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HomeMy WebLinkAbout05-3893 Donald T. Kissinger, Esquire Howett, Kissinger, Conley & Holst, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234,2616 Counsel for Plaintiff Rene A. Magaro IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ) ) ) ) ) ) ) NO. 2005- ?> li 9.3 CIVIL TERM RENE A. MAGARO, Plaintiff RICHARD D. MAGARO, Defendant CIVIL ACTION - LAW IN 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, Cumberland County Courthouse, I Courthouse Square, 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 LA WYER 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, PA 17013 Telephone: (717).249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RENE A. MAGARO, Plaintiff v. ) ) ) ) ) ) ) NO. 2005- 3 H.J CIVIL TERM RICHARD D. MAGARO, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Rene A. Magaro, by and through her counsel, Howett, Kissinger, Conley & Holst, P.c., who states the following in support of the within Complaint: I. Plaintiff is Rene A. Magaro, an adult individual who currently resides at 1000 Highfield Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Richard D. Magaro, an adult individual who currently resides at 116 East Allen Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents in the Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on May 25, 1991 in Mechanicsburg, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States of its allies within the provisions of the Servicemembers Civil Relief Act. 6. There have been no prior actions for divorce or annulment of the marriage instituted by either of the parties in this or any other jurisdiction. 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. The marriage of the parties is irretrievably broken. 9. The parties have lived separate and apart since on or about November 15, 2004. 10. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, ----- to- Date: 7 ~ )"7-" () S Donald T. Kissinger, Esqui e Howett, Kissinger, Conley & Holst, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Rene A. Magaro VERIFICATION I, Rene A. Magaro hereby swear and affirm that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 7~J.7'"o5 ft//'/IfY-<< ~ A~ . Rene A. Magaro . ~ t"_~:l l:i!l (;,,-' Co;;) ~ ...-" ~ ~ 1\ '-\ '"" "" l:- e w ("' '" .. --:::: 0 .., -S:;> - """'" <"> 0 'e r . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ) ) ) ) ) ) ) NO. 2005-3893 CIVIL TERM RENE A. MAGARO, Plaintiff RICHARD D. MAGARO, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE 0.1<' SERVICE I, Richard D. Magaro, Defendant in the above-captioned divorce action, hereby accept service of the Complaint in Divorce. Date: 4. ---5/ JIXJ\" Cj.A.C 2:; c.~_., c..r-\ U -11 :~ ill .- ~:.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. ) ) ) ) ) ) ) NO. 2005-3893 CIVIL TERM RENE A. MAGARO, Plaintiff RICHARD D. MAGARO, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT I. A complaint in divorce under S33OJ(c) of the Divorce Code was filed on July 29, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 tmderstand 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn falsification to authorities. ~ C Date: ov 1 JDOS ~. . '. \J . I RicH d D. Magaro, Defen ( ! .'n r:-: ().) c;, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA RENE A. MAGARO, Plaintiff v. ) ) ) ) ) ) ) NO. 2005-3893 CIVIL TERM RICHARD D. MAGARO, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT l. A complaint in divorce under S3301(c) of the Divorce Code was filed on July 29, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER li330I(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 in 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 above are true and correct. I understand that false statements herein are made subject to the penalties of] 8 Pa.C.S. S4904 relating to unsworn falsification to authorities. Date: ..:::J-/2-(j~ ~ ~ /J;/ J. ;,- /;/ -4 ~/~./ .-r;/:..c..'r"<../<y/- Rene A. Magaro, Plai ff '"'~ ,~ .,:.' ~~;~ ,) -'n --l ..,.. r':'1 -q r,-, l,:() ! CO ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~+~~~~.~+~+~~~~+++~+~~~~~++~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~+++~+++~+~+++~+~~~ IN THE COURT OF COMMON PLEAS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++~~++~+~~++++++++++++~ OF CUMBERLAND COUNTY STATE OF RENE A. MAGARO, Plaintiff VERSUS RICHARD D. MAGARO, Defendant AND NOW, DECREED THAT AND PENNA. No. 2005-3893 CIVIL TERM DECREE IN DIVORCE f~ JI/-'11A~ · ,;~ 2006 , IT IS ORDERED AND RENE A. MAGARO , PLAINTIFF, RICHARD D. MAGARO , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None. ATTEST: J. ++ ++++++ + ++~++~~ ~++++++~+~++ - ~ '2? ~>J:/ ~/L, fe/'- Le. r? ~~ /w ;? ~j4' :t4V n "Irl. if ~ , , . . ." .,. , "': IN THE COURT OF CO:MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1)/1,,' ~.I1!r:Jt{/'a Plaintiff Vs f/rAatd D I111Q~q/,o efendant File No. J.OO5- 3e:l3 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or -.L after the entry of a Final Decree in Divorce dated /0-/ ()-o (; hereby elects to resume the prior surname of 4/1'///. )cu'JI L , and gives this written notice avowing his I her intention pursuant to the provisions of 54 Date: /0 fM 0 Lu'~/ ~~ "Signature of~e being resumed COMMONWEALTH OF P~NNSXLV ANIA ) COUNTYOF ~ On the J at/.. day of (J ~ , 200 ~ before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and aclmowledged that he I she executed the foregoing for the purpose therein contained. 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