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HomeMy WebLinkAbout05-3675HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF ROBERT E. NASTELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2005 -3G 75'CIVIL TERM GLORIA J. NASTELLI, Defendant : IN DIVORCE NOTICE 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 ROBERT E. NASTELLI, Plaintiff V. GLORIA J. NASTELLI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005 - fix CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is ROBERT E. NASTELLI, an adult individual whose mailing address is 400 Mt. Rock Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is GLORIA J. NASTELLI, an adult individual residing at 201 Meals Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have not been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce, but plaintiff believes and therefore avers that both parties will waive jurisdiction. 4. The parties were married on October 8, 1970 in Hagerstown, Maryland. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. July 20, 2005 Q",/ (?' `/ ma"??-M ROBERT E. NASTELLI, Plaintiff HAROLD S. IRWIN, II Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 C7 ? <, U't y 1 G `. - v t" ROBERT E. NASTELLI, Plaintiff V. GLORIA J. NASTELLI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2005 - 3675 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on July 21, 2005, by certified mail addressed to the defendant at 201 Meals Road, Carlisle, Pennsylvania 17013, certified mail No. 7003 3110 0004 5775 4740. 3. A copy of the sender's and return receipts are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. August1,2005 Harold S. Irwin, III Attorney for plaint 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 Postal C3 r CERTIFIED RECEIPT r` r (Domestic In r OFFI CIAL USE Lr) r POMP $ Go Mdi t ?c 1 p CedeedFw 3p pp Relum RBdW Fee (ErdO. nt Required) 75 Postmark Here (Endoraeme Required) 3.so 70 rO? ? ? I M Tote) Posts & Fees ,$ ? ?s M C3 ° ro G (oq---_7, N n--- _-- v mPOBoxNa D 1 . .............. _ --------------------- M e.e (,f Q V?LA ........ ..................... ¦ Oanplets Rena 1, 2. and 3. Also oonlPlerte Rem 4 R ResUWW DslhwY Is desired- is pdm your name end address on the reverse so that we can retum the card to you. ¦ Attach this oerd to the beck of the malipleoe; or on the front R apace permits. 1. AftM Addressed to.' law's.. j1 , N -ZL 1 rr2ol weals 90AS CILr1?I511!1 PA 1 70 '3 ®/Recalveu oY (nmmrnv 1-1. , Nook IWE F -it- D. is d*jery address dR ertt flan eem 1? ''- R yM mytsr deWery address below' 0 No 3. Service 1VP9 0 Osrt1W Mail 17 Exproea Melt 0 RegWeded 0 Reaum Recelptfor Merchandise 2. AredaNurn 7003 3110 0004 5775 4740 (Rensar horn eervke eased) tozses Domestic Return Receipt rYt-M-hsid PS Form 3811, February 2004 EXHIBIT VV .." -wr u? r 22LL 4 Curtis R. Long Prothonotary ®ff f ce of the Protbonotarp Cutnberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 0.5- .3L 7S 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 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