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HomeMy WebLinkAbout06-2941 /I - RESOLINO MANIACI, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 06 - 2941 ROSARlA MANIACI, Defendant, : CIVIL ACTION - AT LAW : IN DIVORCE AFFTnA VTT OF SFRVTC'€ TO THE PROTHONOTARY: I, Shana M. Pugh, Esquire, verifY that the Complaint in Divorce has been served upon the Defendant indicated above by first class, certified mail # 7005-0390-0006_ 3485-5209, restricted delivery, postage prepaid, return receipt requested, pursuant to the requirements ofPa. R.C.P. 1930.4. · ComplIne 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: ~03ClflCt MOflmQj ctD 15 /v\Oxlon f\vt:. ~~llOI3 o Agent g AcIdressee G. ~~gf Delivery ~ -bb-cr b oVes ONe 2. ArtIcle Number (1hJnsIw from SW1Itce IBbeJ) PS Form 3811. February 2004 3\.~lce Type ~ Mall 0 ~ress Mail o Registered ~etum Receipt for Merchandise C InsUred Mall C C.O.D. 4. Restricted Delivery? (Extra Fee) Ves 7005 0390 0006 3485 5209 Domestic Retum Receipt 102595-{)2-M-154Q ~pectful1y submitted, ( . / ('''C--'' - Date: ) len (/\ t I Shana M. Pugh, Esquir. Law Offices ofPatric F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp HilI, Pennsylvania 17011-4706 ID# 200952 Tel. (717) 763-1800 a r-...> 0 = ~ = "'Tl CT' (/) :.? r.-'" -'-11 ,; , tnp -0 '.'orn 1') .rjv -l !~-_) ,.1, -0 ,~~ ::1: ; c: ~ J_ ---I -;.... ;; .<-- ..._~ N -(~ -< -- RESOLINO MANIACI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 06-2941 ROSARIA MANIACI, Defendant : CIVIL ACTION- AT LA W- IN DIVORCE PLAINTIFF'S AFFIDAVIT OF eONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE May 22, 2006. 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. to request entry of the decree. 3. I consent to the entry of a final decree of divorce after service of notice of intention 4. I verity 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. g 4904 relating to unsworn falsification to authorities. Date: '/-/2 - <X Signature: .7', r\ (\.~ ..e Resolino Maniaci /~~ z -.... -( f"--) C::::'"J \:::::) 0'" (/) r-q -0 N -..l o -n -t :c~ n1-"-' , r- -r; f11 :!~(? '-::;Cl c~~~ ~.J =r;! ~ -< -0 ~:.: ,- ~. N II - RESOLINO MANIACI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 06-2941 ROSARIA MANIACI, Defendant : CIVIL ACTION- AT LA W- IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I. 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. 4. I verity that the statements made in this affidavit are true and correct. I understand that false statements herein are made suhject to the penalties of l8 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. Date: q - /2. ...O~' Signature: [2()~ /(~~ Resolino Maniaci (") ~~. r--.:l C'..:> = CJ'" (/) r-rc I' . -;:; f',' -.l - ,-. o -0 --4 I-n rnp -0 rr1 ;I~7 :-~, (~) :'-r: :'T~ r:> ,. 0,,0 Orn ..-1 '1'> Xl -< f',) _~____.___~ft----~_.~~~~~ RESOLINO MANIACI, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 06 - 2941 ROSARIA MANIACI, Defendant, CIVIL ACTION - AT LA W IN DIVORCE PRA FCTPF TO TR A NSMTT RFCORO 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 S 3301(c) S 3J01(d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Service by first class, certified mail #7005-0390-0006-3485-5209, restricted delivery, return receipt, delivered on May 26, 2006. See attached Affidavit of Service. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by the Plaintiff Septemher 1?, ?OOh by the Defendant Septemher 1 h, ?OOh (b) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: Date of filing of the Plaintiffs affidavit upon the respondent: Date of service of the Plaintiffs affidavit upon the respondent: _. 4. Related claims pending: None No d::lims miseo 5. (Complete either paragraph (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, (b) Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: fileo simlllt::lneOllsly wlPmecipe Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: fileo S~ptemher ?h, ?OOh Respectfully submitted, Shana M. Pugh, Esquire Law Offices of Patrick . Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 200952 Tel. (717) 763-1800 Date: {/( ~:;7 c Lt- , () r-...:> 0 c:::.:::> ::= = 11 c:T"' (/) =? r~i'""4 -- "T1 -0 rnr= N -0 J::!J "."e... -.J (5() -i_.,.. -V ~;'<1~ :0 ....;0.- ~~': (") ---"'" ,,~- ::.:J In J.- :-l ..1> N :n -< . "\ vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. Ot.. - .J..1l{! (L ~ t-r8L~ : CIVIL ACTION- AT LA W- IN DIVORCE RESOLINO MANIACI, Plaintiff ROSARIA MANIACI, Defendant 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 at the 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 TillS 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, P A 17013 (717) 249-3166 ... RESOLINO MANIACI, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. O~ - ;;{9l1; c,U~C-T&2-1 : CIVIL ACTION- AT LA W- IN DIVORCE ROSARIA MANIACI, Defendant DIVORCE COMPLAINT The Plaintiff, Resolino Maniaci, by and through his attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce: COUNT I-NO FAUL T DlVORCE--~~ 3301(c) or 3301(d) I, The Plaintiff, Resolino Maniaci, is an adult individual currently residing at 200 B Marion Avenue, Carlisle, Cumberland County, Pennsylvania 17013, 2. The Defendant, Rosaria Maniaci, is an adult individual currently residing at 200 B Marion Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this complaint. 4. The parties were married on December 21,1992, in Brooklyn, New York, 5, There have been no prior actions of divorce or for annulment between the parties. 6, The marriage is irretrievably broken. 7, The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. 9, There are two minor children to this marriage. WHEREFORE, the Plaintiff requests this Honorable Court enter a decree of Divorce in this matter. .... Respectfully submitted, Date: ~- 11-() lp Shana M. Pugh, Es uire Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011 ID# 200952 Tel. (717) 763-1800 > " " RESOLINO MANIACI, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO, ROSARIA MANIACI, Defendant : CIVIL ACTION- AT LA W- IN DIVORCE VERIFICATION 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: 5 ~ If{ - Ob Signature: :401) oj Ii Rosolino Maniaci \:) 1Pr , - 1:. ..0 \) - V1 - -C ';) ~ V"t "Q ~ ~ ~ -.lJ ~ - o ~)~~~': r\'1 ~-\ --':;" 1>\ ~>: r;: ~:\;" :2. r;;; = of' - -1'"."" P" -, ~ S;:J:1 ~S -\)0 N C)':' N :? :', i'"J,:l -0 ;~:; c> :3: grn '-? ':2: ~ a ;.., ~ II RESOLINO MANIACI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-2941 ROSARIA MANIACI, Defendant : CIVIL ACTION- AT LA W- IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE eODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 22, 2006. 2. The marriage of the Plaintiff and the 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 final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. S 4904 relating to unsworn falsification to authorities. Date: ~ II b I ~ c.. I t Signature: /ZJu~_ ~ . Rosaria Maniaci () c <" ,)i:;' ~r:' 6~ ~) 5;'. ~~~ --' -< ,......, = = c;r. U) JI1 ...,/ o 11 --4 :r: mfQ -om :nrl 0' -I C) 25:r, 7C) (3m ~ ~ -< 1',> (j) V ::ll: l)? .r::- "j II RESOLINO MANIACI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 06-2941 ROSARIA MANIACI, Defendant : CIVIL ACTION- AT LA W- IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVOReE DEeREE 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! 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. 4. 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: 9!J~ lOG I , a q!Jd~ I ILllli ~ Rosaria Maniaci Signature: f""-:l c::=> = er- e/) rrt -0 N 0'"\ ; c::. -/ ..., ::2 -0 $ N .' ~ ~--r1 rnr: -n rr. -(:IeJ '~)b ~:f\ ::) -c-) ~07 \1'1 9\ ~ ::..:::. .r;- N ;f. ;Ii ;Ii ;Ii if. ;Ii ;Ii if. !f. !f. ;Ii ;Ii if. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY if. if.if. ;f,if.if.if.<f. <f.;f, if. if. if. if. if. if. if.;f,if. ;Ii STATE OF PENNA. RESOLINO MANIACI, No. 2006 - 2941 Plaintiff VERSUS ROSARIA MANIACI, Defendant DECREE IN DIVORCE AND NOW, 0<-. -\'0 ~e,( 3 100Co, IT IS ORDERED AND DECREED THAT Resolino Maniaci , PLAI NTI FF, AND Rosaria Maniaci , 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; PROTHONOTARY None. By THE COURT: ~-LlW { MtJJ if. if. if. if. if. if. if. if. if. if.if.if.if.<f. if. if. if. 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