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HomeMy WebLinkAbout03-0386MARY PATRICIA RAVIDA Plaintiff VS RAYMOND F. RAVIDA, JR. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - DIVORCE NOTICE TO DE~'END 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 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 first floor in the Dauphin Court Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S ~ES 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 HARRISBURG, PA 17101 1-800-990-9108 ~ pATRICIABAVIDA f plaintif VS RAlq4OND F. RAVIDA, JR. Defendant THE COURT OF CO~4MON pLeAS CUMBEP~AND CoUNT~, pENNSYLVANiA CIVIL ACTION - D~voRCE · .ff Mary patricia ~avida' b~.her OW. comes the ~lalnt= 'ire, and pursuant ~t~::~°n AND N_ % ,..4Aa Sourers, Esqu --de seeks =o v~- _ upon =~_~ =, Ga~l ~'-- .-----4 Divorce ~u , ~ ~ Ravida, or., a=u~'ue~ -~ the pennsy~v~"-~ ~--~-nt, Ra~monu =' · - 'Ca is an adult i~di~dual _ patriclaRav~= ~ ~,:.~ cumberlan= 1. The Plalnt=~f~7~sZt~ pitt streeu, residing ac County, pennsylvania 17013- 2. The Defendant, Raymond F. Ravida, Jr., is an adult individual residing at 1297 Kuhn Road, Boiling springs, cumberland county, pennsylvania 17007- 3. Plaintiff and Defendant have been bona fide residentS of the commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint- 4. The Plaintiff and Defendant were married on December 9, 1989 in prospect, Pennsylvania' · of the availabili~-~f request .~= ~=~ been adv=sed _ ~ ~ave the r~gnu to 5. Pla=nt=~ "- that Plaintlf£ .ma~_~',A participate in counseling a:~ require the paru=e~ ~- ~ that the Cou request the same. counseling and does not 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member of the United States Armed Forces. 9. The Plaintiff and Defendant have no minor children 10. The cause of action and Section of Divorce Code under which Plaintiff is proceeding is the marriage is irretrievably broken under 23 Pa. Const. Stat. ~ 3301 (c) . WHEREFORE, The plaintiff requests this Honorable Court to enter a Decree of Divorce. Gail Guida Souders Attorney for Plaintiff Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 Supreme Court ID # 68740 are true and correct. this ..o~ .~ - -- that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities- ATTORNEY FOR. r., ...... that the statements made in I understand MARY PATRICIARAVIDA Plaintiff VS RAYMOND F. RAVIDA, JR. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - DIVORCE : : NO. 03-386 Civil Term CERTIFICATE OF SERVICE I hereby certify that on January 27, 2003, I served the Divorce Complaint upon the person and in the manner indicated below, which service satisfies the requirementsof Pennsylvania Rule of Civil Procedure. 403: First Class U.S. Mail: Ra~mond F. Ravida, Jr. 1297 Kuhn Road Boiling Springs, PA 17007 Gall Guida Souders Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 717-236-6440 Dated: January 29, 2003 MARY PATRICIARAVIDA Plaintiff VS RAYMOND F. RAVIDA, JR. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - DIVORCE : : NO.O~-?U~. C~.vil ACCEPTANCE OF SERVICE I Raymond F. Ravida, Jr. accept service of the Complaint in Divorce Date MARY PATRICIA RAVIDA Plaintiff VS RAYMOND F. RAVIDA, JR. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - DIVORCE : : NO. 03-386 Civil Term 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 3301 (c) of the Divorce Code. Date and manner of service of the Complaint: January 27, 2003 by First Class U.S. Mail. (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce code: by the plaintiff May 2, 2003; by defendant April 30, 2003. 4. Related claims pending: No other claim pending. 5. Date and 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 (dO (1) (i) of the Divorce Code. o Date of Plaintiff's Waiver of Notice in Section 3301 (c) Divorce Code was filed with the Prothonotary: May 5, 2003 Date of Defendant's Waiver of Notice in Section 3301 (c) Divorce Code was filed with the Prothonotary: May 5, 2003 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NO. 05-586 Civil Term MARY PATRICIA RAVIDA VERSUS RAYMOND F. RAVIDA, JR. Decree IN DIVORCE AND NOW,~ DECREED THAT ,~11~ ~l? IT IS ORDERED AND , PLAINTIFF, AND ~aymond ~. ~avida: Jr. , 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; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff vs. Defendant File No L~ ~ CIVIl- /~i~/~ IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the . / ~ day of ~~7_[~0 ~ , hereby elects to resume the prior surname of P '~f?__JC!/~ /~/L~-- , and gives this written notice pursuant to the provisions of 54 P.S. S 704. igna e J/na~/ ~ S ~ e being resumed COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND : On the _~ ;~ daYaOf .~ ~ · ~0~ before me, a Notary Public, personally ppeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. seal. In Witness Whereof, I have hereunto set my hand and official ~ CLAUDIA A. BREWSAKER NOTARY PUBLIC I I Carlisle 8oro, Cumberland County J I My Commission Expires April 4, 2005 ~