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Home My WebLink About04-6464SALLY A. NARDI, Plaintiff V. DANIEL D. NARDI, Jr., Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 04- 6 y(Ay : CIVIL ACTION - LAW : 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 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 to you, including custody or visitation 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, One Courthouse Square, Carlisle, Cumberland County, 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 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 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SALLY A. NARDI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0 4l - ?lP DANIEL D. NARDI, Jr., : CIVIL ACTION - LAW Defendant : DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Sally A. Nardi, is an adult individual who currently resides at 6666 Springford Terrace, Harrisburg, Dauphin County, Pennsylvania 17111. Her date of birth is September 8, 1963, and her social security number is 169-60-1292. 2. Defendant, Daniel D. Nardi, Jr., is an adult individual who currently resides at 508 Hillside Road, New Cumberland, Cumberland County, Pennsylvania 17070. His date of birth is September 2, 1963, and his social security number is 166-58-7984. 3. Plaintiff and Defendant have been bonafide residents in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint in Divorce. 4. The Plaintiff and Defendant were married on May 16, 1997, in Hershey, Dauphin County, Pennsylvania. 5. There have been no other prior actions of divorce or annulment filed by either of the parties hereto. 6. 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. COUNTI ALIMONY 9. The averments of paragraphs 1 through 8 are incorporated herein by reference as though fully set forth at length. 10. The Plaintiff believes and therefore avers that she is entitled to an award of alimony pursuant to the provisions of the Divorce Code. COUNT II ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 11. The averments of paragraphs 1 through 10 are incorporated herein by reference as though fully set forth at length. 12. The Plaintiff believes and therefore avers that she is entitled to an award of alimony pendente lite, counsel fees, costs and expenses. 13. Defendant is fully well and able to pay Plaintiff alimony pendente lite, counsel fees, costs and expenses incidental to this divorce action. COUNT III EQUITABLE DIVISION OF MARITAL PROPERTY 14. The averments of paragraphs 1 through 13 are incorporated herein by reference as though fully set forth at length. 15. Plaintiff and Defendant are the joint owners of marital property which is subject to equitable distribution by this Court. 2 WHEREFORE, Defendant respectfully requests the Court enter a decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Directing the Defendant to pay alimony to the Plaintiff, C. Directing the Defendant to pay alimony pendente lite and Plaintiffs counsel fees, costs and expenses incidental to this divorce; and d. Granting such further relief as the Court may determine equitable and just. Respectfully submitted, Heather M. Faust Attorney ID #77947 Killian & Gephart 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Dated: December 17, 2004 VERIFICATION I hereby verify that the statements of fact made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S.A. §4904, relating to unworn falsification to authorities. December 21, 2004 ?,?? t ?tc Sally N fi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Sally A. Nardi Plaintiff W Daniel D. Nardi Defendant File No. 04-6464 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, [Select one of the following] X prior to the entry of a Final Decree in Divorce, or ? after the entry of a Final Decree in Divorce dated, hereby elects to resume the prior surname of Sally A. White , and gives this written notice avowing his/her intention pursuant to the provisions of 54 P.S. 0 704. Date: 1 1 A ')-? vS COMMONWEALTH OF PENNSYLVANIA COUNTY OF D A U P 14 1 N / SignatureSign ,a of ?ame being resumbd? _-' ) ss. On the lw day of, ? )005, before me, the Prothonotary or a Notary Public, personally appeared the above a ant kn n to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Prothc,notary or Notary Public DAW)NWHAIM4 OF TNNSYLYANIA Notarial Seal Patricia L. Eismann, Notary Public City of Harrisburg, Dauphin County My Commission Expires Nov. 8, 2067 SALLY A. NARDI, Plaintiff V. DANIEL D. NARDI, Jr., Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYLVANIA NO. 04-6464 CIVIL ACTION - LAW DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in Divorce, filed on December 22, 2004, in the above-captioned case. Respectfully submitted, J l '3 f Cc t-c Heather M. Faust Attorney I D #77947 Killian & Gephart 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Dated: January 26, 2005 t'? ii\ r' ?? CS'l ..,? C_+ `r -f, ???? 1? ? f t ?S? .- 1 ..J '??. _... Philip M. Intrieri & Associates Attorney at Law 615 North 48`" Street Harrisburg, PA 17111-3625 (717)564-6969 Atty. I.D.: 76117 SALLY A. NARDI, Plaintiff VS. DANIEL D. NARDI, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION: DIVORCE NO. 04-6464 PRAECIPE TO ENTER APPEARANCE To: The Honorable, Prothonotary of Cumberland County: Please enter my appearance in the above-captioned matter on behalf of DEFENDANT, Mr. Daniel D. Nardi, Jr. Date V Philip M. Intrieri, Esq. Attorney at Law PMI/sai Attachments : None cc: Heather Faust, Esq. c:o 'h 4 a23 CC Curtis R. Long Prothonotary Office of toe Vrotoonotarp Cumberranb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA RCP230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573