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Home My WebLink About00-02055 - "~ . . . "'''' "':f.'" . . '" Of. "':Ii . . . . . . . .ltc";'! I I 1: I 'I ii " . . IN THE COURT OF COMMON PLEAS . . . OF CUMBERLAND COUNTY . STATE OF PENNA. . . . . . . . . . WOLFGANG M. SEYBOTH, . PLAINTIFF No. 00-2055 CIVIL TERM . . . . VERSUS ESTER LEDEZMA, . . DEFENDANT . . . . . DECREE IN DIVORCE . . . . AND NOW, ~4A ~~ t Q , ~ IT is ORDERED AND ~M. SEYBOTH DECREED THAT , PLAINTIFF, ESTER LEDEZMA . . . . AND , DEFENDANT, . . . . 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 . . . . ATTEST: J, . . . . . . OTHONOTARY . . . . . . . "'''':Ii''' . . . . . . . , .~ ~,_, ~v '. ~. ~ ",. "'-'~ :-. .:.' '" ." ." 7./9'a/ M~ ~lb 4 ~ /'/~.m 5r1~~ <:;~ ~ .-1lI,~".,..,."., ~t..!f"1'" -"",' ':"'~1'''' , ~'~,.' -I~~~-.""""''''''''''' , ,"""", ,~...,.. I~ ,,' ','~";'~I '_.0,.'1 , ' ~ >' n.,' " ' ,..", .', ~'~,-,'"n""_ " ,', "~' '~~: , WOLFGANG M, SEYBOTH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS, : NO, 2000-02055 ESTER LEDEZMA, Defendant CIVIL ACTION-LAW IN DNORCE PRAECIPE TO THE PROTHONOTARY: The Social Security Number of the Plaintiff is 202-76-5852, and the Social Security Number ofthe Defendant is 467-95-8527, Respectfully submitted, PURCELL, KRUG & HALLER BY " '~,~ I,' ",' '''' ,,', ,'-'-- ,,--"," """",~"-',;"", -~"',-'.-' "-"',"',", - ""~ , , WOLFGANG M. SEYBOTH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2000-02055 ESTER LEDEZMA, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 (X) 3301(c) of the Divorce Code. 2. Date and manner of service ofthe Complaint: Certified Mail on March 19, 2000 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: Jnly 8, 2000 by Defendant: July 7, 2000 (b) (I) Date of execution of the Plaintiffs Affidavit required by Section 330 l( d) ofthe Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. (a) Date and manner of service ofthe notice of intention to file Praecipe to transmit record, a copy of which is attached: (b) Date of Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: Filed contemporaueously herewith Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Filed contemporaneously herewit Rtf " ~ ""'" ,,=~ ~,'"..,~ ~iii" "~~,o:..~' ;, ,"',:..:..", ,-,,', - 0 0 Ci c: 0 '-'fj s::: c.... --- ""Or,e; c:: ''';'', ri-/rn C- -, 2:-" -"-,' n 63!i~:: " r:::) r" , , '~ ;:S -=::.., -", (J t-c> -0 "I', )>t-, :;::T! ;:;;:c c., ~ 1'", PC' ;~~ U ;:;;:,-1 2: - =< :.lJ <:0 -<; ~ '~"",~-.- ,-- ... ... WOLFGANG M, SEYBOTH, Plaintiff VS, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 60 _ ;;ZOS'-S' C'O~( c../~ ESTER LEDEZMA, Defendant 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 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 Court Administrator, Cwnberland County Courthouse, Hanover Street, Carlisle, P A. 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, Cwnberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ."" -~ lll'lIllri - - WOLFGANG M, SEYBOTH, Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. Iff) - ,;2 0 5'5 t{!~e,('!r:~' ESTER LEDEZMA, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT 1, The Plaintiff Wolfgang M, Seyboth, is an adult individual whose residence is 40 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania 17055, 2. The Defendant Ester Ledezma, is an adult individual whose residence is 40 Robin Court, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3. The Plaintiff has been a bonafide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint, 4. The Plaintiff and Defendant were married on February 28, 1997, in Carlisle, Pennsylvania, 5, There have been no prior actions of divorce or annulment between the parties. 6, The Plaintiff avers that there are no children of the parties under the age of 18. ,~ , -' "" " 7. The Defendant in this action is presently a member of the Armed Forces. 8. The Defendant is a citizen of the United States. 9, The Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to a divorce decree being handed down by the court. 10. The pfaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken, WHEREFORE, the Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, PURCELL, KRUG & HALLER BY . Purcell, Jr" Esquire 1.D, 29955 ~ 9 North Front Street Harrisburg, PA 17102 (717) 234-4178 ~~~ " ,', $i;llllill, ~ ." VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. 13 4904, relating to unsworn falsification to authorities, Dated: 3<)Y- CO ~ ~ 1i~' ~, \ ,'~,,\ Wolf a g . Seyboth -. WOLFGANG M. SEYBOTH, Plaintiff : IN THE COURT OF CO.MMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS. : NO. 2000-02055 ESTER LEDEZMA, Defendant CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE CO.MMONWEAL TH OF PENNSYLVANIA ) ss: COUNTY OF DAUPHIN I, JOHN W_ PURCELL, JR., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 19th day of March, 2000, I sent, by certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to Defend and Claim Rights to Ester Ledezma, the Defendant in the above action. The return receipt, duly signed by the Defendant is attached hereto and made a part hereof as Exhibit "A". Sworn and subscribed to before me thiso1tMday of !ftJ/ZIL ,2000. ~C'~ INotary Public ' NOTARIAL SEAl BARBARA A. SHADEl., Notary PubHc Harrlsburg, Dauphin County My Commlsslon ExpIres March 17, 2003 < ~ ~, . Complete items 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 mail piece, or on the front if space permits. 1. Article Addressed to: \55~y \-~d.~"2-"""o-.. L\~ "y3\()\\i", (.ou.Yl- - fb:~ \ '->\Y\ ~QSP~~6s'Y; o Agent AdO see O. Is. delive!)' address different from Item 1? 0 'res 3~' :ntGZta;;;$S~V IZ- ~ NQ 1~ /o);i.uJ tv,"'ri3IfRJ- A-AlO [-14- 17010 3. Service Type ,;g:certified Mail 0 Express Mall o Registered 0 Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~Yes ....'" 2. Article Number (Copy from service label) '\()0?\"D'-\QO 00'02:> ~\Q "'60\') PS Form 3811, July 1999 pom~~~ Ret.urn Receipt " Ii i-i Uti n U i j ;: d . -, 102595'99'M-17~~_ u.s. PosfuLservice _ ''- oY-::'~~'---- ~ " CERTIFIED MAIL RECEIPT . _ . . (Domestic Mail Only; No InsuranC4,cOllerage" ~{?,,?cf~'l'-' "; , ... .-'I ~ r:~y l--e9,C-z,.: rn .-'I ru '" !,o~tage $ CerllfiadFee rn o o o o o '" rn Return Receipt Fee (lfndcirsement Reqllin~d) _&strlct$d Delivel)',Fee (Endorsement ReqUIred) IT' IT' 0" ... L-. ?os1mark H,", I ! $ <>~,~ 'if:: Exhibit" AU lIiIliillllij' '~.~ILI;WiI M;l~!I!ll!l-~"'" ~ "~ ~lil.llUi'-L---""'" ~,"~^ , >~. ,,,>. ,~, ...''''~'" " ~,. , ~~ -~~ 0'" ~ liilIi!lId. L", ",. (....... C:'.: ~; C-' ----C;r:;::, S2~;: ~-:::.c Ci}., ' s:C ~i.;~:-,. .J>t; -,. '=j --<~ -~..j - r-~~j :"-'1 - ~ "' ---~ "" _,~il,;,.-iLJ~~ , ~ .,- '--. WOLFGANG M. SEYBOTH, . Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS, NO. 2000-02055 ESTER LEDEZMA, Defendant CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT I " I i ~ 1. A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on April 4, 2DOO, 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 notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301 (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 enter~d 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !i 4904 relating to unsworn falsification to authorities. Date: 7-8-00 ~' 'e"" "J., <0"":""': I. 'JW,uu ,.1Ilitl~11ili'l~11.lIl!il!m~' .-"~,,",,~,,---,, ,~ .- ~=~~ ._~,,~. ~ ~" ,~ :~;.j, ',~ '-,,<;,,":,--, -' ,,~ (') C -aifi ill,r.", :Z-" : "",,::t. ~r- (FJ"f.: r>"" ~"--' ::S;_. 2{.,.I """C Pc! ~ 0;> ",.-..'"' ',.." ~ . a <::> c::; j'- o ~'n -' " ~."~ r" '. , i::::':~ -";"'-j 1"--.,:", "l:J ~~,," -----"'. <-~~~ ~~ z;~< F~ " -' x' -< r:-2 .!l - ~~"l,,, '.I~', . , . - .- WOLFGANG M. SEYBOTH, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2000-02055 ESTER LEDEZMA, Defendant CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the divorce Code was filed on April 4, 2000. . 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 notice of intention to request entry of the ,decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301(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 after it is filed with the prothonotary. I verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. !i 4904 relating to unsworn falsification to authorities. Date: 717 2-80<> ~~"g~ i <'..;':" ;' "'iillif ;<'...."IIIfiIlll~l!iI~~"i.' '1<"-- '~' .......~ 'lllllil!.*" . 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