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HomeMy WebLinkAbout02-4500TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. ~" d'/l~"~ Or. : CIVIL ACTION - LAW : 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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 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, Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania 17013. 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. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 TAMARA J. PETRUCCI, Plaintiff NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe romar accion con prontitud, se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede set emitido en su contra por las Corte. una decision puede tambien ser emitida en su contra por caulquier otra quej a o compensacion eclamados pot el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, One Courthouse Square, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE OF THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 (717) 249-3166 TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301{D) OF THE DOMESTIC RELATIONS CODE And now comes Plaintiff, Tamara J. Pet~ucci, by and through her attorneys, Law Offices of Craig A. Diehl, and files this Complaint in Divorce, respectfully stating in support thereof the following: 1. Plaintiff is Tamara J. Petrucci, an adult individual who currently resides at 208 Norman Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Nicholas J. Petmcci, an adult individual who currently resides at 2104 Wentworth Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both the Plaintiff and the Defendant have been bona fide residems of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Divome Complaint. 4. Plaintiff and Defendant were married on September 13, 1997, in Cumberland County, Pennsylvania. 5. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since July 5, 2002. 6. There have been no prior actions of divorce or for annulment between the parties. allies. 7. Defendant is not a member of the armed forces of the United States or any of its 8. Plaintiff avers that the marriage is irretrievably broken. 9. Plalntiffhas been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce. LAW OFFICES OF CRAIG A. DIEHL ;dina e~ ' iCD1 ~foe.1 ~e~¢ 6E~ qu~ r e -u ~4 ~4dma~?i~ie REad Camp Hill, PA 17011 (717) 763-7613 Attorney for Plaintiff TAMARA J. PETRUCCI, Plaintiff YS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I, TAMARA J. PETRUCCI, verify that the statements in the foregoing DIVORCE COMPLAINT are tree 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 unswom falsification to authorities. Date: TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4500 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Linda A. Clotfelter, Esquire, counsel for Plaintiff, Tamara J. Petrucci, do hereby affirm that the original return receipt of the Complaint in Divorce sent by Certified Mail, Restricted Delivery, Return Receipt Requested, which return receipt appears to contain the signature of Nicholas J. Petmcci, is set forth below. The undersigned understands that the statements herein are made subject to the penalties of 18 P.S. § 4904 relating to unswom falsification to authorities. NICJ-t-OL 5 ..[. l rguC, z..'Z Form 3811, JuN 1999 Domestic Return Receipt Dated:~ LAW OFFICES OF CRAIG A. DIEHL L-~da A.-C~offelter, Esquire ~4~6~m;nY. nI~l eN;~ 7ad2963 Camp Hill, PA 17011 (717) 763-7613 TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-4500 CIVIL TERM ; : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this /~ day of O ~,_'~O ~ ,2002, the undersigned hereby certifies that a tree and correct copy of the foregoing AFFIDAVIT OF SERVICE was served upon the opposing party by way of United States first class mail, postage prepaid, addressed as follows: Nicholas J. Petmcci 2104 Wentworth Drive Camp Hill, PA 17011 LAW OFFICES OF CRAIG A. DIEHL By: J.,t~/~ l l~----~'~l~t..~,'~ 3464 T~dle Road Crop Hill, PA 17011 (717) 763-7613 TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4500 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 18, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 notice of intention to request entry of the decree. 4. I understand that I may lose fights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 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. Date:/-~O' O-~,~ ~ TAMA1La, ]. P~-~R0-~C~I, Plaintiff TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4500 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE iDECREE UNDER § 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 fights 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 tree 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: -P aintiff TAMARA J. PETRUCCI, Plaintiff NICHOLAS J. PETRUCC1, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4500 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 18, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 notice of intention to request entry of the decree. ' 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 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 unswom falsification to authorities. Date: NICH I, Defendant TAMARA J. PETRUCCI, Plaintiff VS. NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4500 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 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 aker 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 unswom falsification to authorities. Date: NICH~~RUCCI, Defendant TAMARA J. PETRUCCI, Plaintiff NICHOLAS J. PETRUCCI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-4500 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THEPROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce 2. The Complaint was filed on September 18, 2002. 3. Date and manner of Service of the Complaint: September 28, 2002, by Certified Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the Affidavit of Service filed on October 2, 2002. 4. The Plaintiffs Affidavit of Consent was executed by the Plaintiff on January 30, 2003, and filed on February 3, 2003. The Defendant's Affidavit of Consent was executed on January 27, 2003, and filed on February 3, 2003. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on January 30, 2003, and said waiver was filed on February 3, 2003. Defendant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on January 27, 2003, and said waiver was filed on February 3, 2003. agreement. There are no related claims pending. The parties have resolved all related issues by oral Respectfully submitted, LAW OFFICES OF CRAIG A. DIEHL Date: B( Lin'~a A. Clotfelter, Esquire k,.~Att, ol~ey I.D. No. _72963 3-4'64 Trindle Road Camp Hill, PA 1701 l (717) 763-7613 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF TAMARA J. PETRUCCI~ Plaintiff VERSUS NICHOLAS J. PETRUCCI, Defendant PeNNA. NO.O2-4500 CIVIL TERM AND NOW, DECREED ThAT DECREE iN DIVORCE T~~ARA~TRUCCI NICHOLAS J. PETRUCCI , IT iS ORDERED AND , PLAINTIFf, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURiSDICTiON OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD 1N THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; NONE BY f: ~ROTHONOTARY ~o. ~! - c