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Home My WebLink About02-2993PATTI L. IACHINI 160 Willow Mil Park Road Mechanicsburg, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive, Apt. Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUiTrY, PENNSYLVANIA CIVIL ACTION - LAW No. .- 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 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 Court House, 1 Courthouse Square, Carlisle, PA 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS ~RANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAEE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~0 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 800-990-9108 Service PATTI L. IACHINI 160 Willow Mil Park Road Mechanicsbur~, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive, Apt. 110 Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE CO~P~u%INT 0NDEH SECTZON 3301(c) OF THE DIVO~6~_ COD; TO THE HONORABLE, THE duvOES OF SAID COURT: AND NOW, comes the Plaintiff, PATTI L. IACHINI, by her attorney, A. MARK WINTER, ESQUIRE, and files this Complaint in Divorce and represents as follows: 1. Plaintiff is PATTI L. IACHINI, who currently resides at 160 Willow Mill Park Road, Mechanicsburg, Cumberland County, PA 17050, and has resided there since on or about May 30, 1998. 2. Defendant is RICHARD J. IACHINI, JR., who currently resides at 2901 Society Hill Drive, Apt. 110, Camp Hill, Cumberland County, PA 17011, and has resided there since on or before November 1, 2001. 3. Both Plaintiff and Defendant have been residents in the Commonwealth for at least six immediately previous to the filing of this Complaint. bona fide (6) months 4. The Plaintiff and Defendant were married on September 27, 1997, in East Stroudsburg, Pennsylvania. 5. Plaintiff avers that there are no children born of this marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. 9. Neither Plaintiff nor the Defendant are in the military or naval services of the United States or its allies, or are otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 19A0 and its amendments. -2- WHEHHFOHH, Plaint~f~ requests the Court to enter a decree divorce. Respectfully submitted, A.-Mark'Winter, ~squire-- 310 W. Chocolate Avenue Hershey, PA 17033 (717) 533-4868 ID #23178 Attorney for Plaintiff -3- VERIFICATION I, PATTI L. IACHINI, hereby verify that the statements in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that the statements are made subject to the penalties of 18 PA.C.S. Section 4904, relating to the unsworn falsification to authorities. Dated: J{,.~,~f~. ZOOt PATTI L. IACHINI 160 Willow Mill Park Road Mechanicsburg, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive, Apt. 110 Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2993 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 21, 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 of divorce after service of note of intention to request entry of the decree. 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. Dated: PATTI L. IACHINI 160 Willow Mill Park Road Mechanicsburg, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive,. Apt. 110 Camp Hill, PA 17011 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 02-2993 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 21, 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 of divorce after service of note of intention to request entry of the decree. 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. ~HA~/ IACHI~/ Defendant Dated: PATTI L. IACHINI 160 Willow Mill Park Road Mechanicsburg, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive, Apt. 110 Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COU1T~Y, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2993 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S 3301(C) AND S 3301(d) 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. Dated: PATTI L. IACHINI 160 Willow Mill Park Road Mechanicsburg, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive, Apt. 110 Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2993 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 5 3301(C) AND 5 3301(d) 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. . ~ ~~/~DR~endant Dated: PATTI L. IACHINI 160 Willow Mill Park Road Mechanicsburg, PA 17050 Plaintiff v. RICHARD J. IACHINI, JR. 2901 Society Hill Drive, Apt. 110 Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLE~S CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-2993 CIVIL TELM IN DIVORCE PBAECIPE TO T~aWS~IT RECORD To the Prothonotary= 1. Grounds for divorce= irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of complaint~ July 1, 2002 by Certified Mail. See Exhibit "AC attached hereto and made a part hereof. 3. Date of execution of the affidavit of consent required by S3301(c) of the Divorce Code= by Plaintiff, September 12, 2002~ by Defendant, September 19, 2002. Related claims pending~ None 5. Date Plaintiff's Waiver of Notice required by §3301(c) of the Divorce Code was filed with the Prothonotary= Contemporaneously with the filing of this Praecipe. 6. Date Defendant's Waiver of Notice required by ~3301(c) of the Divorce Code was filed with the Prothonotary= Contemporaneously with the filing of this Praecipe. Respectfully submitted, 310 W. Chocolate Avenue Hershey, PA 17033 (717) 533-4868 ID #23178 Date t O'~--O~ Attorney for Plaintiff PHONE: 717-533-4868 LAW OFFICES A. MARK WINTER 310 WEST CHOCOLATE AVENUE HERSHEY, PENNSYLVANIA 17033 July 1, 2002 FAX: 717-533-2582 mailed via certified mail 7-1-02 Mr. Richard J. Iachini, Jr. 2901 Society Hill Drive Apt. 110 Camp Hill, PA 17011 In Re: Iachini v. Iachini Dear Mr. Iachini: Enclosed is a true and correct copy of the Divorce Complaint filed by Patti L. Iachini on June 21, 2002 in the Cumberland County Court of Common Pleas. You should take this document to your attorney as soon as possible. Very truly yours, df Iachini Eno. EXHIBIT "A" · Complete items 1, 2, and 3. AJso complete item 4 if Restricted Delivery is desired. · Pfln~ your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mallptece, or on the front if space permits. Mr. Richard 9. Iachini, Jr. 2901 Society Hill Drive Apt. 110 Camp Hill, PA 17011 A. Received by (P/sese Pdnt Clearly) 3. S~vice Type [] Certified Mall [] Registered [] Insured Mail Date of Derive [] Agent [] Address~ [] Express Mail [] Retum Receipt for Merchandi= [] C.O.D. 4. Rsetr~ted Delivery? (Extra Fee) [] Yes 2. Article Number (Copy from sew/ce/abe/) PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-09~. IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF PATTI L. IACHINI Plaintiff VERSUS RICHARD J. IACHINI, JR. Defendant PEN NA. NO. 02-2993 PLeas CIVIL Decree IN DIVORCE AND NOW,~ ~ DECREED THAT PATTI L. IACHINI ~E~~ IT IS ORDERED AND , PLAINTIFF, aND RICHARD J. IACHINI, JR. , DEFENDANt, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORd) ~N THIS ACTION FOR WHICH a FINAL ORDER has NOT YET BEEN ENTERED; ~1~O -- ATTEST: · PROTHONOTARY IN THE COURT OF CO[~MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs. ~Defendan/ IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the _g day of OC~f ~.0~ , hereby elects to resume the prior Surname of ~ Lsd ~Ci$~ ., and gives this written notice pursuant to the provisions of 54 P.S. ~ 704. -~gnature of name being ~eesum--~-- COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS. Notary Public, personally appeared the abov~ affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, seal. I have hereunto set my hand and official