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HomeMy WebLinkAbout03-0968oomin o ye a Plaintiff VS. cion ye a Defendant NOTICE TO DEFEND AND ~ RIGHTS You have been sued ~n court. ~f you wish to defend against the daims set forth in the following pases, you muSt take prompt action. You are warned that ~f you fail to do so, the case may proceed without you and a decree of d~vorce or annulment may be entered againSt you by the court. A judgement nmb, also be entered a~sinst you for any other claim or relief requeSted in these papers by the p~aintiff. You nmy lose money or property or other fights important to you, including custody or visita6on of your children. When the ground for the &vorce is indign½ties or irretrievable breakdown of the msrr~age, may request marriage counseling. A list of marriage counselors is available in the OfSce c Prothonotary at _ IF YOU DO NOT FII25 A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AlqNULMENT IS GRANTED, YOU MAy LOSE Ti~ lU~ TO CLAIM '~Y OF ~ YOU SHOULD TAKE THIS pAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANN~ AFFORD ONE, OO TO OR TIR~HONE THE OFFICE SET FORTR BELOW TO FIND OUT WHE~ YOU CAN G~ LEGAL H~LP. Address~ Phone 2~..3- 653-862~ CIVIL DIVISION COUNTY, PENNSYLVANIA NO. COMPLAINT IN DIVOR(~E PIJI~VANT TO 23 PA.C.S.A. ~ 3301 1. ThePlaintiffis ~x'~r~ [)e~,~.!~-~gg~ Hill state Prison, P.O. Box 200, Camp I~l, PA 17001-0200. 2. The Defendant is CO.~C_e?c_~t~,~ d%os. , who currently resides at Camp , who currently resides at The Plaintiff does not know the latest address of the Defendant. The name and address of the Defendant's nearest relative and/or other person who would be likely to know the whereabouts of the Defendant are: 4. The Plaintiff and Defendant were married on~r~x~t~l~ ~ , at $. The Ph~'~tiff~ resided withi~ this Commo~we~Jth for at le~t six montes immediately prior to the ~ommenCement of this clivoroe action. 6. The De£endant h~ resided withi~ this Commo~we~& £or at le~t six mo~ths immediately prior to the CommenCement of this divorce action. 7. The ?l~ttiff ~ks a divorce based upo~ the following 8rounds: [CIRCLE LETTER(S) WHICH ARE THE GROUNDS YoU ARE SEEKING THE DIVORCE ON] a. Willful and malicious desertion, and absence from the habitation of the injured and innocent spouse, without reasonable justification or any cause for a period from to b. Adultery. o c. The Defendant knowingly entered into unlawful bigamous marriage, while the former marriage is still subsisting. d. Cruel and barbarous treatment that endangered the life of the Plaintiff or the health of the injured Plaintiff. (~The Plaintiff or the Defendant has been convicted and sentenced in a court of law to a term of imprisonment of more than two years. f. The Defendant offered such indignities to the innocent and injured spouse, so as to render the spouse's condition intolerable and life burdensome. To the best of the Plaintiff's knowledge, information and-belief, there has not been any previous action of divorce filed either in this Commonwealth or any other state. The Plaintiff does have knowledge of a pending divorce action filed in County, . Case Caption Case Number 10. The Plaint~has been advised of the availability of counseling and that either party has the right to request that the Court require the parties to participate in counseling. W~REFORE, the Plaintiff request that the court enter a decree of divorce. Plaintiff; Pro Se`/ In.stitution Number SCI - Camp Hill P.O. Box 200 Camp Hil!~ PA 17001-0200 IN TIIE COURT OF COMMON ~S OF (~~(~ CIVIL DIVISION , COUNTY, PEI~ISYLVANIA VS. u De d . NO. VERIFICATION I, .~)~ a}r~ Oe._~% , hereby verify that I am the Plaint~herein and as such v'~y that th~ information oontain~l in th~ fOrgoing p~tition is true and ~ormot to th~ b~st of my knowledge, information and belletl. This verification is made subject to the penalties of 18 Pa. C.S.A. § 4904, relating t° unswom falsification to authorities. Plaintiff~ Pro,ge~ ' In~tution Number /'~. ,,~ .~::',.~ ~'.~ SCI - C~p ~ P.O. Box 2~ C~ ~ PA 17~1~2~. IN THE .COLrKT OF COMMON PLEAS OF ~,~J~ ~ COUNTY, PENNSYLVANIA CIVIL. ACTIO ..N:- LAW CERTIFICATE OF SEI~VICE. hereby Certify that i have this date served a copy of the [oI,~, ~ on the person and in the manner stated below which service satisfies the requirement of Pa I~C.P. 440. PEKSON SEKVED: PLACE OF SERVICE:_ DATE OF SERVICE: METHOD OF SERVICE: Please check one: Hand Delivery or Certified Mail Date: Pro Se IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Domingo Vega C NO. Plaintiff : : VS. : : Concepcion Vega ~ Defendant 03-968 NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT FOR APPROVAL OF DIVORCE GROUNDS If this is a case under Section 3301(c) of! the Divorce Code (where Affidavits of Consent have been filed), you are hereby given notice that twenty days following the mailing of this Notice, a Praecipe to Transmit Record, together with a proposed Order Approving Divorce, will be filed in this matter with the Clerk of the Family Court. If this is a case under Section 3301 (d) of the Divorce Code (based upon separation of the parties), you are hereby given order that twenty days following the mailing of this Notice, a Praecipe to Transmit Record together witi~ a proposed Order Approving Divorce, will be filed in this matter with the Clerk of Family Court. Exact copies of the Praecipe and the proposed Order are enclosed herewith. After the Praecipe and proposed Order are filed, you will have a period of ten days which you may file objections to the entry of the Order based upon the Praecipe. If you dispute any of the information on the Praecipe or the Order, you must act within that ten-day period. Any objections must be filed in writing with the Clerk of Family Court. If no objections are filed before the expiration of the ten-day period, this case will be submitted to the Court for entry of an Order Approving Divorce. Date:~. ~, ~ /p~l_a~n~~ y~ a~ntif-f' THE COURT 0 ' '~, s colvnv o co y. C~ ACTION - LAW ) DEFENDANT PRAEC~E TO TRANSMIT KECORD To The Prothonotary: Transmit the record, ' ':' ' · · . ' ' ' divorce decree: together with the followm~ i~on:~tion, to the court for entry of a I. Ground for. divorce: irretrievable breakdown under § C3~8a~ (3301(d)(1)) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: ~. (Complete either par~Fh (a) or (a) Date of ~e~fion of~e ~t of cogent req~ed by ~ 3301(c) of~e Divorce Cqde: by defen~t 5. (Cbmplete either (a) or Co).) (a) Date and manner of service of the notice of/nten~on to file praec/pe'to transmit record, a copy of which is attached: _ ~:e. ~ /~ ~ 200~ C~ ~ ~A md, I Co) Date plaintiff's Waiver of Notice in § 3301(c) Divorce was flied with the prothonotary: Date defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: IN ~ COURT OF COMMON PI,~.&S OF CUMBERLAND CO~{'r~, PENNSYLVANIA CTC~ DIVISION Dominqo Ve~ : Plaini~ : ; VS. : : Concepcion Veqa : D6mdant. AFFIDAVIT NO. Civil Term 1. Both the Plainfiffand the Defendant to this a~tion separated on March 3 1 9 9 8and have covth~_,~ to live separately for a period of at least two (2) years, 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer fees or other expense, ifI do not claim them prior to the divorce being granted by the court. I v~lfy that the statements made in this affidavit are tree and corral. I unde~-~iand that any fals~ statements made in this affidavit are mb~eet to the penalties provided in 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Dated: ~ Plainlifl~ Pro S~~' ' P.O. Box 200 Camp Hill, PA 170014)200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION pomingo Vega Plaintiff VS. Concepcion Vega Defendant NO. ~3-968 Civil Term CERTIFICATION I, hereby certify that in accordance with Cumberland County Local Rule 1920.73, I served upon opposing ]party ten (10) days notice of my intention to file a Praecipe to Transmit Record in the above-captioned matter and a copy of the Praecipe to Transmit. A true and correct copy of my Notice of Intent to File Praecipe to Transmit Record is attache(] hereto, made a part hereof, and marked Exhibit "A"./ Date: Plainti f f~lSro IN THE COURT OF COMMON PLEAS OF_ ~--~e,-~,[ COUNTY. PENNA. p TIFF VS. DEF4~NDANT NO.: 768 CIVIL ACTION - LAW IN DIVORCE ~OTICE OF INTENTION TO REQ[~ST ENTRY OF § 3301(d) DIVORCE DEC~R~ TO: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 3301(d) affidavit. Therefore, on or after _/~$,,S~ , 20~ , the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and'you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, C4D TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ;(Name) (Street); (Ci~ty)' (State) (Telephonej · Complete itemsl, 2, item 4 If Restdc'tacl Deliver~ · Print your name and address on the reverse so that we can return the card tQ you. · Attach this card to the back of ~he mailpiace, or on the front If space permits. I 2. Axtl¢le Number PS Form 3811, August 2001 Domestic Return Receipt Agent D. Is deli~y address different from item 17 If YES, enter c~ivery address below: [] No ~.~,ertifled Mall [] ~cpre~ Mall I'1 Registered [] Return Receipt fo~ I"1 Insmad Mall [] C.O.D. 4. Restitct~d Deliver? (Extra Fee) [] Yes [Postage & Fees Pa d IUSPS I LPermit No. G-10 Please print your name, address, and ZIP+4 in this box · ,~h- ~'J ~ 7 IN The COURT OF COMMON PLEAS OF CUMBERLAND COUiNTY STATE OF ..~. PENNA. DOMINGO VEGA AK-8357 PLAINTIFF VERSUS CONCEPCION VEGA DEFENDANT DECREE iN DIVORCE AND NOW, /~// 7* decreed THat b0~l~l~0i{~) V~el~O~ ARE DIVORCED FROM THE BONDS OF MATRIMONY. , ~'~J~// , IT IS ORDEREd AND , 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; : BY The COURT: IN TI-IE C0[rKT OF COM2vlON PLE~S OF_Cumber land. COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Dom~ngo Vega ,) PLAINTIPF ) MS ) NO. 03-968 Concepcion vega ) DEFENDANT PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, ' ':' ' · · ' · ' divorce decree: together with the following informa~on, to the com~ for entry ora 1. Ground for. divorce fi-retrievable breakdown under § (~ (3301(d)(1)) of the Divorce Code. (StaSke out inapplicable section). 2. Date and m,n~er of service of the complaint: January 21, 2003 Certified Mail 3. (Complete "~er para~"~h (a) or ~o). (a) Date of execution of the, .affidaMt of cement required by § 3301(c) of the Divorce Co. de: by defendant Co)O) Date of execution of the smdavit required by § 3S01(d) of the Divorce Code:.. Jan. 21, 2003 (2)' Date o?ilng and .~ervic.e. of the plaintiffs Affidavit upon the re~pb'ndent: ~4ay 1 2003 4. Related clmrn.~ pending: ... ~one ' ~ (Complete either (a) or (b).) (a) Date and m~nner of smwice of the not/ce orient/on to file praedpe to tran.~mit record, a copy of whlch is attached: _May 12, 2003 Certified Mail (b) Date plaint~s Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary:. _ Date defendant's Wa/ver of Notice in § 3301(c) Divorce wm~ filed with the prothonotary:.