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Home My WebLink About07-1376JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . No. o-)- / 37 4a Civil Term ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 0 7 ' 13 - Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Janice M. Maldonado, a competent adult individual, who has resided at 619 Liggett Road, Carlisle, Cumberland County, Pennsylvania, 17013, since 2006. Texas. 2. Defendant is Joey Maldonado, a competent adult individual, who resides at Fort Bliss 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. Jersey. 4. The Plaintiff and the Defendant were married on May 12, 2006 in Lakewood, New 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Plaintiff and Defendant are both active duty members of the Armed Forces of the United States of America. 11. Plaintiff has been made aware of her rights under the Servicemembers' Civil Relief Act of 2003, and she is waiving any request for a stay of this matter. 12. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in 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. Janice M. Maldonado, Plaintiff Respectfully submitted, Date: D9 4an Adams, Esquire No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -4 C7 -r? - _ rt w JANICE M. MALDONADO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 1376 Civil Term JOEY MALDONADO, ACTION IN DIVORCE Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Date: C, ICI -(2 Respectfully submitted, J e Adams, Esquire 1. . No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ,V y/) -? 3 JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term : ACTION IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully submitted, Date: 11 , C , Cq lane Adams, Esquire I.D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF n ? o ? ?4 0 A t . a I i7 ?' -r-r? JANICE M. MALDONADO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07 - 1376 Civil Term JOEY MALDONADO, ACTION IN DIVORCE Defendant PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Respectfully Dater /3 aO J Adams, Esquire I /P. No. 79465 W. South St. 4arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF W n ? -- ..: cJ a r 't- %"tj m 0 rv ? ? L JANICE M. MALDONADO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07 - 1376 Civil Term JOEY MALDONADO, ACTION IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on August Lto_, 2006 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I 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. §4904 relating to unsworn falsification to authorities. Date: 2.0NU(v2006 zff'? VJ2 Janice M. Maldonado, Plaintiff C'3 rv PAO N) -7 J?" " s' ` C JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE The undersigned process server, upon oath, deposes and says: I served Joey Maldonado, of Fort Sill, Oklahoma, a copy of the NOTICE TO DEFEND, COMPLAINT IN DIVORCE, PRAECIPE TO REINSTATE, AFFIDAVIT OF SEPARATION, AND COUNTER-AFFIDAVIT in the above-captioned action, as follows: Date Served: 9/05/08 Time Served: 3:00pm Person Documents Delivered to: Joey Maldonado Parking lot of 2312 N. Ft. Sill Blvd. Location where served: Lawton, OK 73507 Signed:-??`' Sworn to and Subscribed before me this ,51b day of , 2008. # 07004480 ? Notary Public :EXP. °5`°"" Q Q ?` OF OK\- mm??u`a??• q T t ?? ^°YR %?.fti - fTr JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): Z_ (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): X (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 or expenses if I 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 or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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: fZ Sepf ;toot ?- Joey Maldonado, Defendant na ° n o 2' te _' to ? r - E _ -' ? Y r-', JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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. 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: ta s e P+ o e Joey Maldonado, Defendant r? [') ? ? ?? =A 'T? _:. ?.? ? ? F- . ..+? JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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. §4904 relating to unsworn falsification to authorities. Date: ,3o sTPT 2.oog Janice M. Maldon o, Defendant Q JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: 3301(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Personal service of both Complaint and Affidavit of Separation on September 5, 2008; by Oklahoma Legal Process Service, Inc., Affidavit of Service filed September 8 2008. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: August 20, 2008. Date of filing and service of the plaintiffs affidavit of separation required by §3301(d) of the Divorce Code on respondent: Filed: August 22, 2008. Served on Defendant: September 5, 2008. Affidavit of Service filed: September 8, 2008. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary, along with an Affidavit of Service: Sent via regular mail to defendant on approximately September 6 2008; defendant signed and returned Waiver of Notice and Counter-Affidavit which was filed on September 12, 2008; Defendant indicated he wanted the Decree to be entered promptly. S Date: to . 4 , 6 D ,One Adams, Esquire I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff -b. ex7 ? f 4=.. 110 a ` JANICE M. MALDONADO, Plaintiff vs. JOEY MALDONADO, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 1376 Civil Term ACTION IN DIVORCE NOTICE TO RESUME PRIOR SURNAME. To the Prothonotary: Notice is hereby given that the Plaintiff in the above matter: X prior to the entry of a Final Decree in divorce. OR after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of CRUZ avowing her intention pursuant to the provisions of 54 P.S. s704. Date: (00ar2-fs 'o .. of Ja Ice . Maldonado Prior Name Janice Signature of Name being resumed. COMMONWEALTH OF PENNSYLVANIA ) ):Ss COUNTY OF CUMBERLAND ) On this, the & A day of "e'- , 2008 before me, the undersigned officer, personally appeared JANICE M. MALDONADOIJANICE M. CRUZ personally known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. s No a Public My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rosa A. Ortiz, Notary Public Carlisle Boro, Cumberland County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries ?? ls? u O 03 ??. "4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Janice M. Maldonado, Plaintiff No. 07 - 1376 Civil Term No. VERSUS Joey Maldonado, Defendant DECREE IN DIVORCE x;33 .M AND NOW, 14 ,- , IT IS ORDERED AND -OX4(AA Janice M. Maldonado DECREED THAT Joey Maldonado AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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. PROTHONOTARY ?? s.? ? .r ? -,5/' :7/