HomeMy WebLinkAbout96-02790
NAN<.:Y PORTILLA,
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IN TilE COURT OF COMMON PLEJ~S _,
CUMBERLAND COUNTY. PENNSV';'VANIA"'"
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NO. 96.2790 CIVIl. TERM
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LAUREANO PORTILLA,
Defendant
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CIVIL. DIVORCE
COUNn~R.AFFIJ)^ VIT IJNDEI{ SECTION 330Hd)
OF TilE I>IVOI{CE COD.:
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1. Check either (a) or (b):
_X_ (a) I do not Oppose the entry of a divorce decree,
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both):
(I) The parties to this action have not lived
separate and apart for a period of at least
two (2) years,
(Ii) The marriage is not irretrievably broken,
2. Check either (a) or (b)
_X_ (a) t do not wish to make any claims for economic
relief. 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,
(b) I wish to claim economic relief which may
include alimony, division of property.
lawyer's fcc's or expenses or other important
rights,
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I NANcy A. PORTILLA,
i I Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO,
LAUREANO PORTILLA,
Defendant
CIVIL ACTION - DIVORCE
You have been named as the Defendant in a divorce proceeding
filed in the Court of Common Pleas of CUMBERLAND County. This
notice is to advise you that in accordance with Section 33021d) of
,i the Divorce Code, you may request that the Court require you and
i, your spouse to attend marriage counseling prior to a Divorce Decree
~: being handed down by the Court. A list of professional marriage
i counselors is available at the Domestic Relations Office, 13 N.
I Hanover Street, Carlisle, FA. You are advised that this list is
kept as a convenience to you and you are not bound to choose a
I i counselor from the list. All necessary arrangements and the cost
: I of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request
for counseling within twenty (201 days of the date on which you
Ii receive this notice, Failure to do so will constitute a waiver of
! your right to request counseling.
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN NAMED DEFENDANT:
Prothonotary
, ,
IAWO'Fll")IW
GARY L. KELLEY
Ul.l'w WA1.NUT S'TMHT
HARRISBURG, PA 11101
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NANCY PORTIl.l.A,
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IN TIn: ('()lIRT (H' COMMON PLEAS
('III\IIU:KI.ANU C()lINTY, PENNSYLVANIA
V.
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I.AI/R.:ANO PORTII.I,,\.
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nVII, . IlIVORn:
C()lINn:R.t\t'...U,\VIT IINIU:R S.:CTION 3301/111
m '1'1": UIVORO: (QJll;
I. ('h~~k I,lIlher (II) or (b)
x (II) I do Illlloppose Ihl,' elllly Ill' a dlvor~~ de~rtlC
(b) I uppuse Ihe ~lIl1y Ill' a dlvor~,~ de~l'~e b~~aase
((,he~k (II, (lIlllr bUlh)
(I) The purlle~ III Ihls a~IIOll hav~ 1101 lived
s~parul~ ami apar! fllr a p~riod of at leasl
IWII (2) years
(II) Th~ llIarrlage IS 11111 rrrelnev"hly broken,
Z. Chu~k either la) Ill' (b)
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(II) I du 1101 wl,sh III llIak~ allY duil11s for e~ollol11ic
rdler I IInderslallll lbal I llIay lose rights
~l,lncellllllg alllllony. dlvlslun Ill' property,
Inwyer's fNs or espenses I I' I do 1101 dallll
Ihelll berore a dlvlIr,e IS grail led
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(b) I wish III dnlln econOIllI~ reli~f which may
,ndade 1I1illlUllY, dlVisioll uf property.
hIWyds fees or expenses or olher impor!unt
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND fOUNTY, PENNSYLVANIA
V.
NO. 96.1790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint in the above-captioned matter on behalf of the
Defendant and hereby certify that I am authorized to do so.
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NANCY PORTIl,LA,
Plaintiff
I IN TilE COURT OF COMMON PLEAS
CUMBERLAND C:OlJNTY, PENNSYLVANIA
V.
NO. 96.2790 CIVIL n:RM
LAUREANO PORTILLA,
Defendant
CIVIL, . IHVORn:
CERTIFICATE OF SERVIU
i. GARY L, KELLEY. Esquire, attorney for Pl.AINTlFF in the above.captioned mailer.
do hereby certify that I served a true and correct copy of the Complaint in Divorce upon
DEFENDANT by an Acceptance of Service executed by the Defendant on April 8, 200S:
By:
GARY L
1.0. #46
1119 North Front Street
Harrisburg, P A 17102
(717) 238.1484
Attorney for Plaintiff
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(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete di~covery,
DATE
COUNSEL FOR PLAINTIFF
COUNSEL FOR DEFENDANT
NOTE:
PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL S'rATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION,
AF'I'ER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING 'rHAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BO'l'H COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IMMEDIATELY,
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
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tAW OFFICES OF
GARY L. KELLEY
132-134 WALNUT STREET
HARRISBURG, PA 17101
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I YOU HAVE BEEN SUED IN COURT. If you wish to defend against
I 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
1 proceed without you and a decree of divorce or annulment may 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.
NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q.(,.. :,l 790 c.w:JI U^'"'-
v.
LAUREANO PORTILLA,
Defendant
CIVIL ACTION - DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
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, Cumberland County Courthouse, 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
I OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
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COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE, 4TH
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013-3387
(717) 240-6200
FLOOR
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LAW OffiCES OF
GARY L. KELLEY
132-134 WALNUT STREET
HARRISBURG, PA 17101
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NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
NO.
LAUREANO PORTILLA,
Defendant
CIVIL ACTION - DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN NAMED DEFENDANT:
You have been named as the Defendant in a divorce proceeding
filed in the Court of Cornmon Pleas of CUMBERLAND County. This
notice is to advise you that in accordance 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 Decree
being handed down by the Court. A list of professional marriage
counselors is available at the Domestic Relations Office, 13 N.
Hanover Street, Carlisle, PA. You are advised that this list is
kept as a convenience to you and you are not bound to choose a
counselor from the list. All necessary arrangements and the cost
of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request
for counseling within twenty (20) days of the date on which you
receive this notice. Failure to do so will constitute a waiver of
your right to request counseling.
Prothonotary
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NANCY A. PORTILLA,
Plaintiff
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II LAUREANO
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v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
No. 9(. .2? 90 GvJ 71~
PORTILLA,
Defendant
CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 3301(0) OR 3301 (d)
OF THE DIVORCE CODE
I TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, Nancy A. Portilla, by and through
her attorney, Gary L. Kelley, and represents as follows:
COUNT I
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I drive,
DIVORCE UNDER SECTION 3301(0) OR 3301 (d)
OF THE DIVORCE CODE
1.
Plaintiff is Nancy A. Portilla who resides at 1424 Bradley
Carlisle, Cumberland County, and has resided there in excess
of six (6) months.
Drive, Carlisle, Cumberland County, and has resided there in excess
2. Defendant is Laureano Portilla who resides at 1424 Bradley
of six (6) months.
3. Both Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six (6) months immediately
I previous to the filing of this Complaint.
LAW OFFICES OF
GARY L. KELLEY
132-134 WALNUT STREET
HARRISBURG, PA 17101
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4. The Plaintiff and Defendant were married on June 25, 1966
in Cuba.
5. There have been no
prior
actions
of divorce or for
I
annulment between the parties.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff requests the court to enter a decree of divorce.
COUNT II
EQUITABLE DISTRIBUTION
9. Plaintiff repeats and realleges the averments of
paragraphs 1 through 8 which are incorporated by reference herein.
10. Plaintiff and Defendant possess various items of both
real and personal marital property which is subject to equitable
distribution by this Court.
distribute the marital property after an inventory and appraisement
WHEREFORE, Plaintiff requests this Court to equitably
has been filed by the parties.
lAW OFF1CES OF
GARY L. KELLEY
132-134 WALNUT STREET
HARRISBURG, PA 17101
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lAW OFFICES OF
GARY L. KELLEY
J2-134 WALNUT STREET
-IARRISBURG, PA 17101
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Respectfully submitted,
LAW OFFICES OF GARY L. KELLEY
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint in the above-captioned matter on behalf of the
Defendant and hereby certify that I am authorized to do so.
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
CERTIFICATE OF SERVICE
I, GARY L. KELLEY, Esquire, attorney for PLAINTIFF in the above-captioned matter,
do hereby certify that I served a true and correct copy of the Complaint in Divorce upon
DEFENDANT by an Acceptance of Service executed by the Defendant on April 8, 2005:
By:
GARY L
I.D. #46
1119 North Front Street
Harrisburg, P A 171 02
(717) 238-1484
Attorney for Plaintiff
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty (20) days after this affidavit has been served on you or the
statements will be admitted.
AFFIDAVIT UNDER SECTION 330Hd)
OF THE DIVORCE CODE
1. The parties to this action separated in May 1996 and have continued to live
separate and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
3. 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.
1 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:
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
X (a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both)
(i) The parties to this action have not lived
separate and apart for a period of at least
two (2) years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_X_ (a) I do not wish to make any claims for economic
relief. 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.
(b) I wish to claim economic relief which may
include alimony, division of property,
lawyer's fees or expenses or other important
rights.
I verify that the statements made in this counter-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:
Laureano Portilla
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you need not file this counter-affidavit.
NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - 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:
I. Ground for divorce: Irretrievable breakdown under Section 3301 (d) of the
Divorce Code.
2. Date and manner of service of the Complaint: By acceptance of service on April
8, 2005.
3.
a.
Date of execution of the affidavit required by Section 3301(d) of the
Divorce Code: 5/5/03.
b. Date of filing and service of the plaintiffs affidavit upon the respondent:
9/16/04 by first class mail.
c. Defendant signed a verified counter-affidavit on 9/24/04 agreeing to the
entry of a divorce decree and waiving all claims for economic relief. This same document was
filed with the prothonotary on 10/08/04.
4. Related claims pending: No other claims are pending.
5. Date and manner of service of the notice of intention to file praecipe a copy of
which is attached: 1/31/05 by first class mail.
LAW OFFICES OF GARY L. KELLEY
Date:
Gal)! L. elley
10 l'o 4 801
132-1 Walnut Stre
Harrisburg, PA 17101
(717) 238-1484
Attorney for Plaintiff
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NANCY PORTILLA,
Plaintiff
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE .. .. . ..
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1. Check either (a) or (b):
_X_ (a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both):
(i) The parties to this action have not Jived
separate and apart for a period of at least
two (2) years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
_X_ (a) I do not wish to make any claims for economic
relief. 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.
(b) I wish to claim economic relief which may
include alimony, division of property,
lawyer's fees or expenses or other important
rights.
Law Offices of
Gary L. Kelley
1119 North Front Street
Harrisburg, Pennsylvania 17102
(717) 238-1484
Fax (717) 238-1761
September 17, 2004
Laureano Portilla
1424 Bradley Drive
Carlisle, P A 17013
Re: Portilla v. Portilla
Dear Mr Portilla:
Please find enclosed a 3301(d) Affidavit and Counter-Affidavit. You must file a response
within twenty days.
Thank you for your attention to this matter
Very truQours,
Jf. L. Kelley
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
LAUREANO PORTILLA,
Defendant
NO. 96-2790 CIVIL TERM
CIVIL - DIVORCE
NOTICE
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If you wish to deny any of the statements set forth in this affidavit, you 1}1jr$~ fil<?j;i
counter-affidavit within twenty (20) days after this affidavit has been served on YO~;or t~
statements will be admitted. '-:; .t:..
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AFFIDAVIT UNDER SECTION 3301(d!
OF THE DIVORCE CODE
1. The parties to this action separated in May 1996 and have continued to live
separate and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights COncerning aJimony, division of property,
lawyer's fees or 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:
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I verify that the statements made in this counter-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:
Laureano Portilla
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you need not file this counter-affidavit.
NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
NOTICE
AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
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1. The parties to this action separated in May 1996 and have continued to Jive
separate and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
Jawyer's fees or 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:
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 3301( d)
OF THE DIVORCE CODE
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1. Check either (a) or (b):
_X_ (a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both):
(i) The parties to this action have not lived
separate and apart for a period of at Jeast
two (2) years.
(ii) The marriage is not irretrievabJy broken.
2. Check either (a) or (b):
_X_ (a) I do not wish to make any claims for economic
relief. I understand that I may lose rights
concerning alimony, division of property,
Jawyer's fees or expenses if I do not claim
them before a divorce is granted.
(b) I wish to claim economic relief which may
include alimony, division of property,
lawyer's fees or expenses or other important
rights.
I verify that the statements made in this counter-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:
9/2'//:;y
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Laureano Portilla
NOTICE: If you do not wish to oppose the entry of a divorce decre~,and you do not wish to
make any claim for economic relief, you need not file this counter-af'fidayit.
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Law Offices of
Gary L. Kelley
1119 North Front Street
Harrisburg, Pennsylvania 17102
(7]7) 238-1484
Fax (717) 238-1761
January 31, 2005
Laureano Portilla
1424 Bradley Drive
Carlisle, PA 17013
Re: Portilla v. Portilla
Dear Mr. Portilla:
Please find enclosed a Notice of Intention to enter Divorce Decree. I will enter a divorce
decree in the above matter on or after February 24, 2005.
Thank you for your attention to this matter.
NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
TO: LAUREANO PORTILLA
You have been sued in an action for divorce. You have failed to answer the Complaint
or file a Counter-affidavit to the Plaintiffs Affidavit. Therefore, on or after February 24, 2005,
Plaintiff can request the Court to enter a final Decree in Divorce.
If you do not file with the Prothonotary of the Court an Answer with your signature
notarized or verified or a Counter-affidavit by the above date, the Court can enter a final Decree
in Divorce. Unless you have already filed with the Court a written claim for economic relief,
you must do so by the above date or the Court may grant the divorce and you will lose forever
the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE
WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE.
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.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURT HOUSE
FOURTH FLOOR
CARLISLE, P A 17013
(717) 240-6200
Gary~
ID o. 4
132- alnut Street
Harrisburg, PA 17101
(717) 238-1484
ATTORNEY FOR PLAINTIFF
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IN THE COURT OF COMMON PLEAS OF
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Plaintiff
CIVIL ACTION - LAW
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NO .96 - 2790
CIVIL
19
LAUREANO PORTILLA
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Defendant
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96 - 2790 CIVIL
LAUREANO PORTILLA,
Defendant
IN DIVORCE
TO: Gary L. Kelley
Attorney for Plaintiff
Ron Turo Attorney for Defendant
DATE: Wednesday, October 9, 2002
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
LAUREANO PORTILLA,
Defendant
No. 96-2790 CIVIL TERM
ORDER OF COURT
AND NOW, this 10th day of February, 1999, upon
consideration of Plaintiff's Petition To Request That Case Not
Be Dismissed, and no answer having been filed to the Petition
and Rule To Show Cause issued by this Court on October 27, 1998,
and the Plaintiff's counsel, Gary L. Kelley, Esquire, having
appeared in court for the argument on the Petition, and no
person having appeared on behalf of the Defendant, the Rule To
Show Cause issued on October 27, 1998, is made absolute, the
case is stricken from the purge list, and the matter shall
proceed as an active case.
By the Court,
GARY L. KELLEY, ESQUIRE
132-134 Walnut Street
Harrisburg, PA 17101
For the Plaintiff
RON TURO, ESQUIRE
32 S. Bedford Street
Carlisle, PA 17013
For the Defendant
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I~ THE COURT OF COMMON PLE.~ OF
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NANCY PORTILLA
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P1aineiff
vs.
LAUREANO PORTILLA
NO.9 6-2 7 90
19
MOTION
NANCY PORTILLA
a master with respect to the
(x) Divorce
( ) AnnulJllent
( ) Alimony
( ) Alimony Pendente
moves the coure eo appoint
Lite
Distribution of Property
Support
Counsel Fees
Costs and Expenses
and in suppore of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant (has) ~~xjGt) appeared in
(by his attorney, xxxxxxxxxxxxxxxxxxxx
3301 (e) & (d) (3) The. staturory ground(s) for divorce (is)
the action (personally)
,Esquire).
(are)
following claims:
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
(c) The action is conteseed with respect to the following
claims:
(5) The action (~X~) (does not involve) complex issues of law
or fact.
(6)
(7)
The hearing is expected to
Additional information, if
6 hours
take (hours) (days).
any. relevant to the motion:
Dace:
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Esquire,
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NANCY PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
Pi'2_dS'~_ f'J(.;;CL
CERTIFICATE OF SERVICE J:\..J .-f: tc
I, GARY L. KELLEY, Esquire, attorney for PLAINTIFJ -J. O(f:j<-- er,
do hereby certify that I served a true and correct copy of the Rule ReturnabJe datea u~'uv~. 27,
1998 on DEFENDANT by depositing same in the U.S. Mail, first class, postage prepaid, on the
29TH day of OCTOBER, 1998, addressed as follows:
Ronald Turo, Esq.
32 S. Bedford Street
Carlisle, PA 17013
By:
GARY
rD. #46
132-134 Walnut Street
Harrisburg, P A 171 0 I
(717) 238-1484
Attorney for Plaintiff
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NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
LAUREANO PORTILLA,
Defendant
NO. 96-2790 CIVIL TERM
ORDER OF COURT
AND NOW, this 27th day of October, 1998, upon consideration of Plaintiffs Petition
To Request That Case Not Be Dismissed, it is ordered that
(I) a rule is issued upon Defendant to show cause, if any she has, why Plaintiff is not
entitled to the relief requested;
(2) Defendant shall file an answer to the petition within 21 days of this date;
(3) the Petition shall be decided under Pa. R.C.P. 206.7;
(4) depositions shall be completed within 35 days of this date;
(5) argument shall be held on Wednesday, February 10, 1999, at 1l:30 a.m., in
Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania; and
(6) notice of the entry of this order shall be provided to all parties by Plaintiff.
BY THE COURT,
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Gary L. Kelley, Esq.
132-134 Walnut Street
Harrisburg, PA 17101
Attorney for Plaintiff
Ron Turo, Esq.
32 S. Bedford Street
Carlisle, PA 17013
Attorney for Defendant
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NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-2790 CIVIL TERM
LAUREANO PORTILLA,
Defendant
CIVIL - DIVORCE
PETITION TO REQUEST THAT CASE
NOT BE DISMISSED
AND NOW, comes the Plaintiff, Nancy A. Portilla, by and through her attorney, Gary L.
Kelley, and respectfully Petitions this Honorable Court as follows:
1. Plaintiff is Nancy A. Portilla.
2. Defendant is Laureano Portilla.
3. The parties are husband and wife having been married on June 25, 1966 in Cuba.
4. A Divorce Complaint was filed in this matter on May 21, 1996.
5. A the time of the filing, significant marital debt existed.
6. Defendant is disabled and makes little or no financial contribution.
7. As a result, Plaintiff worked two and three jobs to payoff marital debt.
8. Had Plaintiff not worked these jobs, the parties would have been forced to file
bankruptcy.
9. Defendant, to date, has refused to sIgn appropriate consents to complete the
divorce action.
10. The parties have now been separated in excess of two (2) years and Plaintiff
intends to proceed under Section 330 I (d) of the Divorce Code, relating to separation in excess
of two (2) years.
11. Given the financial situation of the parties, it is in the best interest of justice that
this matter not be dismissed.
WHEREFORE, the Plaintiff respectfully requests that this Honorable Court not dismiss
her divorce action.
Respectfully submitted,
Gary L. lley
ID No. 46 01
132-134 a1nut Street
Harrisburg, PAl 71 0]
(7] 7) 238-1484
Attorney for Plaintiff
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NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
LAUREANO PORTILLA,
Defendant 96-2790 CIVIL TERM
IN RE: PURGE LIST
ORDER OF COURT
consideration of the purge list in the above-captioned matter,
AND NOW, this 27th day of October, 1998, upon
and represented that good cause exists for keeping this case on
and Plaintiff's counsel Gary L. Kelley, Esquire, having appeared
in C.C.R.P. 228 requiring a petition for that purpose with
the active list of cases, and that he was unaware of the change
time, upon condition that Mr. Kelley file a petition and
proposed rule to show cause, the case will not be purged at this
proposed rule to show cause in accordance with C.C.R.P. 228 by
3:00 p.m. today.
By the Court,
Gary L. Kelley, Esquire
For the Plaintiff
Laureano Portilla
Defendant, Pro Se
Court Administrator's Office
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NANCY A. PORTILLA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
LAUREANO PORTILLA,
Defendant
No. 96-2790 CIVIL TERM
ORDER OF COURT
AND NOW, this 22nd day of October, 2002, it
appearing that recent docket activity has occurred in the
above-captioned case, the case is stricken from the purge
list, and shall remain active.
By the Court,
Court Administrator
1/-/g-09-
I'Gary L. Kelley, Esquire
For the Defendant
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
NANCY PORTILLA,
No.
96-2790 CIVIL TERM
VERSUS
LAUREANO PORTILLA,
DECREE IN
DIVORCE
AND NOW,
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2"o~-:- IT IS ORDERED AND
DECREED THAT
NANCY PORTILLA
, PLAI NTI FF,
AND
LAUREANO PORTILLA
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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 .
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ROTHONOTARY
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