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Home My WebLink About05-5969 . G,/1- \ (k\L <; ,tll.- \.(\\ PLAINTIFF, ) ) ) ) IN THE COURT OF COMMON PLEAS COUNTY, PENNSYLVANIA DEFENDANT ) CIVIL DIVISION ) ) ) NO. 05- 5"&;'0 f ) tad v. !VI l'vhtull p ~u,lvn NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 MAYBE 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 CHILD(REN), WHEN THE GROUND FOR THE DIVORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARIAGE. YOU MAY REQUEST MARRIAGE COUNSELING, A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT , PENNSYL VANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY. LA WYERS 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, LAWYERS REFERRAL SERVICE Telephone: ( For Petitioner Address: Telephone: ( lwl.\ f/-,e'\I\ S'{~\.\A\\ PLAINTIFF, V. ( IN THE COURT OF COMMON PLEAS OF ( ( COUNTY, PENNSYLVANIA ( ( CIVIL DIVISION iNO: ()S'-H'I..<i C;U,{I~ _~l\,~\ P ScrlvO DEFENDANT, COMPLAINT IN DIVOR~E AND NOW COMES. the Petitioner. t.,..., ,t,.\\... k\",\, who files lhis Complainl in Divorce statement of which is as follow: , by FILING PRO SE. L . and adult individual currently residing . fA 17"7 '. -r ,!~ , '-,. The Pelilioner is ~, at 2. . and adull individual currently residing 1'" VIt HCj 3, The Pelitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at leasl six (6) months previous to the filing oflhis Complaint 4. The Pelitioner and Respondenl were married on dale: of fY\A . (P/d-..,ltc,Go . in lhe Slale 5, There (is)...... 6-;w e~u....\r..._ ilc.\,,\~ , child(Nnj born of this marriage. Name(s)_ Birthdale(s): \ - X} -t,')... 6, Neilher party is a member of any branch of mililary, 7, The marriage is irretrievable broken. 8. The Petilioner. -l ,~../, r..\'h &.\\,\~ , respeclfully requesls lhis Honorable Court 10 a granl this Divorce pursuant 10 Seclion 3301 (c), or in the al1ernative, Section 3301 (d) of the Divorce Code Name: Full Address: ~ E"rt Or-c.""".f y. h;,~ ~"" th lilt'1 Telephone Number;;': ~ - :z.'1'\1. I verifY lhal the statemenls made in the Complainl are true and correct. I understand that false statemenls made herein are subjecl to penalties of 18 Pa, C.S,A. Section 4904. relating to unsworn falsification to aulhorities. Dated \ \_ \l_\-C'~ DL \,_.1)" \..'-~ x-~ ) \~b(} ~L. T:::) ,.~" "". ,,1,j,,: \' '..",,'! ">!l,{':::Jj~.,' y\ ~ ,~. l.A ~ . \ ~.. '\ ~ "^ <::0-, ~ \::-" '" -, l' \.i "- ~~ -- ,~ ---J It.; CJ ~ ....... ~ "- \:'.) '{" ~ ~ t ~ 'lJ ....J ~ ~ ~ ".::. ") ,\ 0 _._~-_.------- r--:> c' ~..,. ;;:;.;.-:) <.J" C) r-n ::::\ ,. ~ -1"; -<,',~ _J -I;' r:? c-.:) -J - LORI BETH SALUTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LA W DIVORCE MICHAEL P. SALUTI, Defendant NO, 05 - 5969 - CIVIL TERM PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Lori Beth Saluti, the Plaintiff, in the above captioned matter. Date: March 2 L 2006 cS~~~ X ~L~'\; Sarah L. Rubright Certified Legal Intern '.. J '- ( , 7".1,,' , I~)' i. IF / l \. / ,,'. '--..;......0[ \ L'ucy JOMstOllWalsh, Esq. Supervising Attorney /" -' '~< ,',. , FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 .' Cl (~ ~l C;T~ - ~"... -.i;~ :Sa N ~,... C) -n --I ~~~, -:.1'-( .}~f' "1 ~:<~ -;)h~ ~~ (:~~ o C"- LORI BETH SALUTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE MICHAEL P. SALUTI, Defendant NO. 05 - 5969 - CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: Please reinstate the Divorce Complaint at the above-captioned docket. '-/ - q OL, Date: . \ Q~h rA.. Q~-;rv Sarah L. Rubright Certified Legal Intern J ~. tJcj(( on-Walsh, Esq. ng Attorney G~ ~J -, ~; " LORI BETH SALUTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE MICHAEL P. SALUTI, Defendant NO. 05 - 5969 - CIVIL TERM AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I. The parties to this action separated in October 1993 and have continued to live separate and apart for a period of at least two years. 2. The marriage of Plaintiff and Defendant is irretrievably broken. 3. 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. 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. 94904, relating to unsworn falsification to authorities. Date ~'-':',:)0 -l.JI....f> . '\' \.~. ~. ; . '~..' \........ . ~ , ,.,.. '-'-- - Y-L\'\. _ _ / 2lJ;. ",-. Lori Beth Saluti, Plaintiff ce--' -'--'.-' ".f) LORI BETH SALUTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE MICHAEL P. SALUTI, Defendant NO. 05 - 5969 - CIVIL TERM CERTIFICATE OF SERVICE I, Sarah Rubright, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy ofthe Divorce Complaint on Michael P. Saluti, residing at 13 Crestwood Lane, Dennisport, Massachusetts by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Michael P. Saluti, on the 11 th day of April 2006 as evidenced by the attached green card. cf~h "'- /2v-~ -~ ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 (717) 243-2968 Fax: (717) 243-3639 a. Complete aems 1, 2, and 3. Also complete aem 4 n Res1'icled Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Yf) /cJ1aOt ~ClI u.:i:.J . I s G--v-r;:t;LubO/L L~ Ovl-fUr'..w pcrdl fYl-A D d.& 31 3. Service Type ;:Iii Certtfl1ld Mali 0 Express Mail o Registered ;:Sf Return Receipt for Merchandise o Insured Mall 0 C.O,D, 4. Restricted Delivery? jExtra Fee) ~ 2. Article Number (Transfer from service 7005 0390 0003 2632 36~u PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 :, "'1 '\ . LORI BETH SALUTI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE MICHAEL P. SALUTI, Defendant : NO. 05-5969 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER ~3301(d) OF THE DIVORCE CODE l. Check either (a) or (b): (,,/(a) I do not oppose the entry ofa divorce decree. ( ) (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ( ) (i) The parties to this action have not lived separate and apart for a period of at least two years. ( ) (ii) The marriage is not irretrievably broken. 2. ~eck either (a) or (b): r-/ (a) I do not wish to make any claims for economic relief. 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. () (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice ofIntention to Request Divorce Decree, the divorce decree may be entered without further delay. . I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of l8 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date t; (ZZ/t, ~ ------- o ~; ~;:;... --- ~ ~~ 0' P" C.: G') - J:" ::s ....,.. Q, r:-? ~~ \11 r=: "", . :gy ~~~. ~~~ :~~)-~j ~.~~ (")' .. '::-\ -.... ~ <:::' C - LORI BETH SALUTI, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA v. MICHAEL P. SALUTl, Defendant : CIVIL ACTION - LAW : DIVORCE : NO: 05-5969 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF 9 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 9 3301 (d) affidavit. Therefore, on or after June 26, 2006, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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. IF YOU CANNOT AFFORD 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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. o ~~ "'C"\:' 1"')' ~ <'-'" cr> "'~ C' G-) ~~, : ".s::"'. - };- """ - .... "'';L ':/" --) ~. q, ~:Q ';:;: -("l~-~ ~~.\~~), 1.._-0 -<::'t"'S ~r"(i S ~ r:-? o o '. ... LORI BETH SALUTI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-5969 CIVIL TERM MICHAEL P. SALUTI, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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. Ground for divorce: irretrievable breakdown and separation for two years under S 330l(d) of the Divorce Code. 2. Date and manner of service of the reinstated complaint: service was completed on the 11th day of April, 2006 by the United States mail, certified, return receipt requested, restricted delivery, postage prepaid. 3. Date of execution of the affidavit required by S 330l(d) of the Divorce Code: March 30, 2006; Date of filing and service of the plaintiffs affidavit upon the respondent: Filed on April 4, 2006 and served April 11, 2006. 4. Related claims pending: None. 5. Date and manner of service of the Notice ofIntention to Request Entry of Divorce Decree, a copy of which is attached: Service by first class mail on June 22, 2006. Date D .//4-/ Db h~ III Hammill Certified Legal Intern . ~,/!. _,,"c' -.,._.....". . I i ""I. . I"Y;,<"'/ , i .,-,._--~ Robert . airls, Esquire Lucy Johnston-Walsh, Esquire Anne MacDonald-Fox, Esquire Thomas M. Place, Esquire Megan Malone, Esquire Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 (') ~: ,...., (~ ~ :P" c.:-: t...:-) ..,." -0 --'- o -n -I J::-n fl1~ -nu_). .J...., J )... ~,?i"..,,) :"-1, --i.-_ -;, ::.,:;(') "',-C:: \"\1 :::::~\ ;:;; :...:; ~ o o IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY PENNA. STATE OF NO. 5969 2005 LORI-RRTH SALlITT. Plaintiff VERSUS MTC'HARL SALnTT, Defendant . . . AND NOW, . DECREE IN DIVORCE /2.p..",1" I/" ,,.tIo' ,IT IS ORDERED AND I T,(),RT_RR/"flH C::ATTTrrT , PLAINTIFF, DECREED THAT AND MT('lHART c::,arTl"flT , 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; . . . . N()NF. J. PROTHONOTARY _ ..r# ~ /'P ..", ~ ")0- u - ~ -7'" ,~~ -1"9 'Ifl-U-J ..,1~ . .. . <<:-' ~,~ 'lo .'