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DONNA M. GONZALEZ a/k/a : IN THE COURT OF COMMON PLEAS
DONNA M. GONZALEZ-SOTO : CUMBERLAND COUNTY, PENNA.
Plaintiff
V. NO. ?9
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ISRAEL GONZALEZ a/k/a
ISRAEL GONZALEZ-SOTO
Defendant
: CIVIL ACTION - LAW
: DIVORCE
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 in 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, includig 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 Court Administrator, Cumberland County Courthouse, 1
Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DI17ISION 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:
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
717-240-6200
DONNA M. GONZALEZ a/k/a
DONNA M. GONZALEZ-SOTO
Plaintiff
V.
ISRAEL GONZALEZ a/k/a
ISRAEL GONZALEZ-SOTO
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA.
NO. C9- `/G `/0 l Ic -.
: CIVIL ACTION - LAW
: DIVORCE
COMPLAINT
AND NOW, comes Plaintiff, Donna M. Gonzalez, by and
through her attorney, James W. Abraham, Esquire, Abraham Law
Offices, Harrisburg, Pennsylvania, and files the following:
COUNT I
DIVORCR PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiff, Donna M. Gonzalez, a/k/a Donna M.
Gonzalez-Soto, is an adult individual who currently resides at 6223
Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania,
17055.
2. Defendant, Israel Gonzalez a/k/a Israel Gonzalez-
Soto, is an adult individual who currently resides at 411 East Main
Street, Shiremanstown, Cumberland County, Pennsylvania, 17011.
3. Plaintiff and Defendant have been bona fide residents
of the Commonwealth of Pennsylvania for at least six (6) months
immediately prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on November 20,
1998 in Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties which are active.
6. The marriage is irretrievably broken.
7. 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.
8. Plaintiff and Defendant are not members of the Armed
Forces of the United States.
WHEREFORE, Plaintiff requests Your Honorable Court to
enter a decree in divorce dissolving the marriage.
COUNT II - INDIGNITIES
9. Plaintiff incorporates by reference paragraphs 1
through 8 hereto.
10. Defendant has rendered and caused such indignities as
to Plaintiff, that said indignities have made life intolerable and
burdensome for Plaintiff, the innocent and injured spouse.
WHEREFORE, Plaintiff respectfully requests Your Honorable
Court to enter a decree in divorce dissolving the marriage.
Respectfully submitted:
i
James W. Abraham, Esq.
Abraham Law Offices
513 North Second St.
Harrisburg, PA 17101
(717) 232-7825
DATE: 7/30/99 Attorney for Plaintiff
VERIFICATION
I, 1 -6 NHCL N 6-01A ZaL =f- , the undersigned, hereby
verify and confirm that I have reviewed the foregoing document and
the statements therein are true and correct to the best of my
knowledge, information and belief. I further understand that any
false statements made herein are subject to the penalties of 18
Pa.C.S.A. Section 4904, relating to unsworn falsification to
authorities.
DATE: 7 - I'{- '/
?H_ aL Q L?
CERTIFICATE OF SERVICE
I, James W. Abraham, Esquire, the undersigned, do hereby
certify that I have served a true and correct copy of the foregoing
document, by certified mail, on the date indicated below, to the
following person(s):
Israel Gonzalez
411 East Main St.
Shiremanstown, PA 17011
DATE: 7/30/99
m, Esquire
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