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Home My WebLink About06-2521 BEVERL Y A. CORRAO, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. D& - J SrJ / Civil Term ANTHONY CORRAO, Defendant : ACTION 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 (ail 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 Plainti ff. You may lose money or property or other rights important to you, including custody or visitation of your children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 BEVERLY A. CORRAO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. () {> .;{!{ 2 ( Civil Term ANTHONY CORRAO, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Beverly A. Corrao, a competent adult individual, who has resided at 162 Virginia Ave., Carlisle, Cumberland County, Pa., 17013, since March 2006. 2. Defendant is Anthony Corrao, a competent adult individual, who has resided at 228 Faith Circle, Carlisle, Cumberland County, Pa., 17013, since 2002. 3. Plaintiff and Defendant have been bona fide residents ofthe Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 12, 1996 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together, namely, Amanda Corrao, date of birth, April 7, 1997. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. ] O. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. ] 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. 94904 relating to unsworn falsification to authorities. ~-1'(~ orrao, Plaintiff Respectfully submitted, Date: .S I {c, / a Adams, Esquire I. . No. 79465 4 South Pitt Street Carlisle, Pa. 170] 3 (717) 245-8508 ATTORNEY FOR PLAINTIFF ( '\ "'">>/ ~~ :;:J. ~. d '--.J -{::.. +- ..>-,;. .{:... '-^, - \ \ --S::'\ -...l C> (/\ c::: BEVERLY A. CORRAO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 2521 Civil Term ANTHONY CORRAO, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND,NOW, tl1is May 18,2006, I, Jane Adams, Esquire, hereby certify that on May 12,2006, a certified true copy oftl1e NOTICE TO DEFEND AND COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: Anthony Corrao 228 Faith Circle Carlisle, Pa. 17013 DEFENDANT . ComplllIe Ilems 1, 2, and 3. Also complete ~em 4 n RIllltrIcled Delivery Is desired. . Print your name and address on the revtlI'58 so that we can return tha card to you. . Allach thls card to the back 01 the rnallplace, or on the Iront n space pennils. 1. ArtIcle_to: ANTHONY CORRAO 22& FAITH. CIRCLE., CARLISLE: PA 1 'ffl1 3 2. ArttcIe Number ~from""""ce/_) i PS Form 3811, February 2004 3. ServIce llIpe .Ji!l;,.rtlfled Mail 0 Express Mail o Registered 0 Return Recelpt lor Merchsndlse o 1n.ured Mail 0 C.O.O. 4. RestrIct"" Delivery? (Brtno Fee) '9'f"es 7004 1350 0003 7288 4547 Domeslk: Return Receipt 10251&0241540 an Adams, Esquire LD No. 79465 Soutl1 Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF (") ~ <, -0 l~:" ~~:,' ~,.~. - r~:;:: ~ 5~~= :-;7- 3 " ....., = = cr-> -r,: :;;. -< s;j :C-n rn- -oM "J6 i'" '~ ) :-c::f"i (JE) om ~ Cf:) :32 -l;... - .. N +" BEVERL Y A. CORRAO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 06.2521 Civil Term ANTHONY CORRAO, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 4, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a fmal 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: 9' ~- , G.. c~ Beverly A. 0, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &33011c) AND ~330l(d) OF THE DIVORCE CODE 1. I consent to entry of a fmal 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. Date: Cf. <;. ~ \:..,4 t....:~., BEVERLY A. CORRAO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 2521 Civil Term ANTHONY CORRAO, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under section 3301(c) ofthe Divorce Code was filed on May 4, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filin? 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date/f~;b(, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !5330l(c) AND !53JOl(d) OF THE DIVORCE CODE I. I consent to 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 s herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn fals'ficati ut or' . s. Date q(;(~;; ~ c/..~, :.:;J f~~l C":-' --7"""1 c . ~.. BEVERL Y A. CORRAO, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. ' No. 06 - 2521 Civil Term ANTHONY CORRAO, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 93301(c) of the Divorce Code. 2. Date and manner olthe service of the Complaint: Via certified mail, restricted- delivery, return-receipt requested, on: May 12,2006 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: September 5, 2006 By Defendant: September 15,2006 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: September 18, 2006 Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: September 18, 2006 Date: q ( I ?) / 6 ~ e Adams, Esquire .D. No. 79465 64 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ""d -_.~ ~:;:-l c. ..,.: "';Ii ;Ii'" ;Ii ;Ii ;Ii;li;li;li ;Ii ~;Ii~~~ ;Ii ~ ~~~~~if.if.;Ii;li if.;liif.if.if.~if.~ :t' ;Ii :t' ;Ii if. ~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Beverly A. Corrao, Plaintiff No. 06 - 2521 Civil Term NO. VERSUS Anthony Corrao, Defendant DECREE IN DIVORCE ~ :t' :t' :t' Of. :t' ;t: Of. Of. :t' '" AND NOW, s~)C> t 20 Beverly A. Corrao , 2.00', IT IS ORDERED AND DECREED THAT , PLAI NTI FF, Anthony Corrao AND , 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. J. ~ ~~~~";";";'Ii ";";'Ii'li'li"'''; 'Ii 'lif!;f!; f!;f!;f!; f!;f!;f!;f!;f!; f!;f!;f!;f!;f!;'" "'f!;'" ,.;",,.;;t:";'Ii"'''''lif!;'Ii'''f!; "r# fi ~ ~ 117)C",7 ~r ~~4'.Gv.~ 'XI'W~ '~ ll: </\ ." .",.. ~