HomeMy WebLinkAbout05-6373Dominic E. Rattenni, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05->? CIVIL TERM
Linda M. Rattenni, : CIVIL ACTION - LAW
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 will proceed without you and a decree in divorce or annulment may 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 Prothonotari at the First Floor, Cumberland County
Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, PA 17013
(717) 249-3166
Dominic E. Rattenni, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05- (u ^?? CIVIL TERM
Linda M. Rattenni, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Dominic Rattenni, an adult individual, currently residing at 22 W.
Baltimore Street, 3`d Floor, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Linda M. Rattenni, an adult individual, currently residing at
193 North Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing
of this complaint.
4. Plaintiff and Defendant were married on March 11, 2002 in Cumberland
County, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the
parties.
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the
right to request that the Court require the parties to participate in counseling. Knowing
this, the Plaintiff does not desire that the Court require the parties to participate in
counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since October 2, 2005 and
continue to live separate and apart as of the date of this Complaint.
10. The parties' marriage is irretrievably broken.
11. Plaintiff desires a divorce based upon the belief that Defendant will, after
ninety days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce.
COUNT II
EQUITABLE DISTRIBUTION
12. Paragraphs 1 through 11 are incorporated herein by reference as if set
forth in their full text.
13. Plaintiff and Defendant are joint owners of various items of personal
property, furniture and household furnishings acquired during their marriage, which are
subject to equitable distribution.
14. Plaintiff and Defendant have incurred debts and obligations during their
marriage, which are subject to equitable distribution.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree
equitably dividing the parties' property and equitably apportioning the debts incurred by
the parties.
Respectfully Submitted
TURO LAW OFFICES
Date
'Galen R. Waltz, Efqui
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I understand that false statements herein made are subject to the penalties of
Pa.C.S. §4904 relating to unsworn falsification to authorities.
Date Dominic E. Rattenni
Dominic E. Rattenni, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 05- CIVIL TERM
Linda M. Rattenni, : CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of
the Complaint in Divorce, by depositing same in the United States Mail, first class,
certified return receipt, postage pre-paid on the / f'day of Jae. le? , 2005,
from Carlisle, Pennsylvania, addressed as follows:
Linda Rattenni
193 North Locust Point Road
Mechanicsburg, PA 17050
TURO LAW OFFICES
GiIen R. Waltz, Esquire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688; FAX 717.245.2165
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Curtis R. Long
Prothonotary
®ffice- of the i3rotbonotarp
Cumbprlanb QCountp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
OS - („3 7,3 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