Receipt LEONARD A. ARNABOLDI, Plaintiff : IN T~{E COURT OF COMMON PLEAS : CUMBERLAND COUNTy, PENNSYLVANIA V. : : No. 01-2035 NANCY ARNABOLDI, : CIVIL Defendant : : IN DIVORCE AND NOW comes Plaintiff, Leonard A. Arnaboldi, by his attorney, Kent ~. Patterson, and files this petition as follows: 1. Petitioner is Leonard A. Arnaboldi who is the Plaintiff in this divorce action. 2. Respondent is Nancy Arnaboldi who is the Defendant in this divorce action. 3. Plaintiff and Defendant separated in March 2001 and Plaintiff filed the complaint in divorce on April 6, 2001. 4. Plaintiff and Defendant own marital property consistin~ of real estate which is titled in joint names and personal property which is titled in individual and joint names or is untitled, inc 1 udin~ pensions, deferred s avin~s, motor vehicles, bank accounts, household furnishings and other tangible personal property. 5. Since the separation Defendant has been in ~OSsession of the marital residence at 115 Hillside ~oad, Silver S~rin~ Township, Cumberland County and its contents which consist of marital assets and ~laintiff,s individual non-mar/tal assets. 6. ~laintiff recently learned that Defendant has been removin~ and sellin~ many items of household furnishings and tangible ~ersonal ~ro~erty but Defendant has refused to disclose the whereabouts of this tangible ~ersonal ~ro~ert¥ and to whom and for how much she has sold the tangible ~ersonal ~ro~erty. 7. ~laintiff also recently learned that Defendant, on or about July 1, 2001, hired an auctioneer whose identity is unknown to remove all items from the ~ara~e which is attached to the house and which consisted of ~ower, hand and hydraulic tools, work benches, industrial steel cabinets, air compressor and other mechanics tools and equipment which are the ~ro~erty of the ~laintiff (both martial and non-marital) and have significant value. 8. ~laintiff further recently learned that Defendant listed the real ~ro~erty at 115 Hillside ~oad for sale with a realtor and si~ned Plaintiff · s name to the listin~ a~reement wi thout Plaintiff, s authorization. 9. Section 3323(f) and Section 3505(a) of the Divorce Code and Pa R.C.P. 1920.43(a) ~ives the court equity power to issue injunctions and other orders necessary to protect the interests of the parties and to prevent the removal, dissipation, transfer or encumbrance of real or personal property. WHEREFORE, Plaintiff requests Your Honorable Court to grant the following relief: a. Order that Defendant be enjoined from removin~ any household furnishings, tools and equipment and other tangible personal property from the premises at 115 Hillside Road, Silver Spring Township, Cumberland County (Mechanicsburg, PA 17050) and from selling, transferring, dissipating or encumbering any household furnishings, tools and equipment and tangible personal property, except upon a~reement of the parties or further order of court; and b. Order that Defendant be enjoined from selling, transferring, disposing, dissipatin~ or encumbering any other marital assets of the parties and any of Plaintiff,s non-marital assets, except upon agreement of the parties or further order of court; and c. Order that Defendant disclose and provide an accountin~ of all household furnishings, too ls and equipment and tangible personal property that she removed or caused to be removed from the premises at 115 Hillside Road, Silver Sprin~ TownshiD' Cumberland County, PA and any other marital and non-marital assets that she has sold, transferred, dissipated or encumbered since March 2001. appropriate, d. Such other action as the court deems Attorney for Plaintiff 221 Pine Street ~{arri sbur~, PA 17101 , (717) 238-4100 _VERI FI CATIO~ I, Leonard A. Arnaboldi, verify that the statements in the fore~oin~ petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. 4904 relatin~ to unsworn falsification to authorities. .. Date LEONARD A. ARNABOLDI, : IN T~E COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : V. : No. 01-2035 CIVIL : NANCY ARNABOLDI, De f endan t : : IN DIVORCE ORDER AND NOW this /~d~ of ~~.~~ , 2001, i~ is ordered that a hearing shall be held on the /?~day of ~~~ ,2001, at /~6;~O 6~, m. in Court Room No. ~ of the Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013, at which time the Court shall consider the Petition for Special Relief to Enjoin Sale, Transfer or Dissipation of Marital Assets filed by Plaintiff. Except upon further order of court or agreement of the parties, Defendant shall not remove any household furnishings, tools and equipment or other items of tangible personal property from the residence at 115 Hillside Road, Silver Spring Township, Cumberland County, PA and shall not otherwise sell, transfer, dissipate or encumber any of said tangible personal property, any other marital assets of the parties and any non-marital assets of Plaintiff. Defendant shall disclose to Plaintiff all tangible personal property that she has removed from the ~ residence at 115 Hillside Road since March 2001. ~ ' BY THE COURT: J. LEONARD A. ARNABOLDI, · IN THE COURT OF COMMON PLEAS OF Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA VS. · 0!-2035 CIVIL · CIVIL ACTION- LAW NANCY ARNABOLDI, . Defendant ' IN DIVORCE _0ORDER AND NOW, this 1 7"~ day of August, 2001, this matter having been called for hearing and following meeting with counsel in chambers, it is ordered and directed that neither party hereto shall remove any household furnishings, tools and equipment or other items of tangible personal property from the residence at 115 Hillside Road, Silver Spring Township, Cumberland County, Pennsylvania, nor shall they otherwise sell, transfer, dissipate or encumber any of said tangible personal property, any other marital assets of the parties and any nonmarital assets of either party, except upon further order of court or upon agreement of the parties. This order will reflect that the defendant has provided to the plaintiff by way of auctioneer's receipts an itemization of marital assets previously sold by her. The defendant is directed, further, to provide a listing of items of marital property removed from the residence and their current locations. Defendant shall forthwith return to the plaintiff an antique hunting rifle. · The plaintiff shall be permitted to retrieve the mechanic's tools at a time and place to be mutually agreed upon by the parties. BY THE COURT, K/A. Hess, J. Kent H. Patterson, Esquire For the Plaintiff Lindsay Dare Baird, Esquire For the Defendant :rlm