HomeMy WebLinkAbout98-06574
~,
"
r
<l '
,C)
I
~
)( :
u
E
I 0
I~
I
(
'"
~
.....
.
,
.~
.
<::J
\ ~;
C'-l
i
'-"i
~!
. I
~I
~l
,
.1
~\
, .
)) 5' ~.?
,0,( ~:
/ / ' ,I , .f:' 1./
('; ~., (:1)' 1:(.'," ..f:/ 4' (41~('7 .r.r:.I.-t;7d,...
'/;ltO' /;r,-,J,/ 4- cp
KATHLEEN ANN GOMEZ,
Plaintiff
v.
IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. }tj [,:,'/I( (~{./(I
IN DIVORCE
ANSEL RUIZ GOMEZ,
Defendant
),: '.
; ;:~.
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES 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
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
September 18, 1998 and continue to do so.
8. The Plaintiff has been advised Ihal counseling is availahle .md Ilml Ph,intiff may
have the right to requestlhallhe court require the panics to panieipate in counseling.
9, Defendant is not a member of Ihe anned services:
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
COUNT II - COUNSEL FEES AND COSTS
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as
though set forth in full,
II. Plaintiff has retained the Law Offices of Austin F. Grogan but she is unable to
pay the necessary and reasonable attorneys' fees for said counsel.
12. Plaintiff may need to hire experts to appraise the marital property but she lacks
funds to pay the necessary and reasonable fees.
WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim
counsel fees. costs and expenses and to order such additional sums hereafter may as may be
v
f
.
deemed necessary and appropriate and at final hearing to award such additional counsel fees,
costs and expenses as are deemed necessary and appropriate.
Respectfully submitted,
Date /6j-;-I'd
t' J:' /J
I . (;
f{J4r1t~, /lr(L;c
Austin F. Groga.rt. Esqi1ite
24 North 32nd:Strei)
Camp Hill, PA 1701-1
(717) 737-1956
Attorney for Plaintiff
1.D. #59020
AFFIDAVIT OF SERVICE
STATE OF TEXAS
COUNTY OF ~RIS
I, (arl
x
X
X J' ~I
i~ {( ~~ h #//5
, a Deputy Constable
for Precinct ~1, county of Harris, State of Texas,
certify that on the t day of fl c..
at //:;/ o'clock,4 .M. that I served
Cause number 2{- ~.1'17 ,sl);led
)(fIfA IU/11 #111 (cJo, vrf' 7_'
do hereby
.1?r-
process in
Vs.
,
;ti/?7~ -7-
By delivering to, and leaving with the said
~/
a true copy
signed:
STATE OF TEXAS X
X
COUNTY OF HARRIS X
SUBSCRIBED AND SWORN
undersigned authority on
194$...,
TO UNDER OATH,
this ~ day of
me
the
My Commission Expires:
,
','
KATHLEEN ANN GOMEZ.
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 98-6574 CIVIL
v.
ANSEL RUlZ GOMEZ,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 18, 1998.
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 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
!l1~/99
I
, ~~~/
KA TI-II:; EN ANN GOMEZ