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HomeMy WebLinkAbout06-3635 L. D'ALESSANDRO, Plaintiff VS. T. D'ALESSANDRO, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS case you the OR EX. CLAIM i have been sued in court. If you wish to defend against the claims set forth in the pages, you must take prompt action. You are warned that if you fail to do so, the proceed without you and a decree in divorce or annulment may be entered against court. A judgment may also be entered against you for any other claim or relief I in these papers by the Plaintiff. You may lose money or property or other rights to you, including custody or visitation of your children. m the ground for the divorce is indignities or irretrievable breakdown of the you may request marriage counseling. A list of marriage counselors is available in of the Prothonotary at: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. v(? 13G 35" G'(- ? IN DIVORCE Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 YOU DO NOT FILE A CLAIM FOR ALIMONY , DIVISION OF PROPERTY, LAWYER'S FEES JSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO IY OF THEM. OU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYE OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND 0 T WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 L. D'ALESSANDRO, Plaintiff VS. T. D'ALESSANDRO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.OL•363?< C-"j- _71- IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO WITHIN-NAMED DEFENDANT: ou have been named as the Defendant in a Complaint in a divorce proceeding filed in the ourt of Common Pleas of Cumberland County. This notice is to advise you that in accord nce with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce beinghanded down b the court. A list of professional marriage counselors is available at the Domestic Relatio s Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is k pt as a convenience to you and you are not bound to choose a counselor from this list. A I necessary arrangements and the cost of counseling sessions are to be borne by you and yo r spouse. I you desire to pursue counseling, you must make your request for counseling within twenty ays of the date on which you receive this notice. Failure to do so will constitute a waiver Of your right to request counseling. L. D'ALESSANDRO, Plaintiff VS. NO. 06 - 3G 35, resides Cumbe Hill, PA 3 Commoi this Con 4 Rico. 5 6 7 T. D'ALESSANDRO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE NOW comes the above-named Plaintiff, KELLIE L. D'ALESSANDRO, by her Samuel L. Andes, and makes the following Complaint in Divorce: The Plaintiff is KELLIE L. D'ALESSANDRO, an adult individual who currently t 225 Allendale Way in Camp Hill, Cumberland County, Pennsylvania. The Defendant is ANTHONY T. D'ALESSANDRO, an adult individual who resides in J County, Pennsylvania, and who can be served at 3401 Hartzdale Drive in Camp 17011. Both the Plaintiff and Defendant have been bona fide residents of the of Pennsylvania for at least six months immediately previous to the filing of The Plaintiff and Defendant were married on 18 June 2002 in San Juan, Puerto There have been no prior actions of divorce or annulment between the parties. The marriage is irretrievably broken. Plaintiff has been advised of the availability of marriage counseling and the may have the right to request that the Court require the parties to participate in f COUNT I - IRRETRIEVABLE BREAKDOWN B. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. Sam el L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12'' Street Lemoyne, Pa 17043 (717) 761-5361 C.S. I verify that the statements made in this Complaint are true and correct. I tand that any false statements in this Complaint are subject to the penalties of 18 Pa. P04 (unsworn falsification to authorities). ELLI? D ALESSANDRO s a ra KELLIE L. D'ALESSANDRO, Plaintiff VS. ANTHONY T. D'ALESSANDRO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-3635 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE The undersigned, Anthony T. D'Alessandro, does hereby accept service of the Divorce Complaint filed against him in this matter and acknowledges receipt of a certified copy of that Complaint. DATED: / NTHO T. D? SANDRO - C-; -. , <, ,?? KELLIE L. D'ALESSANDRO, Plaintiff VS. ANTHONY T. D'ALESSANDRO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-3635 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 27 June 2006 and served on 1 July 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. Dated: October 2, 2006 ANT O T. DALE SANDRO ?' `== i r _ c -t:i ?-? c:r? t?7 ? ^t'? ? [-2;._ ?.- ...? ? -? 1 «.1 0? F? ?. ^`v , KELLIE L. D'ALESSANDRO, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-3635 CIVIL TERM ANTHONY T. D'ALESSANDRO, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 27 June 2006 and served on 1 July 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. Dated: October 2, 2006 J6& l 9 KELLIE L. D'ALESSANDRO ? Pv ?a ? ? ??. _???.. c?? `77 ?y ?? ? ` ? ?-r > C ? -_... " _.; ? ! " -rr ; ? .• ... w' ? ._l ( . r_ ,?? ..'?'.I. ?: ?:^ =' r r, ; ? ? . ` a C.?) --<. KELIE L. D'ALESSANDRO, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2006-3635 CIVIL TERM ANTHONY T. D'ALESSANDRO, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filed by Plaintiff's counsel indicating service on or about 1 July 2006 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: 2 October 2006 By Defendant: 2 October 2006 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 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: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 2 October 2006 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 2 October 2006 and filed on 11 October 2006. Date: 23 October 2006 B uel L. Andes Attorney for Plaintiff na \¢ ? 4yJ w.. ` r ? _•. GY r CZ? ? t? ? 1^ CZ) L? _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KELLIE L. D'ALESSANDRO, Plaintiff No. 2006-3635 VERSUS ANTHONY T. D'ALESSANDRO, Defendant DECREE IN DIVORCE AND NOW, 2006 Q..? IT IS ORDERED AND KELLIE L. D'ALESSANDRO DECREED THAT , PLAINTIFF, ANTHONY T. D'ALESSANDRO 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 vow IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA _KELLIE L. D'ALESSANDRO,_ Plaintiff Vs File No. 2006-3635 _ANTHONY T. D'ALESSANDRO_ IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, prior to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated October 3t, 2006, hereby elects to resume the prior surname of Kellie Lynn Mclurov, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: 44??? ' &. d A., ? Signa re o Kellie Lynn D'Alessandro Signature of Kellie Lynn McInroy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND) On the R,? day of ? 2008, before the notary public, personally appeared the above affiant knq to be the person whose name is subscribed to the within document and ackno edged that she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. `f NOTARIAL SEAL SHELLY L NESTER Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Jul 31, 2008 t SA ' .' ? -? i i-.- r? t : ; :y:.. ?\ ?? - ? n C'f w . ? ? - . '- ... w .S ?. ?. r,l`. ?.