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HomeMy WebLinkAbout01-1880 FX ~._o~ " , ., ~- . RAJIESHB. PATEL Plaintiff IN- TWE COURT Of' COMMON-PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, . 2oo1-1't,{0 CIVIL ACTION LAW IN--DlVORCE JOANN PATEL Defendant TO JOANN PATEL: NOTICE To.DE~ENO-AND-CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend againsUhe claims set forth in the following.. pageS,.- )'oLL must take prompt actiarL You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment ma}t be entered against ~ tly 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 pro~ or other rights important to you, including custody or visitation of your children. When the grounds for tha divorca is. indignitiea or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Qffica of the Prothonotary,. Cumberland COUflty Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM-FOR AI IIl40NY,.JlUlISlON OF PROP~, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TQCLAlM-AN.Y 01= THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR- CANNOT AE=1=0RIl ONE. GO TO _OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BARASSOCIATLQN 2 Liberty Avenue CarIisI.e,. Pennsylvania. tz013 (7tz).249-3166 ^Ili:l!"" ~ j"' ~ ..~ , ' "~, ,",. .1 'C.. J'. RAJESH B. PATEL Plaintiff WTHE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, " ~. r ~" _" '.,~ ";,< JOANN PATEL Defendant NO. S. 2001 - I 8' FO G;;J I,.w,..... CIVIL ACTION LAW IN- D1-VORCE COMPLAINT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. The plaintiff is RAJESH 8--. PATEL,.. who currentlll resides at 30 Stephens Road, Camp Hill, Cumberland County, Commonwealth of Pennsylvania 17011. 2. The defendant is JOANN PATR whopresentlll resides at 1533 Route 38, Mount Holly, New Jersey 08060. 3. Plaintiff has beell- a bona fida residenl in the. Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint in Divorce. 4. The parties were married on July. 1~ 199.7 in\lirginia Beach, Virginia and separated in July, 1998. 5. There has been no prior action for dilLorceor annulment between the parties in this or any other jurisdiction. 6. Neither plaintiff nordefendaotis. amember of the United States Armed services or any of its allies. 7. The grounds upon which thaplaintifi seeks a divorce are: (a) the marriage of the parties is irretrievably broken. (b) the parties have lived separate aruLaparUor a period of at least two (2) years immediately preceding the. filing..of this Complaint in Divorce. -: ,. ,"J _.' I, """.""" tl !';Ie......." 8. Plaintiff has been adllise!ithalcouns.eIingjs RVRilRhle and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff avers that no. children were born of this marriage. 10. Plaintiff avers that the parties have no joint marital debts and no marital property to distribute or divide. 11, Plaintiff does not seek alimony,. spousaUlIIppnrlor attorney's.fees anclexpenses. WHEREFORE, the Plaintiff respectfully requests that This Honorable Court grant his prayer and enter an Order granting:. ilia parties a.Decr:ee in Divorce. ~~,~~ "Ill~ . c.--. " ,?.9 " RClJ..sl, B: Patet ~ 3rr Sfepfjens Road Date Camp Hill, Pennsylvania 17011 lr~ _.....-' .. I" " "" ... RAJIESH B. PATEL Plaintiff IN THECOURTOE COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. JOANN PATEL Defendant 00_ S 2001 CIVIL ACTION LAW! IbLDlVORCE VERIFICATION I verify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of m}' ImowLe.~belief aruiioformation. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 re.latingJu unsworn falsification to the. authorities S" "1,"'\ III '\ ~,~,~~ Date RAJESI:LIL.PATEL L"'ll.",~.. .-, ( 'f.~~' f/ .....:':.'\ (" li!l.M&;':~4l,1<,;W~,,:!.,,"" : ';,oli.>'h3_c.>i0.:w",,,,,,i.WPLrO';)'-, ;"'o":,~,,i; ",J:):;.",.u",;,..'c}"r,"oh,,,,;,;,''',.%fr;l:,,,,w.1<i~wiI~~Iti~~-~'oM,il'tiIM./31iiilililili! Jt 1 '..... .~ '-\'; \.l\ '", "- 1_ mm "=~~, , .I ~!l'J,II;;t$~~_____,!l:~I& ~ '- ~ ~(Al ~ ~ ~ \ \ ~ ~~~ ~ o ~ -oEt: rnrc: Z:T' -'7""- /.- '- Q:.X~ t;('C ~~C) ~() r-C z ~ c:\ ..",. ~~.. ~j C." r:) -0 _J.. ~ .. w '. c~ . , . L~~ ,--, ~"i .;;- ~~ ~~~ ,--=-;" , -~ ~ -< -- , , h' "~ '," ~, '""' I , , RAJESH B, PATEL Plaintiff IN THE-COURT OF COMMON. PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. JOANN PATEL Defendant N.~ S CML ACTION - LAW! IN.DL\lORCE 2001 " ) g<6i:J COUNTER-AFFIDAVIT UNDER SECTION 33011dl OF THE DIVORCE CODE 1. Check either (a) or (b): (a) ( ) I do not oppose the entry of a Divorce Decree. (b) ( ) I oppose the entry of aDjyorce Decree he~use (Check (i), (ii) or both): (i) ( ) The parties to this. action have notJiveciseparate and aparlfor a period of at least two (2) years. (ii) ( ) The marriage is nalirretrievably broken. 1. Check either (a) or (b): (a) ( ) I do not wish to- make any. d:!iml; for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them beforaadi.\locce is grant,ed. (b) ( ) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenseaoc other important rigQts. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT "WISH. TO MAKE ANY CLAIM FqR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT, J verify that the statements. in the. foregaing.,Mfidallii are true and correq, I understand that false statements herein are made subject to the penalties of'18 Pa. C,S. ~4904 relating to unswornJalsifLcatianta the authorities. Date JOANN.-PATEL,- Defendant. .~~ ~."'- ~ljl-"- J~~ ~,,~ ; . >., .J~' ''-p.' .~, <",./, ( .\ (, " RAJESH B. PATEL Plaintiff vs. Itll tHEC()IIRt OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA I~ 2001 ~ ~ JOANN PATEL Defendant NO... S CIVIL ACTION - LAW! ItllDL\lORCE PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301fdtOF-THE-DlVORGESOOE I IF YOU WISH TO DENY ANY STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUKT~AfFIDA\lLT WLTHI~ TWENTY(2n) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADM1~D. 1. The parties to this action separated in JuIv,. 1998 and halle continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably brokl;ln, 3. Neither the Defendant nor I is a member of the United States of America military or that of any of ita arurs. 4, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if l do JJot claim, them before the c!i\lOJ:ce is granted. I verify that the statements in tha foregoi[lQ.-Mfida.\lit.are. true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. e.s. ~4904 relating to unswornfalsificatian-tothe.authoriti,es. ?,\:,<9\G \ \t~~ Date RAJESH-B. PATEL.