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Home My WebLink About05-2915 . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JEANETTE F. SGRIGNOLl Plaintiff * NO. 05' ;;'iI~ 4'd * * vs. * CIVIL ACTION. LAW IN DIVORCE * * DOUGLAS M. SGRIGNOLl Defendant * * 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 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 AT THE CUMBERLAND COUNTY COURTHOUSE, 1 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 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 .. ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JEANETTE F. SGRIGNOLl, Plaintiff * NO. tJ:/- ;2.9/S ~ -r~ * * vs. * CIVIL ACTION - LAW IN DIVORCE * * DOUGLAS M. SGRIGNOLI, Defendant * * COMPLAINT COUNT I - DIVORCE UNDER !l3301(c) or !l3301(d) OF THE DIVORCE CODE 1, The Plaintiff is Jeanette F. Sgrignoli, who currently resides at 318 Pitt Street, Enola, Pennsylvania, 17025, 2, The Defendant is Douglas M, Sgrignoli, who currently resides at 519 North Market Street, Duncannon, PA 17020. 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, Plaintiff and Defendant were married on May 15,2004 in Enola, Pennsylvania. 5, The parties are not parents of any children, 6, There have been no prior actions of divorce or for annulment between the parties, 7, Neither party is presently a member of the Armed Forces on active duty, 8, The parties have not entered into a written agreement as to alimony, counsel fees, costs, or property division, 9, Plaintiff has been advised that counseling is available and that she may have the right to request that the court require the parties to participate in counseling, Being so advised, '-' . o. Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued. 10. The cause of action and sections of the Divorce Code under which Plaintiff is proceeding are: (a) ~3301 (c). The marriage of the parties is irretrievably broken; and (8) ~3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time, Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. 11. Plaintiff requests This Honorable Court enter a Decree of Divorce. WHEREFORE, Plaintiff respectfully requests This Honorable Court enter an Order dissolving the marriage between Plaintiff and Defendant. Dated: ~Jrr ~ Tomas M. Clark, Esquire 130 West Church Street Dillsburg, PA 17019 (717) 432-9666 J.D. # 85211 VERI FICA liON I, Jeanette F. Sgrignoli, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. CS. ~904, relating to unsworn falsification to authorities. Date: -lUlU--- ~; {J(}5 /.,\ 1. ~ ~ f ~ '- ~ ~ " -.1::. ~ ~ w "-.J ~ ~ f , ~ '-. Y\ ~, ~ '^ \ ~C) '~ ~~ l ~ o ~ c ~ ::::::',. L c: :z: I -.I !9l 3! m::t! "hi :0 c;J 06 i!"i " o':n :::: C') bM is' ~ N :~ -.J -Q. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA JEANETTE F. SGRlGNOLI, Plaintiff * * * NO. 05-2915 CIVIL v. * CIVIL ACTION - LAW IN DIVORCE * DOUGLAS M. SGRIGNOLI, Defendant * * * ~Ist On the J.. day of RETURN OF SERVICE :Tent' ,2005, I, Lisa Barneycastle, served DOUGLAS M. SGRIGNOLI, Plaintiff's Complaint for Divorce by ~o.nc1\)d lvc-J 9th.+ rt16\",lltt S~vtLt \-\O.((I)~. PA JiL.m. (time of service). (manner of service) , at 11 <J5 at I verifY that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. !;4904 relating to unsworn falsification to authorities. Date: rx"l ~ll1)S \.). I .L. lA.A-W r-tM...0 LISA A. BARNEYCA TLE ...., = = cJ' ,.- S f" w C) -n -' ~:n " " -or',; 7}~ - ,..' () :__)rn :-A ~D .< f" .r:- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA JEANETTE F. SGRlGNOLI, Plaintiff / Petitioner * NO. 05-2915 Civil Term * vs. * * CIVIL ACTION - LAW IN DIVORCE * * DOUGLAS M. SGRlGNOLI, Defendant / Respondent * * PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE AND NOW, this ~ day of December, 2005, comes the Petitioner, Jeanette F. Sgrignoli, Plaintiff, in the above-captioned divorce action, by and through her attorney, Thomas M. Clark, Esquire, of Wiley, Lenox, Colgan & Marzzacco, P.c., and files the instant petition seeking exclusive possession of the marital residence, respectfully averring as follows: I, Plaintiff and Defendant were married on May 15, 2004, 2. Since their marriage, the parties have resided together at 318 Pitt Street, Enola, Cumberland County, Pennsylvania. 3, The residence situate at 318 Pitt Street was purchased as a pre-marital property by the plaintiff in December 1998, prior to the Defendant and Plaintiff having ever met. 4, The parties have no children together. 5. In May 2005, Defendant removed himself from the residence and has only returned one time in June 2005. 6. The Defendant entered the property in June 2005 by forcible entry to retrieve an item belonging to the Plaintiff consisting of pre-marital property of a dog. 7, Plaintiff continues to reside therein. 8. On June 7, 2005, Petitioner filed a Complaint in Divorce at the above-captioned docket. 9. Defendant is self-employed and has secured his own housing. 10. Defendant currently resides at 519 North Market Street, Duncannon, Pennsylvania 17020 and has since May 2005. 1 L Plaintiffrespectfully submits that circumstances which arose prior to May 2005, made it impossible for Plaintiff and Defendant to continue to reside in the same home together. 12. Plaintiff is paying the mortgage as well as all the bills for the residence situated at 318 Pitt Street, Enola, WHEREFORE, Petitioner respectfully requests This Honorable Court award exclusive possession of the marital residence to her. Respectfully su mitted, W~(EY, LEN X, COLGAN & MARZZACCO, P.c. ! i , I \ X" ~ /'-.. Thomas M. Clark, Esquire 130 West Church Street Dillsburg, PA 17019 (717) 432-9666 LD,# Dated: VERIFICA TION I, Jeanette F. Sgrignoli, verifY that the statements made in this document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, '4904, relating to unsworn falsification to authorities. Date: !.::)- 5 -OS- '\ rfJ-T- . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JEANETTE F. SGRlGNOLI, Plaintiff * * NO. 05-2915 CIVIL TERM * vs. * CIVIL ACTION - LAW IN DIVORCE DOUGLAS M. SGRlGNOLI, Defendant * * * * CERTIFICATE OF SERVICE I, Thomas M, Clark, Esquire hereby certifY that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class, postage prepaid, as follows: Date: fij1v ~ Douglas M, Sgrignoli 519 North Market Street Duncannon, P A 17020 /~P 7~ 7' -"- . Thomas M, Clark, Esquire By: .----- .., ("', " ,,' " , - - . JEANETTE F. SGRIGNOLI, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW DOUGLAS M. SGRIGNOLI, Defendant NO. 05-2915 CIVIL TERM ORDER OF COURT AND NOW, this 16th day of December, 2005, upon consideration of Plaintiffs Petition for Exclusive Possession of the Marital Residence , a hearing is scheduled for Thursday, February 16, 2006, at 3:15 p.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania. Thomas M. Clark, Esq. vY.J{J West Church Street Dillsburg, P A 17019 Attorney for Plaintiff ~uglas M. Sgrignoli 519 North Market Street Duncannon, P A 17020 Defendant, pro se :rc BY THE COURT, J. 1 Vit',i';1/.:"i ~ <;f,:r,q[~ M{,!';,,' . ,. . ':';~~:":n:J Sf: :8 fH 91 ::J30 saoz krljD:\\}{:.C!'~Jd jHl :10 3~!3:i(}CFllH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA JEANETTE F. SGRIGNOLI, Plaintiff / Petitioner * NO. 05-2915 Civil Term * * vs. * * * * * CIVIL ACTION - LAW IN DIVORCE DOUGLAS M. SGRIGNOLl, Defendant / Respondent MOTION TO WITHDRAW PETITION FOR EXCLUSIVE POSSESSION OF THE MARITAL RESIDENCE AND NOW, this 20th day of December, 2005, comes the Petitioner, Jeanette F. Sgrignoli, Plaintiff, in the above-captioned divorce action, by and through her attorney, Thomas M. Clark, Esquire, of Wiley, Lenox, Colgan & Marzzacco, P.c., and files the instant Motion to Withdraw Petition for Exclusive Possession of the Marital Residence, respectfully averring as follows: I. On June 7, 2005, Petitioner filed a divorce complaint in the above-captioned matter. 2, On June 21, 2005, Defendant was served with the said divorce complaint 3. On June 23, 2005, said service was filed with the Cumberland County Office of the Prothonotary. 4, On September 19, 2005, Petitioner mailed an Affidavit of Consent and Waiver of Notice to Defendant. S. On December 6,2005, Petitioner filed a Petition for Exclusive Possession of the Marital Residence. 6. On December 13, 2005, Defendant signed the Affidavit of Consent and Waiver of Notice, Please see Exhibit "A" attached hereto and incorporated herein as if fully set forth. 7. On December 16,2005, This Honorable Court scheduled a hearing to detennine the merits of the case relative to the Petition for Exclusive Possession of the Marital Residence. WHEREFORE, Petitioners respectfully request that Your Honorable Court withdraw the Petition for Exclusive Possession. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.c. Dated: r7 - '20 - o~ ~?--- Thomas M. Clark, Esquire 130 West Church Street Dillsburg, PA 17019 (717) 432-9666 J.D. # "i!l,al/ Attorney for Petitioner EXHIBIT "A" JEANETTE F. SGRIGNOLI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 05-2915 CIVIL DOUGLAS M. SGRlGNOLl Defendant CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under !;3301(c) of the Divorce Code was filed on June 21, 2005, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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 made herein are subject to the penalties of 18 Pa. c.s. 94904 relating to unsworn falsification to authorities, /:J-/3 -aS Date f).fI' ~~2> Douglas M:Sgrig Ii ~ Defendant JEANETTE F. SGRIGNOLI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 05-2915 CIVIL DOUGLAS M. SGRlGNOLI Defendant CIVIL ACTION -- DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if] do not claim them before a divorce is granted. 3, 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn falsification to authorities. / Ii- - / ?:1 -oS- Date ~~ f)1^ .... Douglas Nf. Sgri oli -< . Defendant --.". VERIFICA TION I, Jeanette F. Sgrignoli, verify that the statements made in this document are true and correct to the best of my knowledge, information, and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. '4904, relating to unsworn falsification to authorities. Date: /()/ fiO!1J> , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA JEANETTE F. SGRlGNOLI, Plaintiff * NO. 05-2915 CIVIL TERM vs. * * * CIVIL ACTION - LAW IN DIVORCE * * DOUGLAS M. SGRlGNOLI, Defendant * * CERTIFICATE OF SERVICE I, Thomas M, Clark, Esquire hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicatt:d below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States mail, first-class, postage prepaid, as follows: Douglas M. Sgrignoli 5 I 9 North Market Street Duncannon, P A 17020 Date: n. - '2. Co> - 0\ By: 9J{,~ Thomas M, Clark, Esquire (') (,-;, ,-.> c> e.;;) <;;'..1"1 c? t-':"'I n ~" ;:". -r, ::, ~ .-1 L:J] rnf.-. --11 :.,JW-t "y ;:.:~~~ I'-\l ,",() :':':"\1'1 , '.:-::\ '~i:J '< ~ JEANETTE F. SGRlGNOLI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 05-2915 CIVIL DOUGLAS M. SGRIGNOLl Defendant CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT I. A complaint in Divorce under !;3301 (c) of the Divorce Code was filed on June 21, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint 3. I consent to the entry of a 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 made herein are subject to the penalties of 18 Pa. C.S, !;4904 relating to unsworn falsification to authorities, {f! - fI- OS- Date rt!ulit ll~f~ Janette F. Sgrignoli Plaintiff --------- (") c ;:.~ ~, = r::;;-..;; en o Pi n N o ., -{ ::r:_~ rn..-e.; r- -om ?-;y :-~C) "f"'--'- " -"; . 'i:-) ;.")rn & -< .." 'I? q JEANETTE F. SGRIGNOLI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 05-2915 CIVIL DOUGLAS M. SGRIGNOLI Defendant CIVIL ACTION -- DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2, 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. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. s4904 relating to unsworn falsification to authorities. Of-/9 -():; Date ~. '\ L 1,j-;~ . nette F. Sgrignoli N P aintiff C) ~~ =-~ ---:;.. w o "'-.' = ,"';:c:, ''-'" D r'7 c-; f'" o "fl 'i! i"q::JJ r- -nn"~ :ilC': ,OJ f .~~} ~:-:: .-,,;' C"') ::.jrl: .?:::! ::.0 '" JEANETTE F. SGRIGNOLI IN THE counT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 05-2915 CIVIL DOUGLAS M. SGRIGNOLI Defendant CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT I, A complaint in Divorce under 9330 I (c) of the Divorce Code was filed on June 21, 2005, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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 made herein are subject to the penalties of 18 Pa, C.S. 94904 relating to unsworn falsification to authorities, I d - Jl;> 0"::> Date f).(f1 ,~2 -57 > Douglas IVY.S!~k Defendant C) <::: ,. I ...., "'CO> c:;;:,. c." CJ M Cl 1',) o .,., ::;:! fn::rJ r- :9{!} i) '0....1 ,'-,\ I ~j~; ~:,i~S _-~) rfl ~ :0 -< '.' :J,i; w Q JEANETTE F. SGRIGNOLI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTV, PENNSYL VANIA Plaintiff VS. No. 05-2915 CIVIL DOUGLAS M. SGRIGNOLI Defendant CIVIL ACTION -- DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I, [consent to the entry of a final decree of divorce without notice, 2. 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. 3. J 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. I verify that the statements made in this affidavit are true and '~orrect. I understand that false statements made herein are subject to the penalties of J 8 Pa, c.s, !}4904 relating to unsworn falsification to authorities. /}-/ 7-) -0",' bate f)fl\ ~Q ~g -.. Douglas M:' S!~~i . Defendant C) ....., 0 C~ ~~= c..,~:3 -n "" I 0 .-1 'T rq _',,.-n " nIp N -pm -,'10 <':_) 1" MtC~" .....-f'. -1',1 ';':}.z~ I. :r' c..> 0 .< JEANETTE F. SGRlGNOLI, IN THE counT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. NO. 05-2915 CIVIL TERM DOUGLAS M. SGRIGNOLI, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter intends to resume and hereafter use the previous name of Patricia L. Smith and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. Section 704(a) as amended which permits a party in a divorce action at any time prior to or subsequent to the entry ofthe divorce decree to resume any prior SUlrname used by that person. Date: / :-x i J I /- , ! Jff)') I I I ~/l ,J, '1 ;,iV-. .' ~ '(p~M~ Jtanette F. Sgrignoli " ,~ TO BE KNOWN AS: - " -, '; ...-/ ',.' " /' "/,' /' -," ~,'.- -:1 II. ,I ',,! { , ,I " 7, I J ,;,'" \ /L^'- I ,---,/' " " i '~"l . . " . Jeanette F. Smith COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ : SS On this, the ~ay of flf (' () (rt iJJ.A) , 2005, before me, the undersigned officer, personally appeared Jeanette F. Sgrignoli, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she ,executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seaL MY COMMISSION EXPIRES: $'~//fl tt0:0~) NOTARY BLI I COMMONWE~~::ENNSYLVANIJ'A S. Dawn Gladfelter, Notary Public Dillsburg BolO, Yolk Colx1ty My Commission Expires May 17, 2009 Member, PennsylvanIa AnDclltlon of Not.,lit. I) () o{g. r[ ~ (') ....' \l "-'" 0 ~ s = -n - <:.n \",- CI :2-n --1 r<1 - c-> f'l'? ~ ~ -.:J f" -0 CD ~.s:(Q \~:::;(:) ""v r -0 -r' -r, ...() ::J;: ~:jB ~ 1- f..f? ~?rl1 ::;;~ ::0 $7 '-< DEe .2 1 2005 r--/ fAl IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA JEANETTE F. SGRIGNOLI, Plaintiff / Petitioner * NO. 05-2915 Civil Term * * vs. * CIVIL ACTION - LAW IN DIVORCE DOUGLAS M. SGRlGNOLI, Defendant / Respondent * * * * ORDER Upon review ofthe Motion to Withdraw Petition for Exclusive Possession of the Marital Residence, it is hereby ORDERED AND DECREED that the Motion is GRANTED. The Petition for Exclusive Possession of the Martial Residence is hereby WITHDRAWN, therefore canceling the hearing scheduled before this Honorable Court on February 16,2006 at 3:15 p.m. BY THE COURT: DISTRIBUTION: e "d" ~k~ u utl n 1R1Rwtratef } Thomas M, Clark, Esquire, 130 West Church Street, Dillsburg, PA 17019 Douglas M. Sgrignoli, 519 North Market Street, Duncannon, P A 17020 /) - Jf l1S /i C'~UJ ./Y1/~,L n/> TEd l'J1 :f.)1 8- "-0 "^"Z (.0:.!l Jut! At1\/lCr"\)i-:;J.C:~~d 3Hl :10 38jj:~C)-n::JlH JEANETTE F. SGRIGNOLI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. NO. 05-2915 CIVIL TERM DOUGLAS M. SGRlGNOLI, Defendant CIVIL ACTION - LAW IN DIVORCE AMENDED NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter intends to resume and hereafter use the previous name of Jeanette F. Smith and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. Section 704(a) as amended which penn its a party in a divorce action at any time prior to or subsequent to the entry of the divorce decree to resume any prior surname used by that person. Date: I~! ~l {os- 1t.l1fi 7,J. nette F. Sgrignoli TO BE KNOWN AS: . uift-.y ~1'1/ .' .,J COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~ On this, the ~l'Ji!Iday of il1 tvnb-M ,2005, before me, the undersigned officer, personally appeared Jeanette F. SgrignoIi, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. SS IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~~~AL/~~ NOTARY PU LIC MY COMMISSION EXPIRES: eAl.TH OF PENN NolaJ1aI Seal S, Dawn Gladfelter. /IIo1iuy Public llIIoIug Boro. YOlk COU1Iy ~OllI..,.......Elqlinl8May 17. 2009 .....,,'~~.t.._.. '""r ._~ -- -~ No 24 415 014 DUpsnt , ' 008 0111611978 Se" F ' , CGlasS: C Eyes: HJ>>: f,t:ndorSe: __ Height s'd ~GOri'l/Med Rstr: <</1 Issued. 111-15/2001 8<P"es: 01/17/2006 . ORGAN DONOR ~'f.#7 Jl,A t.fEl"1'..ji P sMI'. 'fHa:"""""': ~n,8'p,1'\'T S;fRt;;ET .,,' ~ '. Et.f0LA PA 17'0:25 '. . --..--------.------------.------.---.----.-.------- JI-_ Homecoming~ Financial (NOT A PAYMENT ADDRESS) P.O. Box 890036 Dallas TX 75389 #BWNFNYZ #ZRZQWZZRZW4# + OOObbS~ 000006292 D9HfT2 Pla Jeanette F Smith 318 Pitt St Enola P A 17025-2231 1",111",111,,,,,1,1,1,1,,,1,1,,1,1,,11,,,,11,,,111,,1,1,,1,1 CURRENT ACCOUNT DETAILS Mortgage Amount(s) Due Principal Interest 87.00 206.96 MORrGAGE ACCOUNT SUMMARY Payment Due Date: Statement Date: Acr.ount Information as of 10103/05 Current Principal Balance * Year to Date Interest Interest Rate: 10/18/05 10/03/05 27.625.75 1.893.19 8.990% 'RIOR PERIOD ACTIVlry Activity from 09/02/05 to 10103/05 09/21/05 09/18/05 Payment: 86.31 principal. 207.65 lnterest 09/21/05 Additional Principal Payment 293.96 6.04 :he Cunent Principal Balance does not reflect the total amount required to pay your loan in full Homecomings Financial A GMAC Company www.homecomlngs.com CUSTOMER INFORMATION Borrower: Jeanette F Smith 318 Pitt Street Enola P A 17025 717 732 9094 7177806530 Property Address: Home Phone #: Work Phone #1: Please use the form on the back afthe coupon to update this infonnation. /111I111I1111I11111 ,. ""1'.IIIIIIlI..,,rl"'.iT""lr.'ItI;.j.I]'III"~"'IIl..1I1 ............,..r.- r-' c".-.:.\ ~5~t c.::-' r-n ("") ", >.SJ (~) ~~, .-4 -:c:~ f-n~ -"tD ~:'.\ ~i'< '-j,(? -rJ ~~.\',~i\ :~~ -77 ?r.J :'~ -- 'i'~:: r-.' tJ'i ... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JEANETTE F. SGRIGNOLl, Plaintiff * NO. 05-2915 CIVIL * * v. * CIVIL ACTION - LAW IN DIVORCE * * DOUGLAS M. SGRIGNOLl, Defendant * * PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Grounds for Divorce: Irretrievable breakdown under Section 330 1 (c). 2. Date and manner of service of the Complaint: The Defendant was served on June 21. 2005. the Return of Service was filed with this Honorable Court on June 23. 2005. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: September 19.2005; By Defendant: December 13, 2005. (b) (1) Date of execution of the Affidavit required by Section 330I(d) of the Divorce Code: N/A (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: N/A. 4, Related claims pending: There are no related claims pendin2. . 5, Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in Section 330I(c) Divorce wasfiled with the Prothonotary: December 21. 2005; Date Defendant's Waiver of Notice in Section 330 I (c) Divorce was filed with the Prothonotary: December 21, 2005. Date: ~j~ 1. ~ I By: o %<7--- Thomas M. Clark, Esquire Supreme Court l.D, #8521 I 130 West Church Street, Suite 100 Dillsburg, PA 17019 (717) 432-9666 (Attorney for Plaintiff) ~::;;', o-=:. C.. -:A --1 -;:: ;n ,- f'-~ CJ JEANETTE F, SGRIGNOLI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DOUGLAS M. SGRIGNOLI, Defendant NO. 05-2915 CIVIL TERM ORDER OF COURT AND NOW, this 25tl1 day of January, 2006, upon consideration of Plaintiffs Praecipe To Transmit Record, and it appearing that Plaintiffs atlidavit of consent was filed more than 30 days after its execution and is thus stale, a divorce decree will not be entered at this time, without prejudice to the parties' rights to correct the deficiency and tile a new praecipe to transmit record. See Pa. R.C. P. 1920A2(b)(2). BY THE COURT, /, " ~omas M. Clark, Esq. 130 West Church Street Suite 100 Dillsburg, P A 17019 Attorney for Plaintiff :rc J. ; c~ \,; D \.p ~,~ o " ;_! " !. ~, ~ , G ",1.-:::--, JEANETTE F. SGRIGNOLI IN THE COURT OF' COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff vs. No. 05-2915 CIVIL DOUGLAS M. SGRIGNOLI Defendant CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT I. A complaint in Divorce under !;3301(c) of the Divorce Code was filed on June 21, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a 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 made herein are subject to the penalties of 18 Pa. C,S. !;4904 relating to unsworn falsification to authorities. I hl'7/ D~ Date' I ~ " ;th:;, y. ~ anette F, SgrignOli~ Plaintiff g r ~~:, ~,- /_ l." ~"c .cC :4~(.:' -.('"' ~c~ z -? -- ~ = o~ <.- ~ (.0) C> ~ '$ '-P. Q. %:n -om :ne;:; '~~t z~,",\ ex --\ '"'i;)o' ~ - - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . + . + . . . + . + . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+'~ ~ '" '" ""+. '+: '+':+.:+: . . . ;f.;f. Of. :+. '" .. . . '+: :f. :f. :+.:+.+.~ "" +. :f. ""'+: ++.~+.++ +. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, JEANETTE F. SGRIGNOLl, Plaintiff VERSUS No. 05-2915 CIVIL DOUGLAS M. SGRIGNOLl, Defendant AND NOW, DECREED THAT DECREE IN DIVORCE ff' ~ r'\.l <.' 'l fL JEANETTE F. SGRIGNOLl , ZCCt-" IT IS ORDERED AND , PLAINTIFF, AND DOUGLAS M. SGRIGNOLl , 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; :t''f+'+'+:+::f.:f. . J. +. +. +++. +. +.+ '+'++'+' "" '+' +. +. . + +. Of 'I' '+' '+';+: Of '" '" +. 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