HomeMy WebLinkAbout03-4970VICTOR RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
C1VILACTION-NO: 03- '4c)70 ~
IDA RIVERA,
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
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All
arrangements must be made at least 72 houm prior to any hearing or business before the court. You must
attend the scheduled conference or hearing.
VICTOR RIVER. A,
Plaintiff
IDA RIVERA,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:CWILACTION-NO: 03 - qqg'o ~ '7-'.o,-
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiffis Victor Rivera, who currently resides at 122 Meals Drive, Carlisle, Cumberland
County, Pennsylvania, since November 22, 2002..
2. Defendant is Ida Rivera, who currently resides at 9953 Alicia Street, Philadelphia County,
Pennsylvania, since June, 1995.
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. Plainfiffand Defendant were married on June 13, 1985 in Philadelphia, Pennsylvania.
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 Plainfiffmay have the
right to request that the Court require the parties to participate in counseling.
8. Plaintiffrequests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
Date: September 18, 2003
By: ~~ ~
Kar~'E. Rominger, Esquire
Attorney for Plaintiff
155 South Hanover Street
Carlisle, PA 17013
Supreme Com't I.D. #81924
(717) 241-6070
VERIFICATION
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.
Date:
Victor Rivera, Plaintiff
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
Casa Number: ~'~'; /
Plaintiff:
VICTOR RIVERA
VS.
Defendant:
IDA RIVERA
County of Cumberland
Common Pleas Court
For: Karl Rominger
Rominger & Bayley Law offices
Received by ROMINGER LEGAL on the 18th day of September, 2003 at 12:13 pm to be sarved on Ida Rivera 9953
Alic,,ia, St.reet,.P~lad,elp,hia, PA. I, '7'",~. ~:~'. ~/:~.,{A' , being duly sworn, depose and say that on the
-/,. i oay ot ~, 20 4/~ at ~2._://3 ,,~.m., executed sarvice by delivering a true copy of the Notice -
Divorce, Notice - Complaint Under Section 3~01 (c) of the Divorce Code in accordance with state statutes in the
manner marked below:
~'iNDIVIDUAL SERVICE: Served the within-named person.
( ) SUBSTITUTE SERVICE: By sarving as
( ) POSTED SERVICE: After attempting sarvice on __/__ at and on / at
place on the property described herein.
( ) NON SERVICE: For the reason detailed in the Comments below.
Military Status: ( ) Yes or (v-)~No If yes, what branch?
MaritalStatus: (~/Married or ( )Single Name of Spousa
COMMENTS: ~- [ ~ ..-;~r.,(~ $
__toa conspicuous
I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in
which this sarvice was made.
Sub..~dl:/~ed ~nd Swor..n._to before me on the ~-~-'day
of ~-5~,'~l~,~t~r~,,- // £~t_~ b
' v- y the affiant who is
persodally known to me.
NOTARY PUBLIC ~
PROCESS SERVER #
Appointed in accordance
with State Statutes
ROMINGER LEGAL
155 S. Hanover St.
P.O. Box 1148
HOTARIAL~.N- ' l~q Carlisle, PA 17013
TERESA A. MINZOLA, Nobv~ ~ I (717) 960-9260
My~ ExP~_~ Our Job Serial Number: 2003000269
Ce~/fight ~ 1992-2~1 Database Services, Inc. - Pro~ess Ser, er~$ T(x)lbox V55f
VICTOR RIVERA,
Plaintiff
IDA RIVERA,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - NO: ~
: 0
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 18, 2003.
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 divoree 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
unswom falsification to authorities.
Date: ~/~v~ o~
Victor Rivera/Plaintiff
VICTOR RIVERA,
Plaintiff
1DA RIVERA,
Defendant
: iN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - NO: 0-3-44-5-7
qqa 0
: 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 alirnony, division of property, lawyer's fees or
expenses ifI 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 Courl 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.
Date:
VICTOR RIVERA,
Plaintiff
IDA RIVERA,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - NO: 03~3457
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 18, 2003.
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 ora 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.
Ida Rivera/Defendant
VICTOR RIVERA,
Plaintiff
IDA RIVERA,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - NO: ~
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER § 3301(c) OF TIlE 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 divomed 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 unswom falsification
to authorities.
Date:
7Ida RiveraJDefendant
VICTOR RIVERA,
Plaintiff
V.
IDA RIVERA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - NO: 03-4970
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following infi~rmation, to the Court for entry ora
divorce decree:
1. Grounds for divorce: irretrievable breakdov~a under § 3301 (c) of the Divorce
Code.
2. Date and manner of service of the ComplainlI: Affidavit of Service September 21,
2003. Attached as Exhibit "A".
3. Date of execution of the affidavit ofconsem required by § 3301(c) or The Divorce
Code: by the Plaintiff August 9, 2004; by the Defendant August 9, 2004.
4. Related claims pending: None
5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: August 11, 2004.
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: August 11, 2004.
Date: August 11, 2004
Karl E. Rominger, Esquire
155 South Hanover Street
Carlisle, PA 17013
(717) 241-6070
Supreme Court ID No. 81924
IN THE COURT Of COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
VICTOR RIVERA,
Plaintiff
VERSUS
IDA RIVERAt
Defendant
PENNA.
N O. 03-4970
DECREE IN
DIVORCE ~
AND NOW,~ ~,IT IS ORDERED AND
DECREED THAT VTCT~)R RTVERA , PLAINTIFF,
IDA RIVERA
AND ,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;
None.
PROTHONOTARY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Plaintiff :
Vs :
Defendant :
File No.
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/defendant in the above matter,
[select one by marking "x"]
__ prior to the entry of a Final Decree in Divorce,
or ....~z__ after the entry of a Final Decree in Divorce dated .~- ! ')--,,~ oo__~
hereby elects to resume the prior surname of (~.~$ 7Lg ! / 81, a O , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704.
Signature
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Pf4/z-/t)~'2.Ct//6)
Signature of name being resumed
On the ~ 7tt day of ~,~ly~/t,/d,~f~ ,2004/, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
Protl~lnotary or Notary Public
Notarial Seal
Mary T. Madrack, Notary Public
City of Philadelphia, Philadelphia County
My Commission Expires June 5, 2006-
Member, Pennsylvania Association ot Notaries