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Home My WebLink About04-3710MICHAEL A. CATALANO, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA VS. : CIVIL ACTION -LAW SANDRA J. CATALANO, : IN DIVORCE i Defendant : NO. 0113 ?/D YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MICHAEL A. CATALANO, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : CIVIL ACTION - LAW SANDRA J. CATALANO, : IN DIVORCE Defendant : NO. D t,_ 3171,0 COMPLAINT UNDER SECTION 3301(c)OF THF. DIVORCE. CODE COUNTI AND NOW, this (p day of 2004, comes the Plaintiff, Michael A. Catalano, by his attorney, Jane . Alexander, Esquire, and files this Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is Michael A. Catalano, who currently resides at 251 Oak Grove Court, Mechanicsburg, Cumberland County, Pennsylvania for six (6) months. 2. Defendant is Sandra J. Catalano, who currently resides at 212 Conoy Avenue, Elizabethtown, Lancaster County, Pennsylvania for fifteen (15) years. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 5, 1989 at Elizabethtown, Pennsylvania. 5. There were no children born between the parties during the marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. S. 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. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT 11 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 11. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT iii 12. The allegations of Paragraph one (1) through eleven (11) are incorporated herein by reference and made a part hereof. 13. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully submitted, Jane M. AleIr, Esquir A torney fotiff I.D. No. 07355 148 South Baltimore Street a llsburg, PA 17019 (717) 432-4514 VERIFICATION I verify that the statements made in this Complaint are true and correct understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to un-sworn falsification to au onties. Date: -71,52&10 q Mttchael A. Catalano COMMONWEALTH OF PENNSYLVANIA S. S. COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, personally appeared Michael A. Catalano who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. atalan Michael A. C Nn Sworn to and subscribed before me this r2j day of J,.e . 2004. Notary Public Notarial Seal Halvard E. Alexander, Notary Public Dillsburg Boro. York County My Commission Expires Apr. 23, 2005 Member. PP.nnWvanla ASSociationotNotaries 1, ? t, w ?. W ? ,NJ ? p\` ? ? Ut ij N ry ( , n (tl ORIGINAL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MICHAEL A. CATALANO Plaintiff VS. No: 04-3710 SANDRA J. CATALANO Defendant PRAECIPE Please enter my appearance on behalf of the Defendant, Sandra J. Catalano, in the above captioned divorce. DATE: HONAMAN, 717-397-5127 Attorney ID #67907 PRIGINAL PROOF OF SERVICE I hereby certify that a true and correct foregoing Praecipe was served by first class mail, postage prepaid, addressed as follows: Jane M. Alexander, Esq. 148 South Baltimore St. Dillsburg, PA 17019 DATE: Lancaster, PA 1760 (717) 397-5127 Attorney I.D. 67907 copy of the 9L T 8 A ?k ir,f i p L 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MICHAEL A. CATALANO Plaintiff vs. SANDRA J. CATALANO Defendant . No: 04-371.0 PRAECIPE Please enter my appearance on behalf of the Defendant, Sandra J. Catalano, in the above captioned divorce. H:ONAMAN, LOS 02( & Lancaster, PA 17602 DATE: Attorney ID #67907 PY 15 N. Lime SU ? -n rn r `' CD MICHAEL A. CATALANO, Plaintiff VS. SANDRA J. CATALANO, Defendant : IN T14E COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA N0.04 10 : CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this day of 2004 personally appeared Jane M. Alexander, Esquire who s rs according to law, that a true and correct copy of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return receipt requested upon the said, SANDRA J.CATALANO 212 CONOY AVENUE ELIZABETHTOWN, PA 17022 on July 30, 2004 by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part hereof. M. Alexan r, E ney I.D. #07355 48 S. Baltimore Street PA 17019-0421 Sworn and subscribed before me this day of ,4 ? ? 2004. Notary Public t t Notarial Seal LHaicvard E. Alexander, Notary Public Diilsburg Boro, York County ommission Expires Apr. 23, 2005 Member. Pennsylvania AssociabonotNota0es (717) 4132-4514 MICHAEL A. CATALANO, : IN THE COURT OF COMMON PLEAS Plaintiff . OF CUMBERLAND COUNTY, PA VS. NO.04-370 SANDRA J. CATALANO, CIVIL ACTION - LAW Defendant IN DIVORCE PROOF OF SERVICE ¦ Complete items 1, 2, and 3. Also complete A. Received by (Please F dy) B. Dete item 4 if Restricted Delivery is desired. 7 3 4 • Print your name and address on the reverse C. Sign ure so that we can return the card to you. ? Agent ¦ Attach. this card to the back of the mailpiece, ? Addressee or on the front if space permits. li dd D I d m item 1? ? Yes t fr diff very a . s e eren o 1. Article Addressed to: If YES, enter tlel' ery ?sddress below: ? No c;7rdm S Coralano ale Conocf fi0enue 1 haabeth town M /70c;?--:z 3. Service Type "Certified Mail ? Express Mail dJ ? Registered )?I Return Receipt for Merchandise 0 Insured Mail C1 C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (Copy from service label) good i531) aOi5 .?W?'? ME PS Form 3811, July 1999 Domestic Return RecelDt 102596-00-M-0952 so u Or alTl M YPostage Ill S /Certified Fee M Retum Receipt Fee C3 ndorsemeat Required) C3 Restrlcted Delivery Fee O (Endorsement Required) C3 Total Postage & Fees M Ln ant rocc 5.1 . C3 Street, Apt. N ; rr 1:3 J _.G?p?1..!L7?_.. 0 Clty, Sfafe, G' Y5. N m 1) ry i? C Tll _:, ?('7 T CJ C? Curtis R. Long Prothonotary Office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor q - -3 y16 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573