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Home My WebLink About01-5905ELIZABETH A. FELIZ, Plaintiff VS. JULIO A. FELIZ, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. ~)1- ~-c~o~" 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 AIqNULMENT 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 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 ELIZABETH A. FELIZ, Plaintiff VS. JULIO A. FELIZ, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. ~5'/- ~(~ Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiffis Elizabeth A. Feliz, a competent adult individual; who has resided at 13 S. Hanover St., Carlisle, Pa. 17013, since September 1, 2001. 2. Defendant is Julio A. Feliz, a competent adult individual, who has resides in Brooklyn, New York. 3. Plaintiffand Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 27, 1997 in Brooklyn County, New York. 5. There have been no prior actions of divome or for annulment betWeen the parties. 6. Plaintiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. Plaintiffand Defendant have no children together. 8. Plalntiffand Defendant are both citizens of the United StateS of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiffavers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. I verify that the statements made in this Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. F~ab~th A. Feliz, Plaintiff,~/ ~tted, ~ /z~anlA~re kI.D. 1~o. 79465 ~'t3.fl_Sbuth Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ELIZABETH A. FELIZ JULIO A. FELIZ, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : : NO.d Y ioy civiL : : CIVIL ACTION - LAW PRAECIPE TO PROCEED IN FORMA PAUPERIs To the Prothonotary: Kindly allow, Elizabeth A. Feliz, to proceed in forma pauperis. I, Jane Adams, attorney for the party proceeding in ~ l~lgge,_r~, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. (lan;~. dams, Esquire Hanover St. Caxl~le, Pa. 17013 (717) 245-8508 Id. No. 79465 ELIZABETH A. FELIZ JULIO A. FELIZ, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - LAW AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am thePlaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: ~ Address: 13 S. Hanover St. Carlisle. Pa. 17013 (b) Social Security Number: 056-60-7189 If you are presently employed, state Employer: Unemployed Address: Salary or wages per month: _ Type of work: If you are presently unemployed, state Date of last employment: 1998 Salary or wages per month: $1100/month Type of work: ~ (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: Disability payments: $558.49 a month social securi _ty disabili _ty since April 2001. Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Received $70 cash and $179 food stamps eve _ry two weeks from the state of New York from October 2000 through April 2001, Other: (d) Other contributions to household support (Wife)(Husband) Name: Juiio A. Feliz. Does not contribute to Plaintiff's household expenses the Plaintiff and Defendant are currently separated. If your (husband) (wife) is employed, state Employer: ~__ Salary or wages per month: Unknown. Type of work: Unknown. Contributions from children: None. (e) Property owned Cash: $10.00 Checking Acc(~unt: Savings Account: Certificates of Deposit: Real Estate (including home): Motor vehicle: None. Stocks; bonds: Other: (f) Debts and obligations Mortgage: Norl~, Rent: $489.00 a month. Loans: None, Monthly Expenses: None. $1.00 None. None. None. None. Approximately $100 a month. (g) Persons dependent upon you for support: None. (Wife) (Husband) Name: None. Children, if any: Name: Age: 4. I understand that I have a continuing obligation to inform the court of improvemem in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are tree and correct. I understand that false statemems herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unswom falsification to authorities. ~F~beth A. Feliz, Plaintiff ELIZABETH A. FELIZ, Plaintiff VS. JULIO A. FELIZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND ~qD COMPLAINT. AND NOW, this November 8, 2001, I, Jane Adams, Esquire, hereby certify that on October 26, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted deliVery, return receipt requested, addressed to: Julio A. Feliz 126 Franklin Ave Apt. 1 Brooklyn, New York 11205 DEFENDANT Respectfully Submitted: dam~uire o. 79465 uth Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF UNITED STATES POSTAL SERVICE'!, :!, ,;;~; %, ! Postage & Fe~s Paid| ! IIII! · Sender: Please prir~~ddress, a~d~,ztP~i~his box ~:..; h,i!lh,41h,,,,,lh,th,ilh,l.h,hh,4h,4lh,,l!!,,il ELIZABETH A. FELIZ, Plaintiff VS. JULIO A. FELIZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. DJ- ~"~0..~'- Civil Term : ACTION IN DIVORCE 2001. AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on October tt, 2. The mardage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein ara made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. ~ Date: ~.~o/~)"'7--~ JuhoA. Fei,z, I/t'efe d " WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~-33n-1{c~ OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 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· 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decrae 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. I understand that false statements herain are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ELIZABETH A. FELIZ, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 5905 Civil Term 2001 JULIO A. FELIZ, Defendant ACTION IN DIVORCE 2001. AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on October 11, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. '-E~ ~ '~~ Date: ~-~- I ~;;~ - O~ ~ iff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301 (c~ OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 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. 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 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: '~ .,.- /~,.-~ ,,~ E~izab~_,~A. Feliz, Plaintiff --< ELIZABETH A. FELIZ, Plaintiff VS, JULIO A. FELIZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 5995 Civil Term 2001 ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the COurt for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce 2. Date and manner of the service of the Complaint: Delivered by certified mail. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~ ~ [ [ -- ~ ~ Date Plaintiff's Waiver of Notice in Prothonotary: --~ _/~-- ~p ~ Date: ,.~ /ylO~,.' §3301(c) Divorce was filed with the Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff By Defendant: restricted delivery., return recei_Dt reauested, delivered on: //O J c~ ~ -----~___,) / 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of .~.. PENNA. Elizabeth A. Plaintiff VERSUS Julie A. Feliz, Defendant NO. 5905 Civil Term 2001 AND NOW, DECREED ThAT AND DECREE IN DIVORCE Elizabeth A, Feliz Julie A. Feliz ~/~PT I$ ORDERED AND __,PLAINTIFF, ,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; Nol~.e, ATTEST~ PROTHONOTARY