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HomeMy WebLinkAbout99-05126y?r V I` f rrO C l v Z d z i I 1 f I J N a 4 :O• :? :?• :O• :?•' •:?• {6•..•7C iW :e`•' M. Cx •:M• •:W• -X'? •:E• -W, 4r, W. •:0 '}";?•:::e2: i:1i:[:?{pt+-aA•' :ei•" •31:' ?r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. V-4- R 7-> E E Versus C- Fe Nim /V DECREE IN I V O R C J MD NOW, ............... ..... 19...... , it is ordered and i P/ ?/ decreed that .....E,t~.R ...?....#4n.O.Niq.C-V...... plaintiff, and ............. -?O. rVAM... E'1,....41- 14 .01\14 e-..I..... , 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; .....................o....................................... is is J. •?: re. ?w• <?• •2n• <?• •s• :?• :r.• a::e? ;i• te: t•^•:r•???::.?:::?: ?_cc? c• ?:e: ce:• :%?'t?:•'.?:• ? ?i .? is ??.°?y ?? ??/ ? j PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. No. 99-5126 DONNA M. ALMONACY I Defendant. CIVIL ACTION - LAW IN DIVORCE PRAEdPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under §3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: August 23, 1999 by Certified Mail, Returned Service Reequested. 3. (a). Date of execution of the affidavit required by §3301(d) of the Divorce Code: August 23, 1999. (b). Date of filing and service of the Plaintiffs' affidavit upon the respondent: August 23, 1999. 4. Related claims pending: None. 5. Date and manner of service of the of intention to file praecipe to transmit record, a copy of which is attached: September 20, 1999. Date: !10 Terre E. Almonacy, PI intiff nr - Jy J:: i'( -1 PIERRE E. ALMONACY Plaintiff V. DONNA M. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5126 Defendant. CIVIL ACTION - LAW IN DIVORCE ' ( u? O v cu NOTICE OF INTENTION TO REQUEST ENTRY OF ztn rn -O SECTION 3301 (D) DIVORCE DECREE t G rn . 3 v y TO: DONNA M. ALMONACY, Defendant. ?rZ 0 w You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301 (d) affidavit. Therefore, on or after October 18, 1999, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 PIERRE E. ALMONACY Plaintiff V. DONNA M. ALMONACY Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99 - 5126 CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER 43301 (d) OF THE DIVORCE CODE Check either (a) or (b): ? (a) I do not oppose the of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii), or (both): ? (i) The Parties to this divorce have not been living separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims 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 before a divorce is granted. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 Donna M. Almonacy, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OFA DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 99 - 5126 DONNA M. ALMONACY Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Pierre E. Almonacy, certify that on the 20a' day of September 1999, I caused a true and correct copy of the Notice of Intention to Request Entry of a Divorce Decree Under §3301 (d), the Counter-Affidavit Under §3301 (d) of the Divorce Code to be served by certified mail upon the following individual: Donna M. Almonacy 4843 E. McNeil St. Unit#1 Phoenix, Arizona 85044 )i,p A A A 6- 61 Pierre E. Almonacy, laintiff 1 N _ LLI ?? -J U , CL ' o + i PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. Q? • /?? LGG??f DONNA M. ALMONACY Defendant. CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. Your are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint of for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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 7 PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 9 9• 5/ 1 Ci Q 7z-4?N-i DONNA M. ALMONACY Defendant. CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 (d) OF THE DIVORCE CODE Plaintiff is PIERRE E. ALMONACY, who currently resides at 36 N. Orange Street, Carlisle, Cumberland County, Pennsylvania, since August 1997. 2. Defendant is DONNA M. ALMONACY, who currently resides at 4843 E. McNeil Street, Unit 1, Phoenix, Arizona. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 3, 1987 at St. Albans, Queens County, New York. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling. 8. The 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 unswom falsification to authorities. Pierre E. Almonacy, Plaintiff Un Ci_:eJ S ?-r: C m U PIERRE E. ALMONACY Plaintiff V. DONNA M. ALMONACY Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA No. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The Parties to this action separated on September 1991 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: L "( E Terre E. Almonacy, P aintiff c E- H CL Cli ' 11 cn j PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. DONNA M. ALMONACY Defendant. CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Pierre E. Almonacy, certify that on the 23'" day of August 1999, I caused a true and I correct copy of the Divorce Complaint Under §3301 (d), the Affidavit Under §3301 (d) of the Divorce Code to be served by certified mail upon the following individual: Donna M. Almonacy 4843 E. McNeil St. Unit#1 Phoenix, Arizona 85044 Terre E. Almonacy, Plaintiff lLl?' C ) (-? G_... ?i' ?., O?? Lnr ii- ti. (_ CU ?._ r, u. ('? N L ': f,M u-+ '.t ,:_i ?_? l :c" ?.,? 11i1J ill :.? J (? \n _/ ?d (M? ? ?J PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 99 - 5126 DONNA M. ALMONACY Defendant. CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301 (D) DIVORCE DECREE TO: DONNA M. ALMONACY, Defendant. You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301 (d) affidavit. Therefore, on or after October 18, 1999, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 99 - 5126 DONNA M. ALMONACY Defendant. CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER 53301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii), or (both): ? (i) The Parties to this divorce have not been living separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims 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 before a divorce is granted. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 Donna M. Almonacy, Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. PIERRE E. ALMONACY IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 99 - 5126 DONNA M. ALMONACY Defendant. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Pierre E. Almonacy, certify that on the 20th day of September 1999, I caused a true and correct copy of the Notice of Intention to Request Entry of a Divorce Decree Under §3301 (d), the Counter-Affidavit Under §3301 (d) of the Divorce Code to be served by certified mail upon the following individual: Donna M. Almonacy 4843 E. McNeil St. Unit#1 Phoenix, Arizona 85044 ierre E. Almondcy, Plaintiff 4 M O 7 ?r N i l? l 7 O? C l w... N ? LL F: W N W a t V m V