Loading...
HomeMy WebLinkAbout00-08639 . . . . . ,",,'1 .' , ~, . . . :F. :ti;li:ti .. . . . . . IN THE COURT OF COMMON PLEAS . . . . None. . OF CUMBERLAND COUNTY STATE OF . . . . ASHVIN A. PATF.f" PENNA. . . . . Plaintiff, No, 8639 ;wnn . VERSUS DECREE IN DIVORCE . AND NOW, -r- "-l- I 'J.. o:r J."S3f.ltI. ,2001 , IT IS ORDERED AND . . DECREED THAT Ashvin A. Patel , PLAINTIFF, . AND Aruna A. Patel . . . , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . ARUNA A. PATEL. . 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; . . TPfp.nn~nt . . . . . . . AITEST4 ~. ~ OPROTHONOTART . . . "'if. Of. '" . . .. """""ii'J; J. '" r: . t1 . " i_' . I . " . r . '- fii . 1':1 ," . ", . [" . ('; . ;,; . :"! . . . . t" . ;'] . ,," . '-" . r:: . l' . l" I,: . , . 1,:1 . '-'i . j,', . ~!: . n li: . Ii " . I:! . i, . ,i,J . u . , . ~; .', . Ii . I" ~ !' . ;i: . [j I" . I'; Ii . ;'( . ~:: " . f!i . . \'i j" . Iii Iii . n I' . I! Pi . . . . . . . . . . . . . . . . . . . . . w " /6 tJ/ 6.5'-t::J( " " . "" . "'" >0 _ ~-~,. __ --- "~.'''~ """""m'^"'-"~'~',_<-J .\ \0 \ .. ,ot,. ~~~~~'ff~ ~~~~.. lIJl!II:",~~",~ '~'_, 1r,~,~~~~r!j .l_,,,,_,~,,~!~_I!l_~~T ~"'r" _'~'1_~'~1,i;W'; ~~ I ~ ,: ,-',," "'-';' -,' ~ '-',' ~"; '.','"'" " ,,~;;- 'J ,,;;:~,", , ~ Michael S. Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, P A 17011 (717)731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ARUNAA.PATEL, Defendant. ) ) ) ) ) ) No. 2000 - 8639 VS. CIVIL TERM 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: 1. Ground for divorce: irretrievable breakdown under ~ 330l(c)(I) of the Divorce Code. 2. Date and manner of service of the complaint: April 19, 2001, Acceptance of service attached hereto. 3. Date of execution of the affidavit of consent required by ~ 330l(c) of the Divorce Code: by plaintiff on May 16,2001; by defendant on May 29, 2001. 4. Related claims pending: No economic claims were raised. 5. prothonotary: Date plaintiffs Waiver of Notice in ~ 330l(c) Divorce was filed with the If. :5 ,2001. Date defendant's Waiver of Notice in ~ 33 (c) Divorce was filed with the prothonotary: C;. 5 ,2001. " ae raVlS Attorney for Plaintiff , 0 0 0 ~ -n :s. <- ,--< urn c:: ~:o mn; z " r- Z:r:> f --nn1- tjS ~-"O ~fl /}.;. .l "-'LJ ~e -U ~:+i ~O ::::: ~~ 5>2 ~ ;::) ;g ~ 0:> -< ~ ~1 :J', "'-' 'c" - '~, ,~ 'f'" ' - In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000 - <atP2:,q CIVIL TERM IN DIVORCE vs. ARONA A. PATEL, Defendant. 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. 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 at: i " Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 i I f'; I IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ,j,'-<' ,-,' , r '= '-,- "M',': 'r.", ~ ~'" ,,',', ",,;, " " In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000- 8w3cr CIVIL TERM IN DIVORCE , vs. ARONAA.PATEL, Defendant. NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: , I , [ i" I I, , I I: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302( d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a cOnvenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 1:' ,-', ~, ~." -'" , '~; Michael S. Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-95092 In the Court of Common Pleas of Cumberland Comity, , Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000 - '8&39 CIVIL TERM IN DIVORCE vs. ARONAA.PATEL, Defendant. COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by his attorney Michael S. Travis, respectfully represents: 1. Plaintiff is Ashvin A. Patel, who resides at 30 Stapens Road, Apartment 7-D, Camp Hill, Cumberland County, Pennsylvania, 17011, since March 2000. 2. Defelfdant is Arona A. Patel, who resides at 565 Lincoln Way East, Chambersburg, Franklin County, Pennsylvania, 17201, since March 2000. 3.Plllintiffhas been a bona fide resident of the Commonwealth of Pennsylvania forat least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on February 28, 1986, in the Country of India. 5. There have been no prior actions of divorce or annuhnent between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, plaintiff may submit an Affidl;lvit that the parties have lived separate and apart for at least two (2) years. 8. 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. I -' ,~- 9. Neither plaintiff nor defendant are in the Military Service in the United States Armed Services. Neither plaintiff nor defendant are within the provisions of the Soldiers' and Sailors' Relief Act of Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of 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. Date: /.z/ // /.f CJdo ~J1 ~d6( As vin A. Patel, Plaintiff ~ Attorney for Plaintiff I.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 I:, " ';;';?"";;. ." I I 1:- i ii; i~ !,',! " , j'~: i i" III it! r iii ii] (" I;i )ji gl t,: F: I,! ~l i:! ~i g) ;;! 11 :1 1-' j! ~: ~J H ~: !' :-:1' ",'-- "~'~-'-, In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000 - 8639 CIVIL TERM IN DIVORCE vs. ARUNA A. PATEL, Defendant. 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. 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 at: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 ,.1'",: " - ~,";' : _ ;':__ -I C'- ~ --'-, c' , '" , c;;~ ':,,' w ~---",,', n.' -,-,-',"",' ' ~' '--t, -,; [:' [,.' t;, In the Court of Common Pleas of Cumberland County, Pennsylvania i ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000 - 8639 CIVIL TERM IN DIVORCE vs. ARUNAA.PATEL, Defendant. NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance f,' f-; b: i :; f:' with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. i;~ I,' [' ~1 If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. I '-', '. j,~-', , '~, k ~ "~-~ ~ " , Michael S. 'Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-95092 In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000 - 8639 CIVIL TERM IN DIVORCE vs, ARUNAA. PATEL, Defendant. AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE AMENDED TO CORRECT CAPTION Plaintiff, by his attorney Michael S. Travis, respectfully represents: Paragraphs 1 - 10 of the original complaint are incorporated by reference herein. 11. Plaintiff is Ashvin A. Patel, who resides at 30 Stapens Road, Apartment 7-D, Camp Hill, Cumberland County, Pennsylvania, 17011, since March 2000. 12. Defendant is Aruna A. Patel, who resides at 565 Lincoln Way East, Chambersburg, Franklin County, Pennsylvania, 17201, since March 2000. 13. The caption and complaint of the original divorce complaint incorrectly state that the name of the Defendant is Arona A. Patel. The correct spelling of the defendant's name is , Aruna A. Patel. 14. Plaintiff requests that the caption be amended to indicate the correct spelling of defendant's name. 15. Plaintiff requests the court to enter a decree of divorce. ""J A~ ,- ..,~. -- ;",- -" ' , ' .' I verifY that the statements made in this Amended 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. Date: 4//// Zoot !Iffw;n fJ1idiLL Ashvin A. Patel, Plaintiff ~" Attorney for Plaintiff J.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000 - 8639 CIVIL TERM IN DIVORCE vs. ARUNAA. PATEL, Defendant. CERTIFICATE OF SERVICE I, Michael S. Travis, certifY that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Aruna A. Patel 565 Lincoln Way East Chambersburg, P A 17201 Dated: <1),/0/ c ae . Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 Fax 731-9511 Attorney for Plaintiff i.;,~ -,,- fl~-';'-"'"O~- W'-b-,,"",-"c.--~ (;",;,.",:' "." ,'--,' it":":"" ", ~~:ll: "j' 0;' - - - "":"1,,,,:-:,:.:.<-:.,,-;:;... '<~F"; ~""1f~'.lti~'" ~- ., 'IT' :_;;.:~:',i."'_;" ~_~'/"">;',S:.,,,"~, ,;,.." o <::: ;'}f..' > c ~ cr' r:_: "',( ~~~ ;-~ ~ =< ~,,~" (-, ::::,:-.,.. \.D ::...') , , ~--j -1, =< , ,J, "." '~ :1 I i'T! '''' - "", :,--;1' , "',-- '-.--. 1-'-, '~;'c'..d");;'''''- ~", . "c,"" " _",")z'"' 'i] In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ARUNA A. PATEL, Defendant. ) ) ) ) ) ) No. 2000- 8639 CIVIL TERM IN DIVORCE vs. AFFIDAVIT OF CONSENT L A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on December 15, 2000. 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 ofthe 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. DATED: 5 / l6) Zeo / f '" &in ~fl AshvlD A. Patel, Plaintiff n""";" ;--1 --" " , lif<<.'" ---"""'~:!ii i;'~ -~ "i "~JLJ.Ii~Jlj*~,~~-'"' ':ili~-- ,'-~_i: _, '-, ~"" , ';""/' ~ , '-~->:11_ , " ';_,k",," --: '.;~ -;..~,,: ' , ~ 0 0 -n (,... ::;1 -om c: r-'hp1 ~S3 z I "7 ~~ U1 :.0 ,--., ::;0 ;<0 -0 ~J:: :B ~o ::II: ('.)0 2m >8 S ~ 0 ~ (Jl iW .I.':: --I ., , ,':, ":__:-~~~;~,:,_~J'_;;;:; \'-'n'_~ "' -",^;:;~"'~;~:;: In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000- 8639 CIVIL TERM IN DIVORCE vs. ARUNAA.PATEL, Defendant. AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on December 15, 2000. 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. DATED: S- Pcrfee/CJI ~lMt. ArunaA. atel,Defendant '-::",;- :---', _, -:,' ~,1. ' , , ' ' -'"""''''''~~i1iIiiII~-J>-''" - ~~.--- "-~lii' ,",,., ,..L....;.;... ~p-' 'JiAfdlfaL1: .,,~' " -:{,:, 0'- 'J-'; ',-, " " '," ~, ",,,,,. . g S ~ -om 9igj ~~ '<.0 .." ~O' % )i>g - z, 0 =< (J'l ?;: % I (J'l """'" "C"",~,., 9n --\ :1'".-\\ rnp:: 'c\!l -q"-..--' 1"6 ~:::{~ ',:C -rl <40 om ::::ct ~ " \ .I, .1;" , -, ) "'" In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000, 8639 CIVIL TERM IN DIVORCE vs. ARUNA A. PATEL, Defendant. WAIVER OF NOTICE OF INTENTION TO REOUESTENTRY OF A DIVORCE DECREE UNDER IS 3301(c) OF THE DIVORCE COnE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses if! 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: 6P / /.2=0/ ~'~~Phin~ --', '," \ In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ) ) ) ) ) ) No. 2000- 8639 CIVIL TERM IN DIVORCE vs. ARUNAA.PATEL, Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 6 330H c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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: 5"/ z- 9' /..2.-J:So/ ~-~ Aruna A. Patel, Defendant l~;,;C;:,'i.;<'";",, , "~':'_flti,,~~~...illlill' .........~~"'-"-..''''- ~" .-' ~:'Hl1'--'"'''' ~, "iliin"~'~' --; -, , () 0 0 ~ -1'1 C- --; -o~ c:: fh ;J1 ~:J:.I Z :J323 ~s.;: I (J1 qi ~5 ..,,0 ..., I:rI ~() :x an 2m :1>8 - ~ .. ~ 0 ~ ..,., - . ~ ~, '" '-- "''''1 i 'i L Ii! " I ;1 , r ,1:0 ~ .. C<>;;;~i&i<;:'lienis 1, 2, Sfld3. Also cOmplete item 4 it Restricted Delivery is desired. . Print your name and address on the reverse so@lat we' can return the card to you, . Atlai;h 1his card to the back of the mailpiece, or on tl)e front if space permits. 1" Articldo Addressed to: C, Sign re ~ o Agent o Addressee Dyes DNo x 0, Is delivery address different from item 11 If YES, enter delivery address below: fYo()(A, A. PCl.fe I jCJ'S Linco/n WCU-{ f,usf Cha.tY1bersbv-r5 PA ,nJ 01 wP 3. S ce Type Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail, 0 C,O,D, 4.~~~IElilii\iyii~~ReJi es 2. Article Number (Copy from service label) D RS Form,S ~ ,1. July, 1999 ,_ ; ; '\ \,_ ~ n 1 I,; ; ~ i 102595-99-M-1789 L , In the Court of Common Pleas of Cumberland County, Pennsylvania ASHVIN A. PATEL, Plaintiff, ARUNA A. PATEL, Defendant. ) ) ) ) ) ) No. 2000 - 8639 vs. CIVIL TERM IN DIVORCE AFFIDA VII OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. 7099 3220 0009 6896 5539, return receipt requested, by depositing the same in the United States mail on December 15,2000, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendaut on December 18, 2000. I verifY that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. 'chael S. Travis 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 . .~;""~J'~-''-'-'\ L, "'d':;: -"~'u ,;;" '~'~lili~~" !Hi'" €hI'~f~~-:~;;~';L:,~,_"l;-:LLid--J,:l-';;-i,;'~" "'<,; '"~ ." ',.,O""'dC ,~." .."~ '... ""~i, g 0 0 .." ;;::: t..- -'" -om c:: ::C1\ rnrn ~ en 1"": Z:;U 1 '""Jm ~~ U'1 :':15::' I;{U KG ""t'J :r:=H ~o :;J\: ~o :);>g - om .. ~ ~ .0 (Jl '< . . x