HomeMy WebLinkAbout06-0895COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney For Plaintiff
ROBERT ANTHONY SALVIANO, III
Plaintiff,
VS.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 06 g`I S CIVIL TERM
IN DIVORCE and CUSTODY
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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 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 LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, TO GET LEGAL HELP SHOULD
CONTACT:
Cumberland County Lawyer Referral Service
2 Liberty Avenue, Carlisle, Pennsylvania
1-(800)-990-9108
Date: 13 F,56 06
2
COYN %/IC07?
_ _-
C y
By:
L Marie Coyne, quire
901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa.. Supreme Ct. No. 53788
Attorney for Plaintiff
COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney For Plaintiff
ROBERT ANTHONY SALVIANO, III
Plaintiff,
VS.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. DC- X95 CIVIL TERM
IN DIVORCE and CUSTODY
COMPLAINT IN DIVORCE AND CUSTODY
NOW COMES the Plaintiff, ROBERT ANTHONY SALVIANO, III, by his attorney, Lisa
Marie Coyne of Coyne & Coyne, P.C. and files this Complaint In Divorce and Custody avers the
following in support thereof.
The Plaintiff ROBERT ANTHONY SALVIANO, III is an adult individual residing at
6 Hickory Court, Boiling Springs, Cumberland County, Pennsylvania 17007.
2. The Defendant AMY LYNN SALVIANO is an adult individual residing at 18 Circle
Drive, Pine Grove, Schuylkill County, Pennsylvania.
3. The Plaintiff and Defendant are sui juris and have been bona fide residents in the
Commonwealth for at least six months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on April 10, 2004, at Boiling Springs,
Cumberland County, Pennsylvania.
5. The Defendant is not a member of the Armed Services of the United States or any of its
Allies.
6. A prior action for divorce was filed at Cumberland County No. 05-2739 by the Plaintiff
but was withdrawn.
3
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. Further, Plaintiff waives
his right to request that the parties participate in marriage counseling.
9. The marriage is irretrievably broken.
10. After ninety (90) days have elapsed from the date of the filing and service of this
complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant
may also file such an affidavit.
11. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have
lived separate and apart for at least two (2) years.
WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have
elapsed from the filing of this Complaint, or alternatively if the appropriate time has elapsed since date of
separation, Plaintiff respectfully request the Court enter a Decree in Divorce, pursuant to Section 3301(c)
or Section 3301(d) of the Divorce Code, as may be appropriate.
COUNT L• EQUITABLE DISTRIBUTION
15. The prior paragraphs of this Complaint are incorporated by reference.
16. Plaintiff and Defendant have acquired property, and debt during their marriage.
17. Plaintiff and Defendant have been unable to agree as to the equitable division of said
property and debt.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property
and debt pursuant to the Divorce Code.
4
COUNT II: CUSTODY
18. Paragraphs 1 though 17 are incorporated herein.
19. Plaintiff seeks custody of the minor child, Kaleigh M. Salviano, born December
23, 2004 who currently resides at 18 Circle Drive, Pine Grove, Pennsylvania.
20. The child was born during wedlock.
21. The child is presently in the custody of the Defendant, Amy Lynn Salviano.
22. During the child's lifetime the child has resided with the following persons and at
the following addresses:
Amy Lynn Salviano (Mother), 18 Circle Drive November 24, 2005 to Present
Dirk Musselman and Carol Pine Grove, PA 17963
Musselman (maternal
grandmother and step-
grandfather), and Steve
Unspach (Mother's brother)
Robert A. Salvaino & Amy 18 Circle Drive September 2005 to November
Lynn Salviano (Father and Pine Grove, PA 17963 24, 2005
Mother), Camden Wayne
Salviano (Brother), Dirk
Musselman and Carol
Musselman (maternal
grandmother and step-
grandfather), and Steve
Unspach (Mother's brother)
Robert A. Salviano & Amy 529 Shepherd Street Birth to September 2005
Lynn Salviano (Father and Jonestown, PA 17038
Mother) and Camden Wayne
Salviano (Brother).
5
23. The relationship of Plaintiff to the child is that of natural father.
24. The relationship of Defendant to the child is that of natural mother.
25. Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
26. Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
27. Plaintiff does not know of a person not a parry to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
28. The Plaintiff/Father seeks shared legal and physical custody of his daughter as it
is in his daughter's best interest to have maximum contact and quality time with each parent.
29. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, the Plaintiff, ROBERT ANTHONY SALVIANO, III, respectfully
requests this Court to grant shared legal and physical custody of the child to the Plaintiff and
Defendant.
Respectfully submitted:
COYNE & COYNE, P.C.
13 Fe 6 2oo6
Li a Marie Coyne, Esquir
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. S. Ct. No. 53788
Attorney for Plaintiff
6
VERIFICATION
I, ROBERT ANTHONY SALVIANO, III, certify that the statements made in the
foregoing are true and correct to the best of my knowledge, information and belief and this
verification is subject to penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to
authorities,
Dated: ' O
ROBERT ANTHONY SALVIANO, III
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ROBERT ANTHONY SALVIANO, BI
PLAINTIFF
V.
AMY LYNN SALVIANO
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
06-895 CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Tuesday, February 21, 2006 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. the conciliator,
at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, March 14, 2006 at 8:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ Dawn S. Sunda , sq.
Custody Conciliator I1?
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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, Pennsylvania 17013
Telephone (717) 249-3166
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ROBERT ANTHONY SALVIANO, II
Plaintiff,
VS.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-895 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, LISA MARIE COYNE, ESQUIRE, of Coyne & Coyne, P.C. hereby certify that I have, on the
below date, caused a true and correct copy of the attached Divorce Complaint to be served upon the
person named below by way of certified first class mail, restricted delivery, postage prepaid, return
receipt requested.
Ms. Amy L. Salviano
18 Circle Drive
Pine Grove, PA 17963
Date
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Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
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COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
ROBERT ANTHONY SALVIANO, III
Plaintiff,
Vs.
Attorney For Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 06-895 CIVIL TERM
AMY LYNN SALVIANO,
Defendant. : IN DIVORCE and CUSTODY
PRAECIPE TO WITHDRAW CUSTODY COUNT
TO THE PROTHONOTARY:
By agreement of Counsel, Plaintiff hereby withdraws, without prejudice, his custody count in
this matter.
COYNE & COYNE, PC
Date: -/ 3 - d By
4LISAk4AREE COYNE, squire
et Street
Camp Hill, PA 17011-4227
(717) 737-0464
Pa. Supreme Court No. 53788
Attorney for Plaintiff
10,
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the
foregoing Praecipe was served this date upon the below-referenced individual at the below listed address
by way of first class mail, postage pre-paid:
Jeffrey Philip Paul, Esquire
Attorney at Law
505 West Market Street
Pottsville, Pa 17901
Dawn S. Sunday, Esquire (Custody Conciliator)
Sunday & Sunday
39 West Market Street
Mechanicsburg, PA 17055
Dated: 3 -1 3 -v 6 +?? ?
Lisa M
Attorn a ie Coyne, Esquire
for Plaintiff
2
3
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LIAR2.,R?m
ROBERT ANTHONY SALVIANO, III
Plaintiff
vs.
AMY LYNN SALVIANO
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
06-895
CIVIL ACTION LAW
IN CUSTODY
ORDER
AND NOW, this 27`h day of March, 2006 , the conciliator, being advised by
plaintiff's counsel that plaintiff has filed Praecipe to Withdraw Custody Count, hereby relinquishes
jurisdiction.
FOR THE COURT,
Dawn S. Sunday, Esquire
Custody Conciliator
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ROBERT ANTHONY SALVIANO, H
Plaintiff,
VS.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 06-895 CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE
TO: Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after May 30, 2008, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
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
LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800) 990-9108
ROBERT ANTHONY SALVIANO, H
Plaintiff,
vs.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-895 CIVIL TERM
IN DIVORCE
COUNTER-AFFIDAVIT UNDER & 3301(d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a 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. Check either (a) or (b):
(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 of Intention to Request Divorce Decree, the divorce decree
may be entered without further notice to me, and I shall be unable thereafter to file any economic
claims.
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 18 Pa.C.S. § 4904,
relating to unworn falsification to authorities.
Date:
Amy Lynn Salviano (DEFENDANT)
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you should not file this counter-affidavit.
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, of Coyne & Coyne, P.C. hereby certify that I have, on the below date,
caused a true and correct copy of the attached Notice of intention to Request Entry of Divorce Decree
and Counter-Affidavit to be served upon the person named below by way of first class mail, postage
prepaid:
Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
Date q 8
C. P.C.
By:
Marie Coyne, Esq.
Attorney for Plaintiff
3901 Market Street
Camp Hill, PA 17011-4227
MrT-,
ROBERT ANTHONY SALVIANO, H
Plaintiff,
VS.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-895 CIVIL TERM
: IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a counter-
affidavit within twenty days after this affidavit has been served on you or the statements will be
admitted.
PLAINTIFF'S AFFIDAVIT UNDER Section 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on November 23, 2005 and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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. Cons. Stat. Ann. § 4904 relating to
unworn falsification to authorities.
Dated:
?'?'
Ro Anthon Salvi aintiff
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, of Coyne & Coyne, P.C. hereby certify that I have, on the below date,
caused a true and correct copy of the attached Plaintiff's Affidavit Under Section 3301(d) of the Divorce
Code to be served upon the person named below by way of first class mail, postage prepaid:
Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
Date AAW
& C PANE, P.C.
By: ?
Li 'e Coyne, Esq.
A ey for Plaintiff
3901 Market Street
Camp Hill, PA 17011-4227
0 j ?n>
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ROBERT ANTHONY SALVIANO, H
Plaintiff,
vs.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 06-895 CIVIL TERM
IN DIVORCE
PREACIPE TO WITHDRAW COUNT FOR EQUITABLE DISTRIBUTION
To the Prothonotary:
Plaintiff hereby withdraws Count I (Equitable Distribution) from the Divorce Complaint
filed by Plaintiff.
COYNE & COYNE, P.C.
Dated: ore By:
f vi T
Va/Marie Coyne, Esq.
Supreme Ct. No. 5348
901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, of Coyne & Coyne, P.C. hereby certify that I have, on the below date,
caused a true and correct copy of the attached Praecipe to Withdraw Count For Equitable Distribution to
be served upon the person named below by way of first class mail, postage prepaid:
Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
Date A-? C 9'P
COYNE & COYNE, P.C.
By: At"- W-1
Li arie Coyne, Es
ttorney for Plaintiff
3901 Market Street
Camp Hill, PA 170114227
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t,
COYNE & COYNE, P.C.
Lisa Marie Coyne, Esquire
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 17011-4227
(717) 737-0464
ROBERT ANTHONY SALVIANO, H
Plaintiff,
VS.
AMY LYNN SALVIANO,
Defendant.
Attorney for Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-895 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(d) of the Divorce
Code.
2. Date and manner of service of the complaint: Certified Mail, Restricted Delivery on
February 22, 2006.
3. Date of execution of the affidavit of consent required by Section 3301(d) of the Divorce
Code: May 8, 2008, by plaintiff.
4. Related claims pending: NONE
5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached: May 9, 2008, First Class Mail
6. No Counter-Affidavit has been filed by the Defendant.
Date: 5- 30 -- d r
COYNE & COYNE, P.C.
By: 4
L a Marie Coyne, EY5788
. rem
Supe Ct. No. 3901 Market Street
Camp Hill, PA 170114227
(717) 737-0464
Attorney for Plaintiff
COYNE & COYNE
A PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
Henry F. Coyne
Lisa Marie Coyne
3901 Market Street
Camp Hill, Pennsylvania
17011-4227
717-737-0464
Fax: 717-737-5161
May 9, 2008
Mrs. Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
Re: Salviano v. Salviano
Dear Mrs. Salvanio:
Enclosed please find copies of the following documents:
1. Praecipe to Withdraw Equitable Distribution Count in Divorce;
2. Notice and Plaintiff's Affidavit to Consent to Divorce Under Section 3301(d);
3. Notice of Intention to Request Entry of Divorce Decree; and
4. Defendant's Counter-Affidavit Under Section 3301(d) of the Divorce Code.
Very truly yours,
COYNE & COYNE, P.C.
?T,i a Marie Coyne
LMC/amd
Enclosure
Cc: Tony Salviano, w/encl.
t Z
1 d? `?
ROBERT ANTHONY SALVIANO, II
Plaintiff,
vs.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS 0 ° ?n
CUMBERLAND COUNTY, PENNSYLi&
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NO. 06-895 CIVIL TERM
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IN DIVORCE ? ? j c
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NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE
TO: Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
You have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after May 30, 2008, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
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
LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800) 990-9108
any
ROBERT ANTHONY SALVIANO, H
Plaintiff,
vs.
AMY LYNN SALVIANO,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-895 CIVIL TERM
IN DIVORCE
COUNTER-AFFIDAVIT UNDER 3301(d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) - I do not oppose the entry of a 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. Check either (a) or (b):
(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 of Intention to Request Divorce Decree, the divorce decree
may be entered without further notice to me, and I shall be unable thereafter to file any economic
claims.
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 18 Pa.C,S. § 4904,
relating to unsworn falsification to authorities.
Date:
Amy Lynn Salviano (DEFENDANT)
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you should not file this counter-affidavit.
39 y
CERTIFICATE OF SERVICE
I, Lisa Marie Coyne, of Coyne & Coyne, P.C. hereby certify that I have, on the below date,
caused a true and correct copy of the attached Notice of Intention to Request Entry of Divorce Decree
and Counter-Affidavit to be served upon the person named below by way of first class mail, postage
prepaid:
Amy Lynn Salviano
18 Circle Drive
Pine Grove, PA 17963
Date 197 e°rr 6 COYNE & CO , P.C.
By:
L a Marie Coyne, Esq.
Attorney for Plaintiff
3901 Market Street
Camp Hill, PA 17011-4227
vy y
CERTIFICATE OF SERVICE
I, LISA MARIE COYNE, ESQUIRE, of Coyne & Coyne, P.C. hereby certify that I have, on the
below date, caused a true and correct copy of the attached Praecipe to Transmit Record to be served upon
the person named below by way of certified first class mail, restricted delivery, postage prepaid, return
receipt requested.
Ms. Amy L. Salviano
18 Circle Drive
Pine Grove, PA 17963
Date d?
By:
ISA MARIE CO
Pa. Supreme Ct. No. 53788
3901 Market Street
Camp Hill, PA 170114227
(717) 737-0464
Attorney for Plaintiff
-zi
CD
C' J
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
ira
STATE OF PENNA.
ROBERT ANTHONY SALVIANO, II,
Plaintiff NO. 06-895 CIVIL TERM
VERSUS
AMY LYNN SALVIANO,
Defendant
DECREE IN
DIVORCE
AND NOW,
-' I\ e, 3
, IVA, IT IS ORDERED AND
DECREED THAT ROBERT ANTHONY SALVIANO, II
AND AMY LYNN SALVIANO
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,DEFENDANT,
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;
NONE.
BY THE COURT:
PROTHONOTARY
Q'-°'
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
ROBERT ANTHONY SALVIANO, III
II
Plaintiff
NO. 06-895 CIVIL TERM
VERSUS
AMY LYNN SALVIANO,
Defendant
CORRECTED
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
73?v T1t , 'Loot, IT IS ORDERED AND
ROBERT ANTHONY SALVIANO, III
AND AMY LYNN SALVIANO
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,DEFENDANT,
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;
NONE.
BY THE COURT:
?h ... ,- q ? I
ATTEST: J.
- (3t?m-
PROTHONOTARY