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Home My WebLink About07-0501Ivelisse Alemany Martinez, Plaintiff V. Michael Vega Castro, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-5o1 CIVIL IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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, High and Hanover Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Ivelisse Alemany Martinez, Plaintiff V. Michael Vega Castro, Defendant CIVIL ACTION - LAW No. 07-501 CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Ivelisse Alemany Martinez, an adult individual, who resides at 1101 Lindholm Court, Apt. 111, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Michael Vega Castro, an adult individual, who resides at HCO1 Box 8644, San German, P.R. 00683. 3. Plaintiff is a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 3, 2001 in Mayaguez, Puerto Rico. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: AAas 2y -2&q- Respectfully submitted, ROMINGER & WHARE i Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 93334 Attorney for Plaintiff Ivelisse Alemany Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Michael Vega Castro, No. CIVIL Defendant IN DIVORCE VERIFICATION 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: r,. f Ivelisse Alemany Martinez, Plaintiff Ivelisse Alemany Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION - LAW Michael Vega Castro, No. CIVIL Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Michael O. Palermo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Michael Vega Castro HCO1 Box 8644 San German, P.R. 00683 Dated: -iA4 u ?. Michael O. Palermo, Jr., Esquir 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 93334 Attorney for Plaintiff C) fA 7' L r!) 77 Q i ? y O, - j t R --i '? Ivelisse Alemany Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Michael Vega Castro, No. 07-501 CIVIL Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Michael Vega Castro, hereby accept service of the Complaint in Divorce in the above- captioned action and I certify that I am authorized to do so. DATE: By: Michael V astro Defendant Jr . G ON Ivelisse Alemany Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Michael Vega Castro, No. 07-501 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 24, 2007 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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 unsworn falsification to authorities. Date: Ivelisse Alemany Martinez, Plaintiff t7 C:) r-• m t'3 F? 1, "L1 Ivelisse Alemany Martinez, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Michael Vega Castro, No. 07-501 CIVIL Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 24, 2007 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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 unworn falsification to authorities. Date: 44? Mich ega C tro, Defendant r -?s ON Ivelisse Alemany Martinez, Plaintiff V. Michael Vega Castro, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-501 CIVIL 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 after 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 unworn falsification to authorities. Date: elisse emany Martinez, Plaintiff 1-1 q } ?,: t-1 Ivelisse Alemany Martinez, Plaintiff V. Michael Vega Castro, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 07-501 CIVIL 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 after 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 unsworn falsification to authorities. Date: ichael Ve as tro, 16 efendant `'' _ ra ?; r `s ? ? ? ? .?- "?"?? -t7 4? ti ? 3 ?: ? '?^ G + ? ° Ivelisse Alemany Martinez, Plaintiff V. Michael Vega Castro Defendant CIVIL ACTION - LAW No. 07-501 CIVIL 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service on June 7, 2007. Attached as Exhibit "A". 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff, December 10, 2007 ; by the Defendant, December 10, 2007. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 21, 2007. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 21, 2007. Date: December 21, 2007 t4? 1 0 Michael O. Palermo' Jr., Esq 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 81924 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c ? ? '-Cl {T" t? A C-1 CrN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Ivelisse Alemany Martinez II NO. 07-501 civil Plaintiff VERSUS Defendant DECREE IN DIVORCE AND NOW7_, IT IS ORDERED AND DECREED THAT Ivelisse Alemany Martinez , PLAINTIFF, AND Michael Vega Castro , 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 BY THWrJCOU ATTEST:- J J. PROTHONOTARY oor 6a. ?j?-/