HomeMy WebLinkAbout00-03444
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TOMAS ALBERTO QUINTERO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
DAWN MARY ALEXANDER,
Defendant
NO.
IN DIVORCE
ZP9il, 2000 -3~ //fI' &;./
NOTICE TO DEFEND AND CLAIM RIGHTS
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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.
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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, First Floor, CUmberland County
Courthouse, Carlisle, Pennsylvania 17013.
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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
717-249-3166 or
800-990-9108
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DAWN MARY ALEXANDER, :NO.
Defendant :IN DIVORCE
CIVIL 2000. 3<f''/'I CWJ.. '{L--
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TOMAS ALBERTO QUINTERO,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
:CIVIL ACTION - LAW
COMPLAINT UNDER SECTION 3301(cl OF THE DIVORCE CODE
1. Plaintiff is Tomas Alberto Quintero, who currently resides at
1911 Mary Lane, Carlisle, CUmberland County, Pennsylvania, since
May 16, 2000.
2. Defendant is Dawn Mary Alexander, who currently resides at
1004 Rebecca Street, Carlisle, Cumberland County, pennsylvania,
since 1995.
3. Plaintiff and defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to
the filing of this Complaint.
4. The Plaintiff and defendant were married on September 16,
1997, at Mt. Holly Springs, CUmberland County, Pennsylvania.
5. The~e have been no prior actions of divorce or for 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.
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8. Plaintiff requests the court to enter a decree of divorce.
I verify that the statements made in this Complaint 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:
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TOMA. S ALBERTO QU~NTE ,
Pl~n~~_ p
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WILLIAM S. DANIELS, Esquire
Attorney for Plaintiff