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Home My WebLink About01-2495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Michele R. Agiu, Plaintiff VS. Viorel Agiu, Defendant : 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 you and a decree in divorce or annulment may be 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 the custody or visitation rights of your children. When the ground for 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, 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 LAVVYER 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Michele R. Agiu, : No. o)- ~'/~2~~ ~ Plaintiff : : Civil Action - Law VS. : : In Divorce Viorel Agiu, : Defendant : COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE Plaintiff is Michele R. Agiu, who currently resides at 340 E. Garfield Street, Shippensburg, Cumberland County, Pennsylvania, since May 26, 2000. 2. Defendant is Viorel Agiu, who currently resides at 812 Butler Street, Dunmore, Lackawanna County, Pennsylvania, since August 15, 2000. 3. Plaintiff and Defendant have been bona fide residents in 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 26, 1995, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken· 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. I-~. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 ! verify that the statements made in this Complaint are true and correct. ! understand that false statements herein are made subject to the )enalties of 18 Pa. C.S. Section 4904 relating to unsworn fal~fication to authori ies. Date: ~%~)1 Michele R. ~g z :x 0 -~ O~ -~ ~z T m e 0 C In ~ Z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Michele R. Agiu, : No. 01-2495 Civil Term Plaintiff : : Civil Action - Law VS, Viorel Agiu, Defendant : In Divorce ACCEPTANCE OF SERVICE I hereby accept service of the complaint in divorce and acknowledge receipt of the said complaint on May 3, 2001. Date: Vior Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Michele R. Agiu, : No.01-2495 Civil Term Plaintiff : : Civil Action - Law VS, : : Viorel Agiu, : Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the decree. 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. Michele R, Agiu Plaintiff N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- PENNSYLVANIA Michele R. Agiu, Plaintiff VS. : No. 01-2495 Civil Term : : Civil Action - Law Viorel Agiu, Defendant : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 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. 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. Date: ~/C)\ ! 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. Michele R. Agiu Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Michele R. Agiu, : No.01-2495 Civil Term Plaintiff : : Civil Action - Law VS. Viorel Agiu, : Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 27, 2001. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the decree. Date: 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. Viorel Ag i~J~t"-~ Defendant N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- PENNSYLVANIA Michele R. Agiu, Plaintiff VS. Viorel Agiu, Defendant No. 01-2495 Civil Term Civil Action - Law In Divorce WAIVER OF NOT[CE OF INTENT[ON TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. ! 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. 3. ! 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. Date: 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 unswom falsification to authorities. V!ore Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Michele R. Agiu, : No. 01-2495 Civil Term Plaintiff : : Civil Action - Law VS, : Viorel Agiu, : Defendant : In Divorce PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree; 1. Ground for divorce; irretrievable breakdown under 3301(c) of the Divorce Code. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on May 1, 2001 and was accepted IVlay 3, 2001 however the receipt was signed by Edna Trexler. An acceptance of service dated October 29, 2001 signed by Defendant acknowledging acceptance on May 3, 2001 was filed of record on November 26, 2001. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff December 5, 2001; by Defendant October 29, 2001. 4. Related claims pending: None. Plaintiff's Waiver of Notice was signed on December 5, 2001 and is filed herewith and Defendant's Waiver of Notice was signed October 29, 2001 and was filed on November 26, 2001. H. Anthony Ad,Ins, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~-~_ PENNA. MICHELE R. AGIU N O. 01-2495 PLEAS VERSUS VIOREL AGIU DECREE IN DIVORCE AND NOW, DECREED THAT December I ~ MICHELE R. AGIU 2001 , IT IS ORDERED AND , PLAINTIFF, AND VIOREJ, ACT[] , 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; N0~