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HomeMy WebLinkAbout02-1875 SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEYS.AT.LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff V, Syndi L. Guido, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- / ~ ~",~' CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, 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. Date: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SAIDIS, SHUFF, FLOWER & LiNDSAY By: ~ J oh n~,. ~ e p~y ~E~q u ~ A~o~y I,D.~53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY A'fTORNEYS*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- I~"~" ClVlLTERM : : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE Plaintiff is Michael J. Guido, who currently resides at 1428 J311 Bradley Drive, Carlisle PA 17013, Cumberland County, Pennsylvania. 2. Defendant is Syndi L. Guido, who currently resides at 79 Garland Drive, Carlisle PA 17013,Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 26, 1991 in Carlisle Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Date: ~- - /~ - 02. Respectfully submitted, SAIDIS, SH~I~AY By: "~./__~__.~/// Johnna/~dpec.~, E§q uir~" Attorn~(,/f.D. #,~'3147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for the Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATI'OP.N~YS*AT*LAW 26 W. High Street Carlisle, PA AFFIDAVIT I, Michael J. Guido, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and participate in counselling prior to a divorce decree being handed down by the court. 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: /'?/- / ~ ~ ~-~ c,~hael J, Guido, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY A~fORI~YS*AT*LAW 26 W. High Street Carlisle, PA 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. Section 4904 relating to unsworn falsification to authorities. Dated: hael J. Guido, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATIDP, I~I~*AT*LAW 26 W. High Street Carlisle, PA CERTIFICATE OF SERVICE On this /~day of i~/,~, 2002, I, Johnna Kopecky, hereby certify that served a true and correct copy of the foregoing Divorce Complaint via United States Mail, postage prepaid, addressed as follows: Syndi L. Guido 79 Garland Drive Carlisle PA 17013 SAIDIS, SHUFF, FLOWER & LINDSAY By: ~ODh. n~sa3~47 o~ec. 26 West High Street Carlisle PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATrOP, I~/Y$*ATeLAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1875 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes Petitioner, Michael J. Guido, through his attorney, Saidis, Flower & Lindsay and petitions the Court as follows: 1. Petitioner is Michael J. Guido, the Plaintiff in the above matter. 2. Respondent is Syndi L. Guido, the Defendant in the above matter. 3. Petitioner lacks sufficient property to provide for his reasonable needs and is unable to support himself sufficiently despite his employment. 4. Petitioner requires reasonable support to adequately maintain him during the pendency of this divorce action in accordance with the standard of living established during the marriage. 5. The Respondent is financially able to provide for the reasonable needs of a Petitioner. WItEREFORE, Petitioner prays that this Honorable Court enter a maximum fair award for Alimony Pendeme Lite during the pendency of this divorce action. By: Respectfully submitted, SAID~~ & LINDSAY J_o~Kopffcy, ES~" 5upt.0~e Ct. L"D. # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff SAIDIS SHIIFF, FLOW~ & LINDSAY 26 W. High Street Carlisle, PA YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or heating. SAIDIS SHUFF, FLOWER & LINDSAY ATTOR~YS~AT*LAW 26 W. High S~'eet Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: MICHAEL J. GUIDO, Plai~fifffPetitioner VS. SYNDI L. GUIDO, Defendant/Bespondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE : NO. 2002-1875 CIVIL TERM IN DIVORCE : DR~ 31992 Pacsem~ 443104782 ORDER OF COURT AND NOW, this 18th day of September, 2002, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective conn~l appear before R.J. Shaddav on October 22~ 2002 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11{) (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required doo,ments, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 9-18-02 to: P~qJ. tioner Respondent Johnna Kopeclcy, Esquire Date of Order: September 18, 2002 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HI~LP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS SHUFF, FLOWER & LINDSAY AT'rOR]x~YS*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaimiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002- 1875 CIVIL TERM Syndi L. Guido, : CIVIL ACTION - LAW Defendant : IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes Petitioner, Michael J. Guido, through his attorney, Saidis, Shuff, Flower & Lindsay and petitions the Court as follows: 1. Petitioner is Michael J. Guido, the Plaintiff in the above matter. 2. Respondent is Syndi L. Guido, the Defendant in the above matter. 3. Petitioner lacks sufficient property to provide for his reasonable needs and is unable to support himself sufficiently despite his employment. 4. Petitioner requires reasonable support to adequately maintain him during the pendency of this divorce action in accordance with the standard of living established during the marriage. 5. The Respondent is financially able to provide for the reasonable needs of a Petitioner. WHEREFORE, Petitioner prays that this Honorable Court enter a maximum fair award for Alimony Pendente Lite during the pendency of this divorce action. Respectfully submitted, SAID~ & LINDSAY By: jo~, Es~ii~.j Sup~.oine Ct. ED. # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attomey for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY A~gJ~YS~AT*LAW 26 W. High Street Carlisle, PA YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. COURT ADMINISTRATOR FOURTH FLOOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland Cotmty is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SAIDIS SHUFF, FLOWER & LINDSAY ATrORI~$*AT*LAW 26 W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date: Michae~uido In the Court of Common Pleas of CUMBERLANO County, Pennsylvania DOMESTIC RELATIONS SECTION MICHAEL J. GUIDO Pl~ntiff VS. SYNDI L. GUIDO Defendant ) Docket Number ) ) PACSES Case Number ) ) Other State ID Number 02-1875 CIVIL 443104782/D31992 ORDER AND NOW, to wit on this 22ND DAY OF OCTOBER, 2002 IT IS HEREBY ORDERED that the O Complaint for Support or O Petition to Modify or (~) Other ALIMONY pENDENTE LITE ~lled on AUC-.UST 6, 2002 in the above captioned matter is dismissed without prejudice due to: PETITIONER WITHDREW HIS REQUEST FOR CONFERENCE ON THE A~IMONY pENDENTE LITE. 0 The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant Robert Saidis, Esquire Michael Bangs, Esquire BY THE COURT: E~gar B. Bayley ! ~t~GE S~rvie~ Type M Form OE-506 Worker ID 21o05 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002 - 1875 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE To the Prothonotary: Please withdraw the claim of Plaintiff, Michael J. Guido, for Alimony Pendente Lite. Date: d-- RobOt C. Saidis, Esq. Att~orney for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEY'*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002- 1875 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on April 17, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Michael J. Gu~i~', ~lainti~~' SAIDIS SHUFF, FLOWER & LINDSAY AT~OP,~/YS*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1875 CIVIL TERM © ~ ,~ : CIVIL ACTION - LAW ~'4" ~ ":> ' : IN DIVORCE ' '- . '~ ~', WAIVER OF NOTICE OF INTENTION TO REQUES'~ {~, :~; ENTRY OF A DIVORCE DECREE UNDER s33011c) OF THE DIVORCE CODF 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Uichael~ido, I:~intiff Date: (~_~.c_/7~ ,-~90~2--- SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEYS*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1875 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 23301(c) of the Divorce Code was filed on April 17, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~,'ynej~?-~uido, D~p~1~ant SAIDIS SHUFF, FLOWER & LINDSAY ATrOP, N~YS*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2002- 1875 CIVIL TERM Syndi L. Guido, : CIVIL ACTION - LAW ~!!~ Defendant : IN DIVORCE :~, WAIVER OF NOTICE OF INTENTION TO REQUES-~ ~' ENTRY OF A DIVORCE DECREE UNDER s33011c~ OF THE DIVORCE CODF 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 to the best of my knowledge, information and belief. 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: Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1875 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE · .Complete 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 maJlpiece, or on the front if space permits. 1. A~icle Addressed to: Syndi L. Guido 79 Garland Dr. Carlisle, PA 1701-3 2. Article Number (:fmnsfer from service label) PS Form 3811, August 2001 A. Signature Printed Ne/he) D. Is detive~ address ~ If YES, enter ( 3.Se?ice Type '~l~rtified Mail ~:legistemd [] R~fum Receipt for Merchandise LJ Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes Domestic Return Receipt - ~ 102595-01 -M-O381 SAIDIS SmJFF, FL0W~R & LINDSAY ,ATrOR~I~*AT*LAW 26 W. High Street Carlisle, PA Michael J. Guido, Plaintiff Syndi L. Guido, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1875 CIVIL TERM : : CIVIL ACTION - LAW : 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. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the complaint: Certified, Registered, Return Receipt Requested, May 25, 2002 (attached) 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff on October 17, 2002; by the Defendant on October 18, 2002 4. Related claims pending: None Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: November 12, 2002 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: November 12, 2002 By: Respectfully submitted, S AIDIS, SH~sE2LiNDSAY Robert C. ~aidis, Esquire Supreme Court ID #21458 26 W. High Street Carlisle PA 17013 Ph: 717.243.6222 Attorney for the Plaintiff Michael j. Guido, Plaintiff VERSUS Syndi L. Guido, Defendant INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. No. 2002-1875 Civil DECREE IN DIVORCE AND N OW, ~~~Li~ DECREED THAT Michael J. Guido AND Syndi L. Guido ARE DIVORCED FROM THE BONDS OF MATRIMONY.' ~lT IS ORDERED AND , 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; None. BY H COUR ATT~~ PROTHONOTARY