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Home My WebLink About06-1655 SAlOIS, FLOWER & LINDSAY ATIORNEYS+AT'LAW 26 West High Street Carlisle, PA II CARRIE A. MONETA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - LAW NO.QI..-/&,!;!; CIVIL 2006 RAYMOND J. MONETA, Defendant IN DIVORCE NOTICE TO DEFEND 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 the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 SAIDIS, FLOWE /11/, vZ Carol J. Lindsay, Es Attorney Id. 44693/ 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY ATIDRNEYSoAT'IAW 26 West High Street Carlisle, PA Ii II II I, I' I i I , , I , i II II II CARRIE A MONETA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. Of.. -/(.,J--:,' CIVIL 2006 v. RAYMOND J. MONETA, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Carrie A Moneta, an adult individual residing at 1471 Hillcrest Court, Camp Hill, Pennsylvania. 2. The Defendant is Raymond J. Moneta an adult individual residing at 205 Holly Drive, Camp Hill, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents In the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 24, 2002 in Wayne County, Pennsylvania. 5 There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6 The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. SAlOIS, FLOWER & LINDSAY AnORNEY~;.AT.lAW 26 West High Street Carlisle, PA WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with S3301 of the Pennsylvania Divorce Code. Respectfully submitted, Dated: ;3 /7 ,Iv j; SAlOIS, FLOWER & INDSAY If \", C i ft.. ,:' Carol J. Lindsay Attorney Id.A46 3 26 West Hi' treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAllIS, FLOWER & I1NDSAY ATtORNEYS'AT-IAW 26 West High Street Carlisle,PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. , understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904, relating to unsworn falsifications to authorities *- l\ C~v,0- 0 . ~'Vl/l CM..C}-~ Carrie A. Moneta Date: ,) ~ C -0 It \A~\l , 1. - ;:) \-J ~ - ~ _.J,.. t- 7' -D 'h.~ (:'\ :::.(:1 \l 10 ,,) N ( \ -- vt -r:J T~ U ~ <( , ....:..,.~ (J( ~ c.) -& ::-cJ ," p- ~ .-J:::. U t~.J -t- .~t:- ~ SAlOIS, FLOWER & LINDSAY ATTORNEYS.AT-lAW 26 West High Street CarJisk PA CARRIE A MONETA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 06-1655 CIVIL 2006 RAYMOND J. MONETA, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on April 1, 2006, she served a true and correct copy of the Complaint in Divorce upon Raymond J. Moneta, by mailing those documents to the his address at 205 Holly Drive, Camp Hill, Pennsylvania, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt. the latter of which is signed by the recipient, Raymond J. Moneta. Respectfully submitted, AY Dated: 1ftlc!t Carol J. Lindsay, quire 26 West Higt} Stree Carlisle, PA . (717) 243-6222 Counsel for Defendant r SAIDIS, FLOWER & LINDSAY ATIORNEYS.AHAW 26 West High Street Carlisle, PA I I 'I I ! . Complete items 1, 2, and 3. Also complete item 4 if Restricted 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: !io-ymoncL T mO neJQ 80 5 {~ 0 II Y ]~)r ,'( e.. (OJ'!,-? ~ (I I j) A {70 ( I 2. Article Number (Transfer from service label) PS Form 3811 , February 2004 o Agent o Addressee B. aceiv Yj,f!jnted Name) C. ga~ of ~ltvery -eJ j(I;,..,UA- q..{ II o( D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No 3. Service Type Ilf Certified Mall o Registered o Insured Mail o Exp.... Mall o Return Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 7003 2260 0000 8704 3754 Domestic Return Receipt 102595-02-M-1540 : ~.L; - c...--.:: z ~ o c: ,.. i~''J (-'I ...-.~ ""~" -;" .. J f.'..' SAIDIS, FlDWER. & LINDSAY A11~1l~ 26 West High Street Carlisle, PA II CARRIE A. MONETA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1655 CIVIL 2006 IN DIVORCE v. RAYMOND J. MONETA, Defendant DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on March 22, 2006 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date t)f filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge. information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. y~'- Raymond J. eta Date: 1/' /0' DEFENDANT'S WAIVER OF NOTIC~ OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER' 3301 Ie) 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 tnem 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 to the best of my knowledge, information and belief. 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: .::; /, /tJh ~~~~ SEP 0 5 2006 o ~ '-. -00' ~;c- ..r":- "<- (f'.: . =<- ~;::: ~ c;:::;> a'"" (.n r~" __'1 .... "}:: \.> <:::.~, t-, $E :?~ -'. I CO o 11 -'I ::L.-n \11 'F': -(1tr: -:.,C~ ~~1 ~)~ ':~~{~ ~ -c -:'1.... - - (..!1 SAlOIS, FLOWER & LINDSAY .(J"I()IlNE1So/J.\AW 26 West High Street Carlisle, PA CARRIE A. MONETA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 06-1655 CIVIL 2006 RAYMOND J. MONETA, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce Code was filed on March 22, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. C~~ 0. vln~L0 , f\\ \110' Date: . \ \.... .. V' Carrie A. Moneta PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERi 3301 te) 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 to the best of my knowledge, information and belief. 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:~ (Lw Q .V~fr0, Carrie A. Moneta SEP 1 4 2006 1"...) -.... ~;:~ .~ ~:.:~:) -n c;....... ::::! 'lJ 01 Ci ) :c~ Ui ~D 0 -< ~ SAIDIS, FlOWER & LINDSAY ~AT.IAW 26 West High Street Carlisle, PA II CARRIE A. MONETA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1655 CIVIL 2006 IN DIVORCE PRAECIPE TO TRANSMIT RECORD v. RAYMOND J. MONETA, Defendant To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on April 1, 2006, via certified mail. Proof of service was filed with the Court on April 7, 2006. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: September 1 , 2006 and filed with the Prothonotary on September 8, 2006. By Defendant: September 12, 2006 and filed with the Prothonotary on September 15, 2006. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: September 1, 2006 and filed with the Prothonotary on September 8, 2006. By Defendant: September 12, 2006 and filed with the Prothonotary on September 15, 2006. ... SAIDIS, FLOWER & LINDSAY .qroRNnS-M.IAW 26 Wesr High Srreer Carlisle, PA .. CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Dated: Raymond J. Moneta 205 Holly Drive Camp Hill, PA 17011 SAIDIS, FLOWER & LINDSAY j-; --J , -'-' r c' ~~~~~~~~~~~~~~~~~~~ ~~~~~ ~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. CARRIE A. MONETA No. 06-1655 VERSUS RAYMOND J. MONETA DECREE IN DIVORCE AND NOW, S e.. ~ t t.-~ \0 t,{ CARRIE A. MONETA 1(jt4, IT IS ORDERED AND \~ DECREED THAT , PLAI NT! FF, AND RAYMOND J. MONETA , 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; The terms of the Separation and Property Settlement Agreement dated April 14, 2006 are incorporated, but not merged, into this Decree in Divorce. ( PROTHONOTARY J. _ h :? ~ ~;-t, 1:/- Olp ~ ~ :z ~,,; 4.;> -PJ '1(l 6'-j, .' . .. . ... -------