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Home My WebLink About02-1461JEROME A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 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 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, Carlisle, PA. 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 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 JEROME A. MARSICANO, JR., Plaintiff VS. CIVIL ACTION - LAW IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NUMBER: ~--- lq(.! KEIKO TERAO MARSICANO, : Defendant : IN DIVORCE COMPLAINT UNDER §3301{d[ OF THE DIVORCE CODE Plaintiff is JEROME A. MARSICANO, JR., who currently resides at 2608 Chestnut Street, Camp Hill, County of Cumberland, Pennsylvania, since 1998. 2. Defendant is KEIKO TERAO MARSICANO, who currently resides at 1-2-32 Katanoshiu-Machi #402, Kakurakita-Ku, Kitakyushu, Fukuoka, Japan since 1998. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on September 7, 1994, in Las Vegas, County of Clark, Nevada. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 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. 8. Neither party is a member of the Armed Forces of the United States of America or any of its allies. 9. Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this Complaint 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: .,o't~ROMk A. M~t~SICANO, J~., PLAINTIFF CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 ATTORNEY FOR PLAINTIFF JEROME A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NUMBER: I~)~- [ : : IN DIVORCE NOTICE 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. AFFIDAVIT UNDER .fi3301[d} OF THE DIVORCE CODE 1. The parties to this action separated on 1996 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.C.S. Section 4904 relating to unsworn falsification to authorities. PLAINTIFF JEROME A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NUMBER: ~ll-. I : : IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE I, Plaintiff herein, do hereby depose and say that I am advised and believe that the above named Defendant is not presently in the active military service of the United States of America and I aver that the Defendant is not a member of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and is not an officer of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor is Defendant engaged in any military or Navy units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service; nor has Defendant, to the best of my knowledge, enlisted in the military service covered by this act. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. 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. Section 4904, relating to unsworn falsification to authorities. DAT~ / PLAINTIFF JEROME A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NUMBER: 02-1461 Civil Term : : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF §3301(d) DIVORCE DECREE TO: KEIKO TERAO MARSICANO (DEFENDANT) You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the §330 l(d) affidavit. Therefore, on or after May 17, 2002, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249-3166 JERONE A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 02-1461 Civil Term IN DIVORCE COUNTER-AFFIDAVIT UNDER §3301{d} OF THE DIVORCE CODE 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 {bI above, I must 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 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 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. KEIKO TERAO MARSICANO, 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 need not file this counter-affidavit. JEROME A. MARSICANO, Plaintiff VS. KEIKO TERAO MARSICANO, Defendant IN THE COURT OF COMMONPLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 2001-2375 IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Notice to Defend and Claim Rights, Complaint Under Section 3301 (d), Notice and Affidavit under section 3301 (d), and Military-Affidavit. Service was made on __~ day of ~ I , by registered restricted delivery. KEIKO TERAO MARSICANO, DEFENDANT JEROME A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 02-1461 Civil Term IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Notice to Defend and Claim Rights, Complaint Under Section 3301 (d), Notice and Affidavit under Section 3301 (d), and Military-Affidavit. Service was made on sixth day of April, 2002, by registered restricted delivery. I hereby accept service of the Notice of Intention to Request Entry of a divorce decree and Counter-Affidavit. Service was made on the [~ /~ , 2002. ... day of k~IK~;I'ERAO MARSI~kNO, JR. DEFENDANT JEROME A. MARSICANO, JR., Plaintiff VS. KEIKO TERAO MARSICANO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NUMBER: 02-1461 CIVIL TERM : : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate divorce decree: 1. Grounds for divorce: Irretrievable breakdown under §330 l(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of complaint: April 6, 2002, by registered restricted delivery 3. Complete either paragraph (a} or (b): (a)(1) Date of execution of the affidavit of consent required by §330 l(c) of the Divorce Code: by plaintiff: ; by defendant: (a)(2) Date of execution of the Waiver of Notice of Intention required by §3301(c) of the Divorce Code: by plaintiff: ; by defendant: (b)(1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: March 20, 2002. (b)(2) Date of filing and service of the plaintiffs affidavit upon the respondent: Filed: March 25, 2002; Served: April 6, 2002. 4. Related Claims Pending: NONE. 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: May 18, 2002, by registered, restricted delivery. (b) Date plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: (c) Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: CHARLES E. PETRIE ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF .,~,. PENNA. JEROME A. MARSICANOt JR.t Plaintiff VERSUS KEIKO TERAO MARSICANO~ D~fendant NO. 02-1461 civil Term DEcree IN DIVORCE AND NOW, ~ U ~ 3"'~ ~ ~ DECREED THAT JEROME A, MARSICANO, JR. 2002 , IT IS ORDERED AND , PLAINTIFF, AND KEIKO TERAO MARSICANO , 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; NONE BY THE COURT: PROTHONOTARY