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HomeMy WebLinkAbout98-06399 ~ , \l ~ ~ .., ~; .., > \,... " " ;:! Cl "( "'~ ( ... ~ ........ .-3 \S ~ ~ l\') ~ c;., ~ loll, loan - complalnl-in div~rc' Novombor 12. 1098 JOAN L. LOTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. DIVORCE NO. 98. L 1)' i'i CIVIL TERM IN DIVORCE V5. RAFA CASTENE, JR., Defendant COMPLAINT IN DIVORCE JOAN L. LOTZ, Plaintiff. by her attorneys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., respectfully represents: 1. The Plaintiff is JOAN L. LOTZ, who currently resides at 245 Allen Road, Carlisle, Cumberland County, Pennsylvania, where she has resided since September, 1998. 2. The Defendant is RAFA CASTENE, JR., whose last known address is P. O. Box 3212, Prescott, Arizona 86302 since July 14,1998. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 5, 1997, at Carlisle, Cumberland County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code, loll, joan - complaint in dlVDrcn Novomtlor 12, 199B 7. Plaintiff has been advised of thB availability of marriage counseling and of thB right to request that the Court require the parties to participate in marriage counseling. and does not request counseling. WHEREFORE. Plaintiff requests the Court to enter a decree of divorce. FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: M! , / .r: . " ,-_. Carol J.'Dindsay, Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 Date: k };) /2- /11~( .' VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. )..'.! r / , ,~ Joan L. Lotz Date: }I -I, ,. . (' " ',' ~6 , , :1 "t:J l' ~ pc - ~ ~'" " ~ t!I I'. ! f' ~i7' " .. .. r"'. ~~~ " :;:v ',"j i.l;> -;-, (' .. '~ 0" . , ' ~ :-:) .. -I \fn:: i r' Ul ( ~) .....:,: ~ ~ -~ I=~: -,J 0) (I ~1iln i r- -() \) ~ ~: /jj ,.~.-) 0- 0:", . -1'\ -I '" (;J "1 (1'\ >=Re " c" ~N ~ ;.- .+. -<: :, F ~ k!i':'7):.",:;'o:'i;:',' ..;~:":, ' LAW omens .;d:> SAIDIS, SHUFF. FLOWER & UN.\lSAf ;~:,'":"',"": 26 w. HIGH mtBBT 1111'1 MARKEl STRU:r .i:",~,,_C.UUJL8.'A nOIJ CAMPIIlu.,'4 1101' PtfOHI(,n)24U212 rJtONF.171'Jl 'Jll.J405 CI!KTII'1Il0 COPY, . . JOAN L. LOTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. DIVORCE : NO. 98. 6399 CIVIL TERM V5. RAFA CASTENE, JR., Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint in Divorce in the above captioned matter Lt- 9- 0 ) Date " l,~,. y~_:- Rata Castene, Jr., Defendant SAIDIS SHUFF, FLOWER & LINDSAY ATrORNEYS'AT"lAW 26 W. High Street Carlisle, PA ,1 I" , I ,~ ~ -,; I 1\,; I' , . . ~ ,. ~. l ;t) /1<'" If<F I" /I'}[ . I .-~" , I I ,-: i I. .' , , . :' , , .. . uN C , ~n~i1 JOAN L. LOTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. DIVORCE : NO. 98. 6399 CIVIL TERM V5. RAFA CASTENE, JR., Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 5 3301 (c) of the Divorce Code was filed on November 12, 1998 and reinstated on March 12, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notk:e of intention to request entry of the Decree, I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, 4904 relating to unsworn falsification to authorities, ~ "" ..j} 1.- 0'\. 01 ~oan L, Lotz, ~intiff Date: 9 ( ~z/o I , WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~301 Ie) OF THE DIVORCE CODE SAlOIS SHUFF, FLOWER & LINDSAY ATrORNEVSoAToLAW 26 W. High Street Carlisle, PA 1, 2. property, 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 imrnediately after it is filed with the Prothonotary, I consent to the entry of a final Decree of Divorce without notice. I understand that I may lose rights concerning alimony, division of lawyer's fees or expenses if I do not claim them before a divorce is I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C,S. 4904 relating to unsworn falsification to authorities. ~~ L1~~intiff Date: 9 /8>% )." I . / JOAN L. LOTZ, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. DIVORCE : NO, 98. 6399 CIVIL TERM '/ , . /4' . .r "!,JJ 1(,1. I.,.:l.~':':"- Rafa Castene, Jr., Defendant V5. RAFA CASTENE, JR., Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under 5 3301 (c) of the Divorce Code was filed on November 12,1998 and reinstated on March 12,2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: 4- '1- C> I WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~301lc) OF THE DIVORCE CODE SAID IS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. PA 1. 2. property, 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 consent to the entry of a final Decree of Divorce without notice. I understand that I may lose rights concerning alimony, division of lawyer's fees or expenses if I do not claim them before a divorce is I verify that the statements made in this Affidavit are true and correct to the best of rny knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. (- " 1(. \~ 1<1f.... &';t:::-- Rafa Castene, Jr., Defendant ,. I Date: .<1 -9- "'~I ~ APR I fj 2001 ! I ;'. ! ~ J r' ,. ( - , .. : i " '. ..:.:. ~ !:..:- , " ( - : , .' ::;1 c;::. :";i.t ;," .' . \ JOAN L, LOTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. DIVORCE NO. 9B. , . ,/or \ CIVIL TERM \.1 , )1 - IN DIVORCE VB, RAFA CASTENE, JR., Defendant NOTICE 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 Jose money or property or other rights important to you, including custody or visitation of your children. 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, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 A VENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 By: FLOWER, MDRGENTHAL FLOWER & LINDSAY, P.C. Attorneys for Plaintiff fk{~'la~ Carol J. pnd;rv' Esquire' ID # 44693- 11 East High Street Carlisle, PA 17013 (717) 243-5513 . ' " 1- I Date: /fTV i/. /111( - loll, loan - complalnlln dillOrco November 12. 1998 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce, FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C, Attorneys for Plaintiff By: l Carol J, 'ndsay, Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 Date: k 1 . ,& /2-- /11f. I ~ <:J ~:5 N .. ~J!': (') :l!:: U"~ T~ " '.... ')"" (,. i;;:! ~f 'n :5 "J .'l~ , .. .~: - Ii fii '-if! fo: 1:'0: ....1. .l III ' .~.: ':C ~. .sj !5 (;) G . , ~ Iii ~ ~ ~ ~ ~~~~ ~ ~ 5! c c olJ ~ ~ ~ ~ llll _ ~ e ~ .. lEo Ofil ~ r.:- ! g N:Il ~ ...~~ S ~.; ~ ~" :I: l:l,; N..-: w. <:l ttl _... .. 5 ~ E:e" ~ ~ ~ i~ (IJ l!l , .