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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