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HomeMy WebLinkAbout07-1991Y ~ ~ ? Cyntia R. Mogollon Plaintiff v. Edgardo J. Jimenez Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.07- ~~Q~ CIVIL TERM 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. 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, Cumberland County Courthouse, 1 Courthouse Squaze, Callisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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. Cumberland County Baz Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Cyntia R. Mogollon Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA N0.07- / R 9 / CIVII. TERM Edgardo J. Jimenez Defendant IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE s 1. Plaintiff is ~~] `~ ~('~ ~~ Yl ,who currently resides at Cumberland County, Pennsylvania. 2. Defendant is ~QU ~ ~~\'(YY~P'1E' who currently resides at Y1 i ~-~- 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ~~ ~ ~~~, at t S. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Pazagraph 2 above. , t - ..' 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ~ ~~ ~ /~ Date Plain ff, Pro Se I, i ~'~ C ~ ~ ~ U~ verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made fierein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa'. C.S. §4904. zl I l 1 ~~ Date: Pla~jhtiff, Pro Se Assisted by: Susan Candiello, Esquire 4010 Glenfinnan Place Mechanicsburg, PA 17055 (717) 724-2278 C; h2 ~~' -~..i "r; ~-~ -r' ~, r;~r ~? ~ :~-~,a _ ~;,;.} }'. - ~ :. ; =-_ ~ 1 - f Cyntia R. Mogollon IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v• N0.07- ~~4~ CIVII, TERM Edgardo J. Jimenez Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Cvntia R. Mogollon Plaintiff, to proceed in forma au eris. I, Susan Candiello, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the p~Y• Attorney fo Plain iff 4010 Glenfi an lace Mechanicsburg, PA 17055 (717) 724-2278 C'` ' r'' `~ _~ ~ ._., ) i , , ~Z ~ ~ ~r ~ _ - ~..~4 _ i:... ~.~ _ _ _`...: ~+~ ~ ~~~ ..~ Cyntia R. Mogollon IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v• N0.07- ~ q9 ~ CIVII. TERM Edgardo J. Jimenez Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ,~. rya ;~, .~ ~' - fi _ ~.. _r~ .~.. f 3 ti : ~T ~ ~ __ '~ r, _r 1 l..' « .u1ft~ .. ~"' "'~ Y CYNTIA R. MOGOLLON, PLAINTIFF vs. EDGARDO J. JIMENEZ, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ~SY.~ANIA N0.07-1991 CIVIL TERM CIVIL ACTION -LAW ACTION FOR DIVORCE SERVICE OF DIVORCE COMPLAINT BY CERTIFIED MAIL 1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania. 2_ I re~esent. Cy~ia B_ Mc~gQl}~n,, Plaintiff in the above-~~ matter. 3. On April 12, 2007, a true and correct copy of the Complaint for No-Fault Divorce U~ S~ 33I#1~~e) of a Ien'ee ~ deli~et~ wit tie U.S. Pell Set~iee in Mechanicsburg, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7006 0810 0000 7883 6671, and addressed to the Defendant, Edgardo J. Wiz, at I'.E3. 52~#2~9, Mir, richt ~~I52. 4. The return receipt card signed by the Defendant, Edgardo J. Jimenez, showing a date of service of May 2, 2007, is attached hereto as Exhibit "A". ~. wee by c~ rn~l ~ regreme ~~Pa.R.C.P. 4f~2) a~ Pa.R.C.P. 403. /~ SUSAN KAY Counsel for P. 1 ^ Complete kerns 1, 2, and 3. Also complete ~ kem 4 if Restricted Delivery is desired. ^ ~ ^ Print our name and address on the reverse ^ Addreaee s0 tlWe Can retlMTl the Card to you. B. Re INI ted H C. Date of Delivery ^ A is card to the back of the mailpiece, ~ .~, or frorrt if space permks. to: D. is address Item 1 T ^ Yes ~~ ~ ~ ~ ~~ ~~ ~ H , enter ~ ~ below: ^ No P ~a~a~ ~© ~ o~ ~ l Cti/Wl"h+"~ 3. Type Certified Mail ^ Express Mail 3~ ~~ ^ Registered ^ Retum Receipt for Merchandise ^ Insured Mall ^ C.O.D. 4. Restricted Delivery?(Extra Fee) ^ Yes 2. MtlcleNumt~er 7006 D810 X000 7883 6671 p-.e.lfer ntxr- earn PS Form 3811,• February2004 Domestic Retum Receipt ~_ tar~ilsce~ts+o . EXHIBIT "A" `-~ci C`-~`, ~ ~ ..~, st c'; . _. ;~ ~_ ~~' t:~5 p ,,. ~" ~ :. .~~ ~