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Home My WebLink About06-0357 McNEES WALLACE & NURICK LLC By: Pamela L. Purdy Attorney ID No. 85783 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile ppurdv@mwn.com Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA GIUSEPPE DIESI, v. NO. Ot., - 357 /) . ( LI\)1 L /UJr, JENNIFER A. DIESI, 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 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 at the Cumberland County, Carlisle, Pennsylvania. 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, PA 17013 (717) 249-3166 or (800) 990-9108 McNEES WALLACE & NURICK LLC By-f~"{,.q Attorneys for Plaintiff Dated: January 17, 2006 - 2 - McNEES WALLACE & NURICK LLC By: Pamela L. Purdy Attorney 10 No. 85783 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile ppurdy@mwn.com Attorneys for Plaintiff GIUSEPPE DIESI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. O~ - .3~7 (}.,;..J... ~ ~ IN DIVORCE v. JENNIFER A. DIESI, Defendant COMPLAINT IN DIVORCE Divorce Under 3301(c) or 3301(d) of the Divorce Code 1. Plaintiff is Giuseppe Diesi, 5780 Nesbit Drive, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is Jennifer A. Diesi, who currently resides at 1437 Apple Circle, #186, Mechanicsburg, Cumberland County, Pennsylvania. 3. Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 7,2000. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The grounds on which the action for divorce is based are: A. Section 3301(c): The marriage of the parties is irretrievably broken. After 90 days have elapsed from the filing of this Complaint, it is believed the parties will file Affidavits of Consent to a divorce. B. Section 3301(d): The marriage of the parties is irretrievably broken. Plaintiff and Defendant separated in June 2005. After June 2007, Plaintiff intends to file an Affidavit alleging that the parties have lived separate and apart for a period of two years and that the marriage is irretrievably broken, and he anticipates that Defendant will not deny that the parties have been separated for a period of at least two years and that the marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives his right to such counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. McNEES WALLACE & NURICK LLC By ~p~; fLy Dated: January 17, 2006 Attorneys for Plaintiff - 2 - VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Dated: l{'~6 D -c<;4 -p - <'\t- oO ~ D . VI - - C>' ...4 ..J::: ;U \).J ~ 'V B ..c: r- --..c::. 'D ~ r - t--.... >., -;1 ( " . ._~ -~ (") 1:1 , C) . ( CJ !,-l 8 "'-;. ,-<,. McNEES WALLACE & NURICK LLC By: Pamela L. Purdy Attorney ID No. 85783 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile DPurdv@mwn.com Attorneys for Plaintiff Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-357 CIVIL TERM GIUSEPPE DIESI, v. JENNIFER A. DIESI, Defendant IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Divorce Complaint in the above matter. '.. ( , ~ ~. \ . k ....- .... .." .,,'. '. ----- (~if~r~.9 SI -------- Dated: I P-'-I(06 t - GIUSEPPE DIESI, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-357 CIVIL TERM v. JENNIFER A. DIESI, Defendant : IN DIVORCE PRAECIPE TO SUBSTITUTE COUNSEL TO THE PROTHONOTARY: Please enter the appearance of Pamela L. Purdy, Esquire for Plaintiff Giuseppe Diesi, and withdraw the appearance of McNees Wallace and Nurick LLC, as counsel for the Plaintiff in the above captioned action. fcl"tE~ 115 Pine Street Harrisburg, PA 17101 (717)221-8303 Attorney 1.0. #85783 J. Pa Helvy ~ Mc es Wall e, 1150 Pine Str et- PO Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorney I.D. #53148 Date: ~ / {l'rJ / ()Li' . Date: )/17)/.1 .' - 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: Jennifer A. Diesi 1437 Apple Circle, #186 Mechanicsburg, PA 17055 Dated: .3 !~(J I M.f? //" q '-- -< r-<) r:~ C:-:j L'.... C) "11 ::::l '~1 :!J r- -ail"'\ ~.." C-) -< ::. .')~} .;;,'-i1 };.,) ~..) \:'1'1 ..--\ ~~;> :.lJ -.; ::!t ):... :-0 N -,., <;.? o ~" GIUSEPPE DIESI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-357 v. JENNIFER A. DIESI, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was tiled on January 18, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the tiling and service of the Complaint. 3. I consent to the entry of a tinal decree of divorce after service of notice of intention to request entry of the decree. 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. S 4904 relating to unswom falsification to authorities. " Dated: u/t L.J J 0 (0 I I f".-..c' ( ~",":' "'.::::' <-;'~.... rn <..- r-;:' -:-1 :r: C0 :r';." i--- '::0 a -< Pamela L. Purdy, Esquire Attorney ID No. 85783 115 Pine Street Suite 100 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff GIUSEPPE DIESI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. JENNIFER A. DIESI, Defendant NO. 06-357 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 18, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 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: 5b'1/~ I ....., C:::::l (-) -;'.] :-:-f '~:;" ~ ,i L~' c: ....... . Pamela L. Purdy, Esquire Attorney ID No. 85783 115 Pine Street Suite 100 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.net Attorney for Plaintiff GIUSEPPE DIESI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-357 IN DIVORCE v. JENNIFER A. DIESI, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 453301 (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. I verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~904 relating to unsworn falsification to authoriti Dated: '-17106 I -2- ,.,,' c:-> . r-~~~~ 1-) ~-1 .~ . i-I'] G.') ." Ci GIUSEPPE DIESI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. JENNIFER A. DIESI, Defendant NO. 06-357 IN DIVORCE WAIVER OF NOnCE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !3301(c) OF TI1E DIVORCE coo.g 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. 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. ~904 relating to unsworn falsification to authorities Dated: (J/tf/ol/ {. I r..,.,' ,.:-:~ W~ Go .'. " -" ''--. .. -. Pamela L. Purdy, Esquire Attorney 10 No. 85783 115 Pine Street Suite 100 Harrisburg, PA 17108 (717) 221-8303 (717) 221-8403 facsimile plpurdy@verizon.het Attorney for Plaintiff GIUSEPPE DIESI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-357 IN DIVORCE v. JENNIFER A. DIESI, 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: Personally served. Affidavit of Acceptance of Service was signed by Defendant on January 24, 2006 and filed of record on March 7, 2006. ~ -. 3. Date of execution of the affidavit of consent required by ~ 3301 (c) of the Divorce Code: by Plaintiff: June 27, 2006; by Defendant: June 14, 2006. 4. Related claims pending: N/A 6. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: contemporaneously with this Praecipe. Date Defendant's Waiver of Notice was filed with the Prothonotary: contemporaneously with this Praecipe. ~/~" amela L. Purdy- Attorney for Plaintiff Giuseppe Diesi Date: July 6, 2006 -2- G.:J ("- .- . --1 :1: ;t; ;t; ;t; ;t; ;t;;t; ;t; ;t; ;t;;t; ;t; ;t;;t; ;t; ;t;;t;;t;;t; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY Giuseppe Diesi PENNA. STATE OF Plaintiff No. 06-357 if. ;t; ;t; ;t; ;t; VERSUS ;t; ;t; ;t; Jennifer A. Diesi ;t; ;t; ;t; Defendant ;t; DECREE IN DIVORCE \~ J \J \'{ , 2.00', IT IS ORDERED AND AND NOW, Giuseppe Diesi DECREED THAT , PLAI NTI FF, Jennifer A. Diesi AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. if. 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; if. ;t; if. ;t; ;t; if. if. if. if. if. if. if. By THG' ~~~\\ ATTEST~~ \ - ---~PROTHONOTARY if.;t; ;t; ;t; ;t; if. if. if. if. if. if. if.if.if.if.if.if. if. if.;t;if.if. if. ;t; if. if. if. ;t; ;t; if. if. if. if. if. if. ;t; ;t; ;t; if. if. ;t; ;t; J. -.h ~ ~~~n-' ~ "'J(/' /;{ ~L ~ P 1!. ~-~ ~ '7t?' bl-t. " ,< . . .. . " . flit .. . .., '.1 " ~.. t