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