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Home My WebLink About06-2142TODD MANCINI, V. MARY MANCINI, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: Ot? - o?!Ua 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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, 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 2 LIBERTY AVENUE Carlisle, PA 17013 (717) 249-3166 TODD MANCINI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, / V. :NO: 0? -a14? ?rc>r? CIVIL ACTION -LAW MARY MANCINI, IN DIVORCE Defendant. COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Todd Mancini, by and through his attorneys, Mancke, Wagner & Spreha, and files the following Complaint in divorce: 1. The Plaintiff, Todd Mancini, is an adult individual currently residing at 4 Essex Road, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant, Mary Mancini, is an adult individual currently residing at 221 Oxford Manor, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are husband and wife having been married on May 26, 1995, in the Poconos, Pennsylvania. 4. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the availability of counseling and that he has the right to request that the Court require both parties to participate in counseling. 8. Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken pursuant to §3301(c) of the Divorce Code; and B. that as of February 1, 2008, the parties will have lived separate an apart for a period of at least two (2) continuous years pursuant to §3301(d) of the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, Mancke, Wegner & Spreha P. Richard Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Plaintiff Date: G Q/v -2- I verify that the statements made in the foregoing document 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. DATE: 3 - Z?i - 1 C -c TODD MANCINI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 06-2142 CIVIL TERM : CIVIL ACTION -LAW MARY MANCINI, : IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 13, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 4. 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 unworn falsification to authorities. ' .Q. DATE:- //07 Mary Manc' i ?'? a ? ?:?_ .? :.?. ?_ -n _. =? - -??, .- c? : ,'-.. _ ?£ ? ? 4l: - ..?.? -? ,_ c^? • ?a {7' .? , TODD MANCINI, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. Plaintiff, : NO. 06-2142 MARY MANCINI, Defendant. : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Mary Manci DATE: ? co TODD MANCINI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO. 06-2142 : CIVIL ACTION -LAW MARY MANCINI, : IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 13, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 4. 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. DATE: Todd Mancini rv r-s F r, r, _ v z ' ? GJ TODD MANCINI, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. : NO. 06-2142 CIVIL TERM MARY MANCINI, Defendant. : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33010c) 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Todd Mancini DATE:?II ?7 C? ? p c?. {-In 4 % f-ii 4 L n -1 TODD MANCINI, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. NO: 06-2142 CIVIL ACTION -LAW MARY MANCINI, IN DIVORCE Defendant. CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of Mancke, Wagner, Spreha & McQuillan, do hereby certify that on this date a copy of the Complaint in divorce was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Ms. Mary Mancini 5325 Oxford Drive, Apt. 121 Mechanicsburg, PA 17055 ? t By Debra K. Spinner, ecretary Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff Date: A / ??6(0 - 1,, Er Utr9 r • - a j (Domestic Mail Only;Zo lnst:'ance Coverage Provided) Ln . delivery information visit our website at www.usps.com, %oFFICIAL USE-1 M Postage $ r-1 Certified Fee C3 Q Return Receipt Fee Postmark Here (Endorsement Required) ? c3 Restricted live Fee (Er(Endorsement Required) Total Postage: Fees $ Ln Sam TO -S>reer ?.??----- ------ - ------- -#......---°°------ or PO Box lY.. J?j?J ? . I. .r. ------- - ---- ------------- ZIP44 . ¦ Complete items 1, 2, and 3. Also complete item 4 It.Re"19ted Delivery Is desired. ¦ Print your name and address on the reverse -so that we can retum the card to you. ¦ Attach this card to the back.of the mallpiece, or on the irortt If space permits. 1. A title Addressed to: • A?aAj /7?gS 0 Agent D. Is delivery apdress dtf6erent If YES, enter delivery addn jc? k Ir . 3. CertHied Mall O Express Mdi-"`°••- R"Wered ? Retum Receipt for Merchandise ? insured Mail ? C.O.D. 4. ResMated Delivery? (Extra Fee) Yes 2. Article Number 7005 1160 0001 3321 5069 (7lansfer ft m service PS Form 3811, Feb mwy 2W4 DorneWc Return Receipt 102596-02-M-1sw co --t -TI *t_ -C TODD MANCINI, V. Plaintiff, MARY MANCINI, Defendant. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 2006-2142 CIVIL : CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: 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(c), 3301 of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: May 17, 2006, by certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 05/19/07 By Defendant: 04/19/07 (b) (1) Date of Execution of the Plaintiffs Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1)(i) of the Divorce Code: (b) Date Plaintiffs Wavier of Notice was filed with the Prothonotary: 04/18/07 (c) Date Defendant's Waiver of Iiotice jku filed d with th e Prothonotary: 06/12/07 .P.?Wi Esq. Attorney for Plaintiff tb ? { -y?1 w . ( r+ C)f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TODD MANCINI, VERSUS DECREE IN DIVORCE AND NOW, Am g , LZ do7, IT IS ORDERED AND TODD MANCINI DECREED THAT AND No. 9006-2142 MARY MANCINI 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; A By THE COURT: A4v- Arw 1-909