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HomeMy WebLinkAbout07-2401e!. ~ .- ~.• LUAN T. CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. ©~ ~ ~ yDI CIVIL TERM Defendant : IN 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 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 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 Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 i ~r• "~-- LUAN T. CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. 4%• ~.Yv~ CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Luan T. Crespo, who currently resides at 105 Oneida Road, Camp Hill, Cumberland County, Pennsylvania, 17011 since 1985. 2. Defendant is Carlos M. Crespo, who currently resides at 1072 Lancaster Blvd., Apt. 8, Mechanicsburg, Cumberland County, Pennsylvania, 17055 since 2002. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on March 20, 1976, at Las Vegas, Clark County, Nevada. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. r --- 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: ~ - °~ 3 --~? ~ (,. ~ Luan T. Crespo, Plaintiff ANDREWS & JOHNSON By: Ronald E. John; Esquire Attorneys for ntiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 u, A.J ~~ n ~ O r- - C~ .~, -ri y , W ._C~ ~ t_~, '~~ ~ ~ ~ ' 'iy'f 1 ~ ~ (Vy S { ~ ~ ,'. N ~ ~ a C Ti f. `% C c _~ ~~ '~ . _- w -, LUAN T. CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. 07-2401 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Apri126, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Date: ~ " ~ " ~ 7 / Luan T. respo, Plaintiff C`; ^~ r_~ -~ ,~, r-_. a=:a ~~ F"' {_ _ ~ ~+,.~ _ x l ':'• r~ _ ~ ._,,' ._„~. ~. _ / Y _ .. t. .E~ •~ LUAN T. CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. 07-2401 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 26, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. Date: ~d7 C~'.--C~f~-~- ~._L ___-~~ Carlos M. Crespo, Plaintiff ~ _ ~ ~ : c ~ _ .. -.. a ` r `~.' _ ~'~ rp-t .,~ ~ ~ ~ a l" -C LUAN T. CRESPO, v. CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. 07-2401 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of properly, lawyer's fees or expenses if I 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. IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA Date: ~ " ~ ` Luan T. Crespo, Plaintiff c`~ r.~ ` ~ v .._.~ -r7 .~ --~ r- -...._ _' _..~i l .- ..... ,_: _ ) " ~~ A, G '? . ~,~ I t`3 ~ .. „'~ LUAN T. CRESPO, v. CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. 07-2401 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 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. IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA Date: 104 O7 Carlos M. respo, Defendant C.' ` ~ ~ ~ ~, r_-• G'~ ai7 .; f ~~ : ~~ } ~. ~-t . ~~ w +v . 1 ~ ~ ~..~~ ~~._ LUAN T. CRESPO, v. CARLOS M. CRESPO, TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-2401 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: Restricted certified mail, return receipt requested dated Apri128, 2007. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff August 4, 2007; by Defendant August 4.2007. 4. Related claims pending: None 5. Date Plaintiff s Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~~~/ 7 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~/_r~/~ ~ ANDREWS & JOHNSON Date: August ~ 2007 By: Ronald E ~hnson, Esq. 78 West omfret Street Carlisl PA 17013 (717)243-0123 "v ~- ° ~.~ ~;-; rz-~F~-_. ...... _.r. 1 ~a.. ~ ,.. __ `rt ~.~i : ' 1 ~.l r ~, -~ ~- .. - , { ~.~ 1 ~ ~~~' r ; ~ ~ '"'~ LUAN T. CRESPO, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW CARLOS M. CRESPO, : NO. 07-2401 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this s2~ day of April 2007, I, Ronald E. Johnson, Esquire, attorney for Luan T. Crespo, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiffin the above-captioned matter, upon the Defendant at his residence at 1072 Lancaster Blvd., Apt. 8, Mechanicsburg, PA 17055, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on April 28, 2007, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON Ronald E. J Attorney fq Sw and subscribed t~before me this day of ~r ` 1~ , 2007. COMMONWEALTH OF PENNSI(LVANtA NOTARIAL SEAL SHELLY SEXTON, Notary Public Cart~le Born, Cumberland County Commission F~c 'res April 26, 2011 k !}5~ ~a ~' ~ - .. .., Y ~- -a . y ~ ' ..:k ":fit f ` r1 _~ .- A. Signature ^ Agent X ~ ^ addressee B. Received by (Printed Name) C. Date Delivery D. Is delivery address different If YES, enter delivery add •~ s ~ ~ ~/,( ~~~ ~ ~OQ ~ f /y 3. .S,,,efrvice Type ~~ ,,~•,/,~.~i"'~ Yi v" !! Certified Mail ^ Express Mail i (~~77 ^ Registered ~.Ftetum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Feel Yes 2. ArticleWumber 7005 257 oaoa 3796 3455 (fiansfer from seryke laben PS Form 3811, February 2004 Domestic Return Receipt 102585-oz-M-lsa0 ^ Complete kerns 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse that we can return the card to you. ^ lath this card to the back of the mailpiece, 0 on the front 'rf space permits. 1. title Addressed to: C, Aa ws~u~sT£ e- S BcvD . ~p12 t..w, I°~4'i' • ~ ~Q Exhibit A ~.., r ` _~, ` ~ ; _ i . ~ C~ ~, ~. I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~~~ ; Luan T. Crespo Plaintiff N O. 07-2401 VERSUS Carlos M. Crespo Defendant DECREE IN DIVORCE AND NOW, ~~.I/ ~O] , IT IS ORDERED AND DECREED THAT Luan T. Crespo ,PLAINTIFF, AND Carlos M.'~Crespo ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; ,tle N ~ . PROTHONOTARY ~ ~~~ ~ ~ ~©~ fi .~y ~. .r+ i d