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Home My WebLink About00-00964 , , . . . . .. . :Ii :Ii ;ti:ti,Ii:f.:ti ... . . . "'iIi,'"'' :Ii '" . . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . . . . PENNA. STATE OF JANE E. MENDEZ, . . Plaintiff No. 2000 - 964 CIVIL TERM . . . . . . . VERSUS ADALBERTO MENDEZ, Defendant . . . . DECREE IN DIVORCE . ~ 2;(2-P)l\; "ji"f'b, IT IS ORDERED AND . . . . AND NOW'~ (8 . . Jane E. Mendez DECREED THAT , PLAINTIFF, . . Ada1berto Mendez , DEFENDANT, AND . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . 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 . . :Ii :Ii'" '" . . . o~ "' '1 PROTHONOTARY . . . . . . . . :Ii"':Ii :Ii :Ii:li :Ii "'''' :Ii :Ii . ~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .. III C:o---- Ie;( . .;zo ,tV J;i 'dO'.~ ~--~ "" ,'0 ,_ .,.. U""".<,.,."~""..,, ,.^,"-~.'~~ ,~- "."..,.~..> , ~ -~,,, ,.,,'. . <-.<", ..,~~ - ~-~ ~~ . ,\...' . \" ; ,~ " ~,~ "cO Ced~~jJ~~4~ ??k~~1#' "~~_ JII!III!!IIIll! ~~, - " ,,~ <~^;" '--' - , ,;', . ,<'" .',. Ii " .. ~'- ,-, , .' ' ,~- ,;:,.S ',- '" 'C,-.~c""',_' ';"0'- ~,"~; ,1.>-.; ,~,"":'" JANE E. MENDEZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA v. : NO. 2000 - 964 CNIL TERM ADALBERTO MENDEZ, Defendant : CNIL 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 ( ) 330l(c) (XX) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: February 26, 2000 by certified mail number Z 448 660 652. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 330l(c) of the Divorce Code: by Plaintiff: ; by Defendant: (b) (I) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: October 2, 2000. (2) Date of service of the Plaintiffs Affidavit upon the Defendant: October 14, 2000. 4. Related claims pending: None. <'- oj, ~ ,.; _'.' ."__ '"'_ 0 . 'f " ' ". " " ,),. "~'b":::~:'-''':;bl;:~i,:'''-J. ".."__, ._ , , ",~,' 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: October 14, 2000. 6. Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(c) of the Divorce Code: or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff: ; by Defendant: and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce Decree: . JAMES, SMITH, D ONNE LP Date: I~ -1- 00 ""..-. ~" - 1- ,~" I" "IY_. JANE E. MENDEZ, PLAINTIFF : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 2000 - 964 CIVIL TERM ADALBERTO MENDEZ, DEFENDANT : CIVIL ACTION - LAW : IN plVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE (i TO: Adalberto Mendez, Defendant 803 North Second Street, Apt. 2 Harrisburg, PA 17103 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the Section 3301(d) Affidavit. Therefore, on or after October 21, 2000, the other party 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 of a Counter-Affidavit by the above date, the court can enter a fmal Decree in Divorce. A Counter-Affidavit which you my file with the Prothonotary of the court is attached to this notice. 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. The filing of the form Counter-Affidavit alone does not protect your economic claims. 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 - ~~........... ,.-,1 ilii" OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 I , 1 I i'l " I:.! ;.1 , !:j I: I !",i !::i . coim~~Y, ., Esquire/' e orP . ti Post e Box Hershey, P A 17033 (717) 533-3280 PALD. No. 15615 ',j 1,.1 j !:i :1 I I ,'I i'i " " I' .) II "'I :, ;., , , < J., JANE E. MENDEZ, PLAINTIFF : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 2000 - 964 CIVIL TERM ADALBERTO MENDEZ, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, John 1. Connelly, Jr., Esquire, of James, Smith, Durkin & Connelly, attorney for the Plaintiff, Jane E. Mendez, hereby certifY that I have served a copy of the foregoing Notice of Intention to Request Entry of Divorce Decree, 3301(d) Affidavit, and Defendant's Counter- Affidavit Under Section 330l(d) of the Divorce Code on the following on the date and in the manner indicated below: U.S. FIRST CLASS. CERTIFIED MAIL Adalberto Mendez, Defendant 803 North Second Street, Apt. 2 Harrisburg, P A 17103 JAMES, S:MITH, DURKIN & c;ONNELL Y ) X~ By: .- ~ JoM 1. onnel1y, J~ Esquire ,'-- Attokey or Pl!Untiffi ( \ \.'-:::J , Post Q ce Box oJ-O -"---/ Hershey,PA 17033 (717) 533-3280 P A LD. No. 15615 DATE: t () - ~ -DO JANE E. MENDEZ, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 964 ,CIVIL TERM ADALBERTO MENDEZ, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE 1. Check either (a) or (b): _(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 years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(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 of expenses ifl 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 of other important rights. !;"""'-""' " . , - . I'~ ~- 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. 4904 relating to unsworn falsification to authorities, Date: Adalberto Mendez, Defendant 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. " -,-I -~~,- ~'! JANE E. MENDEZ, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000 - 964 CIVIL TERM ADALBERTO MENDEZ, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE NOTICETOTHEDE~NDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated since August of 1998, 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! 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. III ....j -'i/'. Date: I {i -;-,,"~ .- [i v , /l C" .-777. . , ".. ',' ", /,,' , ,.. ". ~?/:-:--U:Z- '../ .A:,.'";;r7<(~t:~ -1 ane'!. Mendez, Plaintiff . j '--.----' -' ilIiillJl .!MiiI_~- K.l~l.m;\fJ~ " ~. _" ,..~ 0' .,.. .,~ ' " ,,~ -..""""""'..~,~" , ._,- ,,~ ~ ,,' ~ Jj ~' .h:I 1.<,0 - ..~ -, ~ OM 'd~''- ",j b (."? 0 c: 0 -" s::: 0 :;:,~ ,"om 1"" r~'l:n 111m n ,f f-- 2::n I ''(]m ZI;:;: "'0 (,<)-'7 <Jl or ~t:j -{!? ",. '1"" . ~Q :J1: 03 .';;",0 ;>0 OITl c: '.-1 2; """ ~ =< -..J -< . - , ,'1~' ," <', ~",. _, ;. .,~' .,',',. , - -">J,:,;"'::':,, JANE E. MENDEZ, Plaintiff v. :: IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : NO. ..1000- q(".'1 Ci,-,~l '-r~ ADALBERTO MENDEZ, Defendant : 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 papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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, One Courthouse Square, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 " " "~, . -" "~ 'r. c ~ JANE E. MENDEZ, Plaintiff v. :: IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA : NO. .;l.tJtJV. 9 (,'/ CM.I "'/ b-- ADALBERTO MENDEZ, Defendant : CIVIL ACTION - LAW : IN 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 Common 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 Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this 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 ,." ' _ ,_0 ~- ,,~~;q:;~.(";:, JANE E. MENDEZ, Plaintiff v. :: IN mE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA ; NO. iLb-vV. q(P'f~ -r.u-.- ADALBERTO MENDEZ, Defendant : CML ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Jane E. Mendez, who currently resides at Jane E. Mendez, 1203 Gross Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Adalberto Mendez, who currently resides at 803 North Second Street, Apt. 2, Harrisburg, Dauphin County, Pennsylvania 17113. 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. Plaintiff and Defendant were married on August 23, 1996, in Mechanicsburg, Pennsylvania.. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. "f"" .,. -,",";'.' '\ 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. The parties to this action have been separated since August of 1998. WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant. JAMES, SMITH, DURKIN & CONNELLY Date J, -j/p-OO ""-'"'::-:,:::"'T:~-~> ,~' " ~ VERIFICATION I verify that the statements made in this Pleading 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: .1-I&-Of) ~M!:~ij .. ,', '", , ~.- ,'<<- " ",-,~ '.' , ,,',~-.:,-, ,? " =~ ..~'. >,,_;C "''''''' :,,,,'; I j'" ~,< ,un'_ , .~ ~ ~ ~ w ~ ~ ...... ~ ~ h,Vi ~ 8 ~ I I \...I ~ ~ ~T l~ ..c (;? 63 ,," ,,' ,,,,",1 'CO ' (2 C:''::, {:) {;) (::~l ;-j ?-:: 4, ,. , -r.J U ""1 ',':',1 n" .' ::rJ ':'T; "":..- '~,l~J U::. CD -, ~- -j f< ~, ~.~"'j . . , ~':_- 5'~~ ,", )..-- ~~-'l :.;; " ='"-=], ~ "''0 ,0 '< 4, ,. , ~,' ,." -',,1,.',;'-- - JANE E. MENDEZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-964 Civil ADALBERTO MENDEZ, Defendant : CML ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA : ss. COUNTY OF DAUPHIN , rd / AND NOW, this( g day of ':7'7d?/?//I./ , 2000, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Complaint in Divorce was served on the Defendant, Adalberto Mendez, on February 26, 2000 by certified mail number Z 448 660 652, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and subscribe before ~ this ~ day or/I ~ ,2000. c ~ci~ ~'Jdf Notarial Seal Stephllllle LGatley. ~ PubI~ic HummeIsloWn BolO, Il8Uphin My commission Expires Sept. 2l!. 2 Member. Pennsytvanla AsSOCIaIlon 01,,,, . 'lL" ~"' 'ok' 'Co~plet~ it~~s 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 mailpiece, or on the front if space permits. 1. Article Addressed to: c. x vitia (btY'lz; /'?O?& z j'IJ vt:rJA 02/l<<Sd vPd c2 ~/!5'j~ ;::;/1 /7//';; D. Is delivery address differ t from item 1 If YES, enter delivery address below: 3. Service Type ri ~ertified Mail 0 Express Mail 6 Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. . 4. Restricted Delivery? (Extra Fee) }if Yes 2. Article Numb~Copy from service label) . , ,~,il./?{~ 6~(J, (,ti'c2:., PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 - , "-'~'~'''"'I' 'I_M~'" r """.'=,--. 'Jll~~~ -;..", .-. . ~ ~~ -..'-, '."""""""j . '. ;"'''''''-'1 0 0 ,-, ,~ ~ a 'n :1:: ~"I rHOJ :r- ~:fiE~~ m :;0 2::0 653i -"1 , "- ,:~~iT' ~o >::;c, ::~ ._'E~ :;1 )> 4...4i.,. ~o 20 >8 r:? (5r71 ."1 2 ",. 2: ~ :;? !!l: - ~., , ,0 '~.I . . JANE E. MENDEZ, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - 964 CIVIL TERM ADALBERTO MENDEZ, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE 1. The parties to this action separated since August of 1998, 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! 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: / ~ -d, - {jO . d~e~cP~ . . 0 ;:::J C) C CJ " ~ a -oct (-) 7') rn[,E' ---I Z_.1_,' ;:'1 &; S;~ a ~> -< ~;. ~c' v v :;:'2 ~ 2:C-- .. ,;,,----:; ~(-) N fC1 >e: 0 2: Ul Si :< :"1) co -< ~ "" "- '" 1<-': -'-" JANE E. MENDEZ, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA ;NO. .;20DO - q~<{ C!to':( TVu-t ADALBERTO MENDEZ, Defendant : CML ACTION - LAW : IN DIVORCE PRAECIPE TO ENTER SOCIAL SECURITY NUMBERS TO THE PROTHONOTARY: Please enter the following social security numbers in the above-captioned divorce action: Jane E. Mendez 477-68-6350 Adalberto Mendez 200-76-1402 JAMES, SMITH, DURKIN & CONNELLY LLP Date: J -112 -00 By: Jo A Post Box 650 Hershey,PA 17033 (717) 533-3280 PA J.D. No. 15615 c c. C C) ,~ =2'" '-' ,'I vU: ..., u_i nlr~-l "~t~ ~!= t:;a (7', r> ~ "',) ~'~3.' -' .. ",. .. ~'-I ." -<,' '.;:) " <""' -I. / JANE E. MENDEZ, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-964 CIVIL TERM ADALBERTO MENDEZ, DEFENDANT : CML ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF DAUPHIN AND NOW, this /4Jl day of ~)u , 2000, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Notice of Intention to Request Entry of Divorce Decree, Defendant's Counter-Affidavit and Plaintiff's Affidavit was served on the Defendant, Adalberto Mendez, on October 14,2000 by certified mail number 70993400000929160953, addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and subscribed before me this fql:L day of jjl~JU, 2000. NOTARIAL SEAL Jean L. Kosier, Notary Public City of Hummelstown,County of Dauphin My Commission Expires Feb. 9, 2004 I - , '",,""~-'- , . " .. Complete items 1, 2, and 3. Also complete item 4 jf 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 mailpiece, or on the front if space permits, 1. Article Addressed to: 3. Service Type )lcertified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail >--,~ 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 2, . A, rt, iC~,eN N,X "'}1fmbjter {fj(.;oog ".~f~~lm.se" Nice fa, belj , ", Iii !.~~~ ~~n4R/~ jtJ<ttf8!, il 'PS -Ferm 3811, July 1999 Domestic Return Receipt flYJAI..-t3EUD mE. /JDEZ- ~ D '0 /JOt.nt ~tJD St. ftPT J, J../fJ I!.J:lj/?;U e4} PA 111D3 '~Yes 102595-99~M-1789 _.._J ... " ''--....:ol.> ,_ ~ , ~ "o.~,,, ,,;,'~ "~. "Ill:. ~- ~ "M """,...J.., ~ . - ~~, 0 C) C::-. c....,. 7" c:l -Dr;~ ;;'; QJ1.'j-~ ;?:-=: '" C<2 C - ,- / -~ 'i; (J ::; ~z: ,~ J> ~, '1 c: 2 :< \l , .'"'1 ~