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Home My WebLink About05-2739 ROBERT ANTHONY SALVIANO, II Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO.t0S' -.:l. 72/1 CIVIL TERM AMY LYNN SALVIANO, Defendant. : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defen4 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 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 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 HA VE A LAWYER OR CANNOT AFFORD ONE, TO GET LEGAL HELP SHOULD CONTACT: Cumberland County Lawyer Referral Service 2 Liberty Avenue, Carlisle, Pennsylvania 1-(800)-990-9108 COYNE & COYNE, P.c. Austin F. Grogan squ 3901 Market Street Camp Hill, PA 170t -21227 (717) 737-0464 Pa.. Supreme Ct. No.59020 Attol'/ley for Plaintiff # ROBERT ANTHONY SALVIANO, II Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. OS - .;1,:739 CIVIL TERM AMY LYNN SALVIANO, Defendant. : IN DIVORCE COMPLAINT IN DIVORCE NOW COMES the Plaintiff, ROBERT ANTHONY SALVIANO, III, by his attorney, Austin F. Grogan, Esquire and files this Complaint In Divorce and avers the following in support thereof: 1. The Plaintiff ROBERT ANTHONY SAL VIANO, III is an adult individual residing at 6 Hickory Run Boiling Springs Cumberland County, Pennsylvania 17007. 2. The Defendant AMY LYNN SALVIANO is an adult individual residing at 529 Sheppard Street, Jonestown, Lebanon County 17038 3. The Plaintiff and Defendant are sui juris and have been bona tide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 10, 2004, at Cumberland Pennsylvania. 5. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 6. There have been no prior actions of divorce or for annulment between the parties. 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. Further, Plaintiff waives his right to request that the parties participate in marriage counseling. 9. The marriage is irretrievably broken. 2 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. II. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, if both parties file affidavits consenint to a divorce after ninety (90) days have elapsed from the fIling of this Complaint, or alternatively if the appropriate time has elapsed since date of separation, Plaintiff respectfully request the Court enter a Decree in Divorce, pursuant to Section 3301(c) or Section 3301(d), as may be appropriate. COUNT II - EOillTABLE DISTRIBUTION 15. The prior paragraphs of this Complaint are incorporated by reference. 16. Plaintiff and Defendant have acquired property, both real and personal, and debt during their marriage. 17. Plaintiff and Defendant have been unable to agree as to the equitable division of said property and debt. WHEREFORE, Plaintiff requests thIS Honorable Court to equitably divide all marital property and debt pursuant to the Divorce Code. Respectfully submitted: COYNE & COYNE, P.C. AUSTIN F. GR GA 3901 Market Street Camp Hill, PA 1701 (717) 737-0464 Pa. S. Ct. No. 59020 Attorney Jar Plaintiff squire Dated: 5,~)'o) By: 3 . . VERIFICATION I, ROBERT ANTHONY SALVlANO, II certify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief and that this verification is subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. / I Date .f;, 1') . J~ 4 ....... ""6<}. t~ ~ ~ --- -- \G ~ I<~ \) C> 0 L'; Cv V( S ^ -- () - 0- ~ D - () ...,.- .. ..t:: ~~ v, t (). u ~ e ~ 1- ~ ~ CG ROBERT ANTHONY SALVIANO, II Plaintiff, vs. AMY LYNN SALVIANO, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-2739 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, AUSTIN F. GROGAN, of Coyne & Coyne, P.C. hereby certify that I have, on the below date, caused a true and correct copy of the attached Divorce Complaint to be served upon the person named below by way of certified first class mail, restricted delivery, postage prepaid, return receipt requested. Date 1.1.1 Ul~ ~!gset 0i,111 ~!~!! a i.-I.Uii i .J; aU, I :~'ifU~ I Mrs. Amy Lynn Salviano 529 Shepherd Street Jonestown, PA 17038 5.1.-1.. J'- J ~ ll. J] IE q l ,Uo . DOg i 1<1 !I ~1 \)0 ... '" - ... ~1;?S:: ~ j~ ~ ~ - ~ ~ -..J ~ -i f~~ <:::i:Vl"""7 ..: , o ~ ~ i ...n ::t" ...n 0 0 ru '" ru '"" j 0 0 0 0 j ...n ru J ru m 0 0 r'- ~ 8::: '" ! -. ... oi By: 1. No. 59020 Austin F. Grogan Pa. Supreme Ct. No. Pa. 3901 Market Street Camp Hill, P A 17011-4227 (717) 737-0464 Attorney for Plaintiff ...n ::t" ...n o o ru m ru U,S. Postal Service"., CERTIFIED MAIL, RECEIPT . (Domestic Mail Only; No Insurance Coverage ProvIded) Postage $ ~,\J~,l ' .s /~'\ 71" r'l o Cl Retum Reclept Fee o (Endorsement Required) CJ Restricted Del!V8lY Fee ...lJ (Endorsement Required) ru ru Total postage & Fees $ '" R ~~_nhnhm1!!o1omoL.!i,'21nhoJ:JI'!L1;!.~n_oo. on ,h m 0 '!:!::!o;;}'tnn.5.~5..o__o5_&tH.4..!d0.ohn:__o:__o:.__:o City, SfBlB,Z11'>4 0/1 W W'<UI ,4 110 J 'Y Certified Fee ~G j;; ~.o S:=;:s :;1 ':'') -u :::r.: ~-'? Ul ~c) ::l:-'-, 07" -?,() (.'S,n ~ :.1) .-< ROBERT ANTHONY SALVIANO, II Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ; NO.~S: c213/] CIVIL TERM AMY LYNN SALVIANO, Defendant. : IN DIVORCE PRAECIPE TO DISMISS SUIT TO THE PROTHONOTARY: Kindly dismiss the above captioned divorce complaint. DATE /' (p .Z-1-o~ a~v..d Austin F. Grogan, Esq Attorney for Plaintiff (') c ~ C:::-' c.>' (...- c:. :,,:.-.- .- 1'-' -' q, _--l ff,~ '- -('1,iJ.--' ;EJ}{.~ ~~: - f:,,? ~2. \?}.