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Home My WebLink About05-4703Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Hamisburg, PA 17110 (717) 232-7200 cubruntApaonl ine.com ROSEANN B. CORDELLI, Plaintiff V. DOUGLAS G. CORDELLI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. (15-- 1-170-? Defendant : 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 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 Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717232-7200 cpbruntApaon I ine.com ROSEANN B. CORDELLI, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. DOUGLAS G. CORDELLI, Defendant NO. J-5- 5"70.3 c4l 7i IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, ROSEANN B. CORDELLI, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce from the above-named Defendant, DOUGLAS G. CORDELLI, upon the grounds hereinafter set forth. COUNTI DIVORCE 1. Plaintiff is ROSEANN B. CORDELLI, an adult individual, who currently resides at 3923 Ridgeland Boulevard, Mechanicsburg, PA 17050. 2. Defendant is DOUGLAS G. CORDELLI, an adult individual, who currently resides at 1515 Orrs Bridge Road, Apt. 2A, Enola, PA 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 20, 1984, in Harrisburg, Dauphin County, Pennsylvania. parties. There have been no prior actions of divorce or for annulment between the The Plaintiff and Defendant are both citizens of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States or any of its allies. 8. The Plaintiff has been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the marriage is irretrievably broken. 10. Plaintiff requests the Court to enter a Decree in Divorce. COUNT II 11. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated by reference as though fully set forth hereinafter. 12. Plaintiff and Defendant have individually or jointly acquired real and personal property during the marriage, in which they individually or jointly have a legal or equitable interest, which marital property is subject to equitable distribution. 13. Plaintiff requests the Court to determine and equitably distribute, divide or assign said marital property, pursuant to Section 3502 of the Divorce Code. WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce as follows: (a•) dissolving the marriage between the parties; (b.) equitably distributing, dividing or assigning the marital property of the parties; and (c•) granting such other further relief as the Court deems appropriate. Respectfully submitted, CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. DATED: 9.Dl? B. COR'TEL1 I, Plaintiff n C r -} i lG' 1 P\} L:? vi .y -ni Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 cpbruntppaonl ine.com ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW NO. 05-4703 CIVIL DOUGLAS G. CORDELLI, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, DAWN S. SUNDAY, ESQUIRE, attorney for the Defendant, DOUGLAS G. CORDELL], in the above-captioned divorce action, hereby accept service of the Complaint in Divorce filed on September 9, 2005, and certify that I am authorized to do so. Date: ?L,p?M-bdf /.at d'W5 DAWN S. SUNDAY, ESQUIRE 39 W. Main Street Mechanicsburg, PA 17055 (717) 766-9622 Attorney for Defendant ? ? r-? O c? v .? ?_, ?? -a y.. i- . tP ? T Lt. ?, .7 ?-. V?? ? ? ' r? Un ? ? . ??? ?a ? ? _ . ? ..- tt l ` ? . ? C?J ` ? J; ? ?) ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. DOUGLAS G. CORDELLI, Defendant By PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Constance P. Brunt on behalf of Plaintiff in the above- captioned matter. Constance P. Brunt 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Please enter the appearance of Debra Denison Cantor and McNees Wallace & Nurick LLC on behalf of the Plaintiff in the above-captioned action. CIVIL ACTION - LAW NO. 05-4703 CIVIL IN DIVORCE 40,- I-AA4- McNEES WALLACE & NURICK LLC By i. eni Cantor e.No. . 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Dated: January4 , 2006 c7 ?- =r c -?,? ->? _, ?-.? ? ??r ? 1 s9 ; ?,? 1.. { ?? C3 ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 05-4703 CIVIL DOUGLAS G. CORDELLI, IN DIVORCE Defendant PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff, Roseann B. Cordelli, by and through her counsel, McNees Wallace & Nurick LLC, and requests special relief as follows: 1. The parties hereto are Husband and Wife, having been married on October 20, 1984. 2. The parties separated on February 7, 2003, when Husband moved from the marital home. Since that date, Wife has solely resided in and controlled the marital home. 3. The parties are the parents of three minor children, namely Dante Cordelli, date of birth: April 14, 1988; Nina Marie Cordelli, date of birth: May 9, 1990; and Mario Michael Cordelli, date of birth: September 12, 1994. 4. Since the parties' separation, Wife has served as the primary physical custodian of the minor children. Husband has had rights of partial custody as the parties agree. This partial custody has not included overnight visitations. 5. Dante Cordelli is scheduled to graduate from Cumberland Valley High School on June 9, 2006. 6 On May 24, 2006, wife advised Husband that she intended to have a graduation party for her family and friends on June 10, 2006. She encouraged Husband to plan a separate celebratory event. 7 Since the Christmas holiday after separation, they have celebrated all holidays, family events, and birthdays separately with the exception of two religious ceremonies. 8 On May 24, 2006, Husband inferred that it was his intention to attend the graduation party with his family. He further inferred that because his name appeared on the deed of the home, there was nothing that Wife could do to prevent his appearance. 9 This is a significant event in Dante Cordelli's life and Husband's presence therein will cause significant disruption and likely lead to police intervention. 10 It is believed, and therefore averred, that Husband is not considering Dante's best interests. 11 Given that Wife has had sole possession of the home since February 7, 2003, it is inappropriate for Husband to assert his presence, uninvited, at this graduation party. 12 Husband has the ability to celebrate this graduation at a time and place of his own choosing. 13 Husband's counsel, Jeanne Costopoulos, was advised of this issue on May 25, 2006 and given 24 hours to reply prior to the filing of this Petition. WHEREFORE, Petitioner requests this Honorable Court to grant her exclusive possession of the marital home located at 3923 Ridgeland Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17050 from June 8, 2006 through June 13, 2006. McNEES WALLACE & NURICK LLC By b Denis Can r TD. No. 6637 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff, Roseann B. Cordelli Dated: MayA6 , 2006 VERIFICATION Subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities, I hereby certify that the facts set forth in the foregoing document are true and correct to the best of my information and belief. ZRos4WWB. Cordelli Dated: Mayf(O , 2006 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Jeanne B. Costopoulos, Esquire 3803 Old Gettysburg Road Camp Hill, PA 17011 De ra Can r Dated: Maya(, 2006 C7 ? Q Ff - n N - + r 7l co ROSEANN B. CORDELLI, Plaintiff V. DOUGLAS G. CORDELLI, Defendant RECEIVED MAY 3 U 200 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 05-4703 CIVIL IN DIVORCE RULE TO SHOW CAUSE AND NOW, this Z% day of , 2006, a Rule to Show Cause is issued for Husband to show cause as to why the relief requested should not be granted. Rule returnable in five (5) days.,o-f BY THE COURT: C7 n -o fTl 1 N =ri C. 1 ? ? 1 T'1 n to ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW V. NO. 05-4703 CIVIL DOUGLAS G. CORDELLI, : IN DIVORCE Defendant MOTION TO MAKE RULE ABSOLUTE AND NOW, comes Plaintiff, Roseann Cordelli, by and through her counsel, McNees Wallace & Nurick LLC, and moves to make Rule absolute as follows: 1. A Petition for Special Relief in the above-captioned matter was filed on May 26, 2006, requesting exclusive possession of the marital home from June 8, 2006 through June 13, 2006. 2. On June 2, 2006, a Rule to Show Cause was issued for Defendant to show cause as to why relief should not be granted. 3. The Rule to Show Cause was served on Jeanne Costopoulos, counsel for Defendant, by facsimile and first-class mail letter dated June 2, 2006 (copy attached). 4. To date, no responsive pleading has been filed. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting the relief requested. McNEES WALLACE & NURICK LLC By em n Cantor - Uaw I.D. 663 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff, Roseann B. Cordelli Dated: June 8, 2006 AVIV- McNees 0 Wallace & Nurick LLC attorneys at law 0 FILE COPY DEBRA D. CANTOR DIRECT DIAL: (717) 237-5297 E-MAIL ADDRESS: DCANTOR@MWN.COM June 2, 2006 VIA FACSIMILE & FIRST-CLASS MAIL Jeanne B. Costopoulos, Esquire 3803 Old Gettysburg Road Camp Hill, PA 17011 RE: Roseann B. Cordelli v. Douglas G. Cordelli C.C.P. Cumberland Co. No. 05-4703 In Divorce Dear Attorney Costopoulos: Enclosed and served upon you in the above-captioned action please find a Rule to Show Cause. Your attention is appreciated. DDC/jmb Enclosure c: Roseann Cordelli (w/encl.) Sincerely, McNEES WALLACE & NURICK LLC By I?.V De ra . Cantor P.O. Box 1166 - 100 PINE STREET - HARRISBURG, PA 17108-1166 - TEL: 717.232.8000 - FAx: 717.237.5300 - WWW.MWN.COM HAZLETON, PA - LANCASTER, PA - STATE COLLEGE, PA - COLUMBUS, OH - WASHINGTON, DC CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing document was served by first-class mail, postage prepaid, upon the following: Jeanne B. Costopoulos, Esquire 3803 Old Gettysburg Road Camp Hill, PA 17011 D .Cant Dated: June 8, 2006 t7 - - ?, Ti _ Q = T 11 ?C7 ? _ •r RECEIVED JUN 9 ? 20 G ROSEANN B. CORDELLI, Plaintiff V. DOUGLAS G. CORDELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 05-4703 CIVIL IN DIVORCE ORDER AND NOW, this Cl* day of June, 2006, upon consideration of Plaintiffs Petition for Special Relief, the Petition for Special Relief is hereby GRANTED; Plaintiff shall maintain exclusive possession of the marital home at 3923 Ridgeland Boulevard, Mechanicsburg, Cumberland County, Pennsylvania, 17050, from June 8, 2006 through June 13, 2006. BY THE COURT: J. A '? b10 ,,.:-? i 1 `r t ` ` ??l?a '????n? Wit.,' . !, ,1,? t?,?? u ..V MARIA P. COGNETTI & ASSOCIATES JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorneys for Defendant ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. DOUGLAS G. CORDELLI, Defendant : NO. 05-4703 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Jeanne B. Costopoulos, Esquire, verify that Defendant's Answers to Plaintiffs First Set of Interrogatories to Defendant and Defendant's Answers to Requests for Production of Documents were served upon Plaintiffs counsel of record date via hand delivery on this date. I verify that the statements made herein are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. MARIA P. COGNETTI & ASSOCIATES By: JEANNE B. COSTOPOULOS, ESQUIRE PA Supreme Court I.D. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Defendant Date: November 17, 2006 ROSEANN B. CORDELLI, Plaintiff V. DOUGLAS G. CORDELLI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 05-4703 CIVIL TERM CIVIL ACTION -LAW DIVORCE PETITION FOR APPOINTMENT OF DIVORCE MASTER AND NOW comes the Defendant, Douglas G. Cordelli, by and through his attorney, Jeanne B. Costopoulos, Esquire, and moves this Honorable Court to appoint a master with the respect to the following claims: Equitable Distribution In support of this motion, Defendant states; 1. Discovery is complete as to the claims for which the appointment of a master is requested. 2. The Plaintiff has appeared in the action represented by Debra Denison Cantor, Esquire. 3. The statutory grounds for the divorce are 3301(c) and/or 3301(d) of the Divorce Code. 4. The action is contested with respect to the following claims: (a) Equitable Distribution of property 5. This action does not involve complex issues of law or fact; and 6. The hearing is ,xpeeLed co take oric (1 Y. . r" Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES By: JE NE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 i elephone No. 17? 7) 909-41060 Attorney for Douglas G. Cordelli, Defendant Dated: tell • ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE VERIFICATION I, Douglas G. Cordelli, Defendant in the above-captioned case, hereby swear and affirm that the statements contained in the foregoing Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein and are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. DATED: ?? ? ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the Petition to the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid, and addressed as follows: Debra Denison Cantor, Esquire McNEES, WALLACE & NURICK, LL C. 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 MARIA P. COGNETTI & ASSOCIATES By: JEANNE B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Douglas G. Cordelli, Defendant Dated: .wo DEC S 12006 eY ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE ORDER APPOINTING DIVORCE MASTER AND NOW, this i9L"k day of '2006, upon consideration of the attached Petition for Appointment of Divorce Master, it is hereby Ordered and Directed that e. &d aj-'eb , Esquire, is appointed master with respect to the following claims: 4J, ,) BY CO Cn 1*n4 1% J. a r ? ? .- C- cv LLJ I-CD N ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05 - 4703 CIVIL DOUGLAS G. CORDELLI, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 104 day of 2007, the economic claims raised in the proceed'ngs having been resolved in accordance with a marital settlement agreement dated June 27, 2007, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY 2TCOURT, W j Edgar B. Bayley, P.J. cc: Debra A. Denison Cantor Attorney for Plaintiff Jeanne B. Costopoulos \ G Attorney for Defendant 7 / ??? LO - PSJ CV Q ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 9, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date: b Signature&kos1qZB_ Corde i t? ? ? ?_ ? °? G? "j?t 4;)??. tA... ? .-? e - -.j t?' ?? ?. ', _.?.` __ ? ?C`y > i tit Y ` ?u ? . .?7 ROSEANN B. CORDELLI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: 62 Signature: Rose B. Cordelli y?+? s h ?? y. s ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 9, 2005. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: ?? ll Signature: Do as G. Cordelli C> rya ? ?? ? ?1,, " ' i ;? ? " -ry T ? .f'l ....._ j '- _ ? wi5'?i ?..,.3 Jvi?t 1 ^? ?{? ? ? _?1 ? t ? a-+ . ?} ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 05-4703 CIVIL TERM DOUGLAS G. CORDELLI, CIVIL ACTION -LAW Defendant DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to Dated: ?? a7 Signature: C? ? ?? ?., ? ? ? -? ? ? '.?a r"? _ ?'[': `?' C`;, .r'p •./ 9 i .; ?? `? r?. V, . A McNEES WALLACE & NURICK LLC BY: Debra Denison Cantor Attorney I . D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5297 (717) 237-5300 facsimile dcantor(cD-mwn.com ROSEANN B. CORDELLI, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. 05-4703 CIVIL DOUGLAS G. CORDELLI, IN DIVORCE 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: 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on Dawn S. Sunday, Counsel for Defendant on September 9, 2005. An Affidavit of Service was filed on September 12, 2005. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff: June 27, 2007; by Defendant: June 27, 2007. Plaintiffs . 49L Affidavit was filed on July 10, 2007. Defendant's Affidavit was filed on July 10, 2007. 4. Related claims pending: N/A 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: July 10, 2007. Date Defendant's Waiver of Notice was filed with the Prothonotary: July 10, 2007. MCNEES WALLACE & NURICK LLC By te k 0, - P ebra D. Cantor I.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff, Roseann B. Cordelli Date: July 23, 2007 1. . 4 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing Praecipe to Transmit was served by first-class mail upon the following: Jeanne B. Costopoulos, Esquire The Ahrens Law Firm, P.C. 52 Gettysburg Pike Mechanicsburg, PA 17055 c 6ujvn? e nifer L. Ke , Paralegal Dated: July 23, 2007 {"V ?a _.? --.? -•-? ;_, ?> "-<. _" S. e? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROSEANN B CORDELLI, Plaintiff I I No. 2005 4703 VERSUS DOUGLAS G. CORDELLI, Defendant DECREE IN DIVORCE AND NOW, v-.1 IT IS ORDERED AND DECREED THAT ROSEANN B. CORDELLI , PLAINTIFF, AND DOUGLAS G. CORDELLI 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; BY THE COURT: PROTHONOTARY q?" a' ?t ° 2 "rte <o? l 3 .? - '_