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Home My WebLink About94-00738 :1 ..... ~ , '11. -/. ., I " '11" " .,,1/ II" " " ," ., I " " ., , , ., II "~I' , ',", ,., " ,., ., ,I ., II II' ," , , " ': , , " , " " , , " ,. , . :,fJr'r,' ., I, I' , , " " ~, r'-.) ..... ~ ." , , , , , , ~ '~ ~ .:t ~~J \) ~ J i. ,'i,. a\() " .......... .,.. ,~Il )., ..,'I: .I;' I/! ~S. , ' ,'I " t," .~.e 1'1... ,,~ 1"1 (''J , ~), .~ I::-":l' -yl '":.:.\', ~J "--; ~ C~ f) ~,-;-y ---..... " 'II , ' in' .... 1:1 .... ~~ ""'- \' , ~\ " , , ., , , .. " , , , " I,' '. " ;') " ,1'1 ~' . I'fl)... I '. \ \_'~ .:r "I, ~~ \%) \- . " ..".l !';' ;,,1 " ." ',' , .---.{.. o q ~ ~' i ! I:: I!lH ~ ~. ! I 'I ~ \ iQ ~ ;,:,t. --, ~ ..... ,/, . ,I , '; ~~, ~~ , , l ,\ 'I ,.1,.1 'I, " I,!I ,J., }), ii, , .ti' ',t,'j ,tj \'\,!" ';,w " ., ,. , '" " DO.... A. 'I.aoAL~INI, I I. TH. COURT or COMMO. 'L.A. 'laintiff I CUMlIRLAND COU.TY, .....rLVANIA VI. : "0. '/.,J <;, (y.( 0 (t Jt114. I ,) ,) RICHAaD e. PI.aOALLI"I, I Defendlnt I CIVI~ ACTIO" - DIVOaC. .OTICI TO DI'I"D AND CLAIM RIOHTI YOU HAV. BI." SUIlD I" COURT. If you wish to defend againet 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 or propertr or other rights important to you, including custody or visitAt on of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may ~equest marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland county Court House, Cumberland County Courthouse, One Court House Square, Carlisle, Pannsylvllnia. IF YOU DO NOT F'ILE 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. CUMBERLAND COUNTY C9URT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FL001( ONE COURT HOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 DORIN. A. , XlItGALI.INI , I IN THI COURT or COMMON PLU. Pla1nUff I CUMllftLAlD COUNTY, '.NNIYLVANIA I VI. I NO. I RICHARD .. PIIRGALI.INI, I Def.ndant I CIVIL ACTIOIf - DIVORC. COMPLAINT VND,. .ICTIOIf 3301(0) or 'lIHI "p'IVORCI COOl COQNT N\lMBI...1. 1. PlaintiH is Dorena A. Piergallini, an adult individual residing at 5011 McDonald Drive, Apt 17, Mechaniosburg, Cumberland County, Pannsylvania 17055. 2. Defendant is Richard S. Piergallini I an adult individual residing Penn~ylvania 17053. 3. Plaintiff hilS been a bona fide resident of this at 207 Kings Highway, Marysville, Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Dafendant wera married on March 26, 1985 in Harrisburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 7. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in suoh 2 oounseling. Beinq so advised, plaintiff does not request that the Court require tho parties to partioipate in counseling prior to a Divorce Decree beinq issued by the Court. 8. Plaintiff avers that the ground on which the action i. based is that the marriage is irretrievably broken. 9. plaintiff requests the Court to enter a Deoree of Divorce. COU.or .UNBa. :I 23 fa. C.I.A. 3301 (8) (II) 10. Averments one (1) through (10) above are herein incarporated by reference thereto and made a part of this Count. 11. The Defendant has offered such indignities to the Plaintiff, the innocent Ilnd injured spouse, aD to render her oondition intolerable and her life burdensome. 12. Plaintiff requests the Court to enter a Decree of Oivora'e. COU.or .UNBaR 3 CLAIM POR IQUlorULI DllorltlBUTlO. OP MARITAL PIO.IRT! U.DIR 23 'A. C.I.A. IICTlO. 31101 13. The Plaintiff and Defendant are owners of various items of personal prop'erty, furniture and household furnishinqs acquired during the marriage which are subject to equitable distribution by the Court. 14. The Plaintiff and Defendant are owners of various motor vehicles acquirQd during the marriaqe which are sUbject to 3 equitable distribution by the Court. 15. The Plaintiff and Defendant singly or jointly have interests in various bank accounts acquired durinq the marriaqe which are subject to equitable distribution by the Court. , 16. Plaintiff and Defendant own or have an interest in the followinq real estate which is subject to equitable distribution by the Court l Pennsylvania. 17. The Plaintiff and the Defendant have acquired 207 Rinqs Highway, Marysville, durinq the marriage other marital property which is subject to equitable distribution by the Court. COUIIT IUMBIR , ALJMOllt PIIIDIIITI LIT., COUII81L '118, COlTS AND IXPIIIIII 18. The Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litiqation, and is unable to appropriately maintain herself during the pendency of this action. 19, The Defendant has adequate earnings and resources to provide for Plaintiff's support and to pay her counsel fees, costs and expenses. ""I"'ORI, Plaintiff requests the Court to enter a Decreel (a) Dissolving the marriage between Plaintiff and Defendant I (b) Equitably distributing all marital property owned 4