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HomeMy WebLinkAbout07-5015._ , In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez Plaintiff V. Term, 2 Case Number: ~ ~ ~ `~ U, s Gnu' ~ -fit~+- Peter Lopez Defendant And in the interests of (minor children) Mia Gisella Lopez (Age: 2) Notice to Defend and Claim Rights TO: Peter Lopez You have been sued in Court. If you wish to defend against the claim 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 child(ren). When the grounds for divorce are 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 ~:u`~ {1~er~ahd Coun~v ,Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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: Lawyer Referral Service (enter address below): CC (3ar- Prssocio,~iot, 3 Carlin e. I-10(3 Phone: X00 996 - Q~~g Date: uA~~2°a~ ~ca rn L LODPZ Print Name (Plai tiff) Signature (Plainti Mailing Address: PO Box 37, Grantham, PA, 17027 Phone: 717-796-5958 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L LoRez Plaintiff V. Peter Lopez Defendant And in the interests of (minor children) Mia Gisella Lopez (Age: 2) Term, 2 Case Number• Complaint for Divorce This suit is brought by Tara L Lopez, the Plaintiff, Pro Se, Social Security #: 221-74-6002, Drivers License/State ID #: 28 284 639, age 29 years old, who resides at: Low Street and Second Street, Unit 4, Grantham, PA, 17027 with a home phone number of: 717-796-5958. Defendant is Peter Lopez, Pro Se, Social Security #: 139-86-9780, Drivers License/State ID #: 28 284 678, age 27 years old, who resides at: 12 Altoona Avenue, Enola, PA, 17025 with a home phone number of: 717-732-2113. I. RESIDENCY: The Plaintiff has been a resident of the State of Pennsylvania for the preceding 6 (six) months and a resident of the county in which this Complaint for Divorce is filed for the preceding 10 (ten) days. II. MILITARY STATUS: The Plaintiff is NOT active in the United States Military. The Defendant is NOT active in the United States Military. III. SERVICE OF PROCESS: A Waiver of Citation will be filed by the Defendant, therefore, no service is necessary at this time. IV. JURISDICTION: The Court has the required jurisdiction to hear this case. Neither party has ever been involved in any other domestic relations proceedings involving the other party in this or any other jurisdiction. V. MARRIAGE: The parties were married on July 17, 2004 in the city of Enola, in the state of Pennsylvania, and separated on or about, December 1, 2006, at which time they separated and ceased to live together with the intent to terminate the marriage. An official marriage license is attached to this Complaint for Divorce for reference. VI. GROUNDS: Irretrievable breakdown of the marriage and the spouses intend to file affidavits that they consent to the divorce. VII. PREGNANCY: The Plaintiff is not currently pregnant. VIII. CHILDREN: The Plaintiff and Defendant are the parents of the following child born, or legally adopted of the marriage under the age of eighteen (18) who are not under the continuing jurisdiction of any other court: The information about the child is as follows: Child #1 Full Name: Mia Gisella Lopez Age: 2 Date of Birth: December 26, 2004 Sex: Female SS#: 184-82-2733 IX. CHILD CUSTODY AND VISITATION: The child custody and visitation arrangements, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. X. CHILD SUPPORT: The child support obligation, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. XI. PROPERTY AND DEBT: The property and debt, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. XII. RETIREMENT ACCOUNTS: The retirement accounts, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. XIII. SPOUSAL SUPPORT: The spousal support, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. XIV. HEALTH INSURANCE: The health insurance, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. XV. TAX ISSUES: The tax issues will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. XVI. PROTECTIVE ORDERS: There are no protective orders between the Plaintiff and Defendant. XVII. NAME CHANGE: The Plaintiff requests that the Court order a name change for the Plaintiff and that the name be changed to: Tara Lynn Dugan (maiden/prior name). XVIII. PRAYER: The Plaintiff respectfully requests this Honorable Court to grant this Divorce pursuant to Section 3301 (c), or on the alternative, Section 3301 (d) of the Divorce Code. XIX. REPRESENTATION The Plaintiff has chosen to act as her own attorney in a pro se fashion, and understands that she has the legal right to representation by an attorney. She fully understands her rights and consider the terms of the attached Marital Settlement Agreement to be fair, reasonable and in the best interest of the child. XX. VERIFICATION I verify that the statements made in the Complaint for Divorce are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: $ I (3/200 ~7 , Tara ~ Lo vez PrintN{ame (Plainti f, Pro Se) ~, I n,0. ~~J~ Signature (Plaintiff, ro Mailing Address: PO Box 37, Grantham, PA, 17027 Phone: 717-796-5958 COUNTY COURT OF COMMON PLEAS INTAKE This form must be filled out if you are filing a divorce or custody action in the Prothonotary's Office: Today's Date: g~~ ~ " ~ ~ Case Number:: B ~ - ~D 1 S L~~~~ -re.~M. Please Check One: (_) Divorce Filing - No Children (X) Divorce Filing -With Children Under 18 (_) Custody Filing -With Children Under 18 Plaintiff Name, Address and Phone: Name: Tara L Lopez Address: Low Street and Second Street, Unit 4, Grantham, PA, 17027 Phone: 717-796-5958 Defendant Name, Address and Phone: Name: Peter Lopez Address: 12 Altoona Avenue, Enola, PA, 17025 Phone: 717-732-2113 [`} /~~ t," rJ Q ...t, ~ .,,~ -~ _~ ~-1 (.J c= ~ ~ j- r1 fv ~,-; J' l .. _' ! ..._.. ~ ~Z , i'77 l~~1 `_ .. `1 W r' ~- In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez Plaintiff V. Peter Lopez Defendant And in the interests of (minor children) Term, 2 Case Number: 07 ~ ~~ ~ S c- ~' «~'`` Mia Gisella Lopez (Age: 2) Affidavit of Verification THE STATE OF: PA COUNTY OF: Cumberland BEFORE ME, Tara L Lopez, the undersigned authority and the Plaintiff in the above referenced case, on this day personally appeared who, being by me duly sworn, upon oath says: My name is: Tara L Lopez Social Security #: ~ Driver's License/ State ID #: ~ My mailing address is: PO Box 37, Grantham, PA, 17027 Phone:717-796-5958 The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my knowledge, i/nformation, and belief, and that I am authorized to make this affidavit. Date: ~g(Z2/ZOU7 Taml-t-oPez Print Name (Plaintiff) Signature (Plaintiff j U ~' ~ SWORN TO AND SUBSCRIBED BEFORE ME Tk~R L-__ L°~t'Z o~ cer~ which witness my hand and seal of office. 1~7otary Public, State of PA Notary Seal by the said i this ~ ~' ~~ , -~ ~ to COMMONWEALTH OF PENNSYLVANIA My commission expires: RIAL SEAL LINDA E. HERMAN, Notary Public Lemoyne Borough, Cumberland Co. My Commission Expires Aug. 26, 2008 c-' ~' c_N ~ v - r, ~;, ~~ ~ ~ ~-- _ N _ ;' ` ~; ., - ~ -, -4, , '. .. '~ .. ~ :T.1 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez ) Term, 2 Plaintiff ) V. ) UI S Cd ~, ~-FtcM Case Number ~ ~ a S Peter Lo~-ez ) Defendant ) And in the interests of (minor children) ) Mia Gisella Lopez (Age: 2) COUNSELING NOTICE (Under PA. R.C.P. Rule 1920.45(a) (1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section Indignities 3301(a) (6) Section 3301 Irretrievable Breakdown (c) Mutual Consent Section 3301 Irretrievable Breakdown (c) Two (2) Year Separation Where the Court Determines That There is a Reasonable Prospect of Reconciliation A list of qualified professionals is available for inspection in the office of the Appointments Clerk of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations Branch of the Family Court of Philadelphia. Date: ~ 113 1200`7 Tc~ra~~oez Print Name (Plaintiff) -,o~~ Signature (Plainti f) t'~ c` ^~ ~ a z~m -- t7l ~`~ N -; ~ -- - -~ C:: = 4.~, ..ate ' ~=:3 __ r~ rep d_, ~.. z3 -.a -G In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez ) Term, 2 Plaintiff ) V. ) ~ Case Number: Peter Lopez ) Defendant ) And in the interests of (minor children) ) Mia Gisella Lopez (Age: 2) COUNSELING NOTICE (Under PA. R.C.P. Rule 1920.45(a) (1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section Indignities 3301(a) (6) Section 3301 Irretrievable Breakdown (c) Mutual Consent Irretrievable Breakdown Section 3301 Two (2) Year Separation Where the Court Determines That There is (c) a Reasonable Prospect of Reconciliation A list of qualified professionals is available for inspection in the office of the Appointments Clerk of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations Branch of the Family Court of Philadelphia. Date: ~ ~ ~ 3 _ ~ Print Name (Defendant) Q Signature (Defendant) z_. ~ ~~ ' s ~ ~~ fU Vi t=: ~!h .'~'~ `.ell '~Y~` _.e ~ \ In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez Plaintiff V. Term, 2 Case Number: 2007'05015 Peter Lopez Defendant And in the interests of (minor children) Mia Gisella Lopez (Age: 2) Acknowledgement (Plaintiff) THE STATE OF: PA COUNTY OF: Cumberland ~ ` r' /y!!-tif~l~F~ 2 G~ On this dfD day of ~, before me, a Notary Public, the undersigned officer, personally appeared Tara L Lopez, known to me to be the person whose name is subscribed to this written instrument, and acknowledge that (s)he executed the same for the purposes therein contained. A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on /fttqus'4' 22 LOo'1 I ,the Plaintiff, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and nintey (90) days have elapsed from the date of the filing of the Complaint for Divorce. All information contained within the attached documentation is true and correct to the best of my knowledge, information and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Maritral Settlement Agreement documentation. Date: NO i~ern der Z ~ 2 007 Trr L ez Print Name (Plaintiff) r t Signature (Plaintiff) SW..O.,$N TO AN SUBSCRIBED BEFORE ME by the said ~ /~ ~ / i~'~'+~ ~ L.O~Z- on this ~`~ ~/~, yb~ ~o certify which e d and seal of office. No y Public, State of PA Notary Seal COMMONWEALTH OF PENNSYLVANIA My commission expires: ~ NOTARIAL SEAL MI AEL R. CARANCI, Notary Public Lemoyne Boro. Cumberland County My Commission Expires June 15, 2010 ca © ~ -r~ -~) n'tr~': ~.R : ~ ~"~ ~rt~- ..~ cry : N ,. ~~ ~ .~ r ~ `~ rn <-=' = ~+ c:: 2 ~ ~ c, r ~ In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Terra L Lopez Plaintiff V. Peter Lopez Defendant And in the interests of (minor children) Mia Gisella Lopez (Age: 2) Term, 2 Case Number: 2607 "050(5 Acknowledgement (Defendant) THE STATE OF: PA COUNTY OF: Cumberland .~. ~/ On this ~ day of /VOd~MY1~.'r' , 2007 ,before me, a Notary Public, the undersigned officer, personally appeared Peter Lopez, known to me to be the person whose name is subscribed to this written instrument, and acknowledge that (s)he executed the same for the purposes therein contained. A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on ~u~a~.s~ 22 Zook I ,the Defendant, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and nintey (90) days have elapsed from the date of the filing of the Complaint for Divorce. All information contained within the attached documentation is true and correct to the best of my knowledge, information and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Settlement Agreement documentation. Date: l ~ - '- ~o ~ O'~ `~" ~,k.~ qtr L c7 7D -~ Z Print Name (Defendan ) ~. Signature (Defendant) SWC~N~ D~ CRIBED BEFORE ME by the sai ~~ ~ /0/ ~ to rr ~- on this /y , c • ' ich and seal of office. No ry Public, State of PA Notary Seal COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL My commission expires: MICHAEL R. CARANCI, Notary Public Lemoyne Boro. Cumberland County My Commission Expires June 15, 2010 ~ ~ o ..y,. _..,, -n n ° -- ~ rn n t' CfJ ;i'° tV i7 . ~=~ ~ C> rn •• ~ ° 0 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez ) Plaintiff ) V. ) Peter Lopez ) Defendant ) And in the interests of (minor children) ) Case Number: Z~7 ~ 0~ ~rJ Judge: 2 Mia Gisella Lopez (Age: 2) AFFIDAVIT OF CONSENT (Plaintiff) THE STATE OF: PA COUNTY OF: Cumberland 1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on ~Au~Qust 22 200 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint for Divorce. 3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the Decree of Divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authoritie-sf. l Date: I~{oVernb~er 2cL, 200'] Print Name (Plaintiff) ~'L Signature (Plaintiff] _~., ~ ~ N ~ ~:.. ~ ~~ ~ .'= '- ~ ~ -~ ~ ~ Q ,,,~ In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez ) Term, 2 Plaintiff ) V. Case Number: ZOO 7 - G50 (5' Peter Lopez ) Defendant ) And in the interests of (minor children) ) Mia Gisella Lopez (Age: 2) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE. (Plaintiff) THE STATE OF: PA COUNTY OF: Cumberland 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, distribution of debts, child custody, visitation, child support, lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court. 3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a copy of the Decree of Divorce 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~I_ave~-bQr 4J Z.C~U I t f rc ~ ~~n.~? Print Name (Plaintiff) Signature (Plaintiff) ~ ~ o C7 ~ ~ ~-z? O ~~TE .~ ` ~ ~. ~.. ~~~~ N ~ r,.;~. ~ .. ~' r.-, 3ar i ~- -i ~ ~~ ~~ In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez Term, 2 Plaintiff V. Peter Lopez Defendant And in the interests of (minor children) Mia Gisella Lopez (Age: 2) Case Number: 206-05015 AFFIDAVIT OF CONSENT (Defendant) THE STATE OF: PA COUNTY OF: Cumberland 1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on ~u 22 20G~ 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint for Divorce. 3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the Decree of Divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ t., ~ S ^ ~~ Print Name (Defendant) ~.~~., Signature (Defend ) O '77 ~~ -...e ~ ~ ~ ii~~"ii ~,..,, ::. ~ ~-, O ~ ~ ~'` ~ `~ In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez ) Term, 2 Plaintiff ) V. Case Number: 2007 -{35o 15 Peter Lopez ) Defendant ) And in the interests of (minor children) ) Mia Gisella Lopez (Age: 2) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE. (Defendant) THE STATE OF: PA COUNTY OF: Cumberland 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, distribution of debts, child custody, visitation, child support, lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court. 3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a copy of the Decree of Divorce 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ ~' ~ ~ ~ O 1 ~ ~k e.~' Lo Z,2 Print Name (Plaintifij pe~erK~E~, Signature (Plairttiffl 1d~tl~ ~ 0 0 f~ v ~*+ ~ -~-. ~~ c~ N ~~ :_:: ~ a_ ~~-- o ~~~a f--, ~ ~: ~ ~a ~ , ~ . + ~ e~ ~ ~ .~ In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Tara L Lopez Plaintiff V. Peter Lopez Defendant And in the interests of (minor children) } Term, 2 Case Number: 20~"I.OSO 15 Mia Gisella Lopez (Age: 2) Praecipe to Transmit Record To the Prothonotary: Kindly Transmit the Record, together with the following information, the Court for entry of a Decree of Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and Manner of Service of the Complaint for Divorce: Approximate date of service: Type of service: Opersonal or Ocertified mail. 3. Complete Paragraph (a) or (b). (a) date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the Divorce Code: By Plaintiff: , By Defendant: , (b) date of execution of the Affidavit /Consent Waiver required by Section 3301 (d) of the Divorce Code: By Plaintiff: , By Defendant: , 4. Related Claims Pending: None. ~ ~ Date: ~ ~Ve'Yrl U2~C~' ~~ _,~-. -1~~ ~ Z Print Name (Plaintiff) ~y[g~) ~,, Signature (Plaintiff) Mailing Address: PO Box 37, Grantham, PA, 17027 Phone: 717-796-5958 ~ C'„: ' ~ ~ o d -.~ --~ TJ C:'Y` ..~ E~ ~ ~ ry ~~ -f .,.. ~" i", '~ Q ~ ~ {mil ~ -t ~ ~~ ~, ~-- ' ~ --1 ~ "~Cy -- ~ D "{ IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA In re the Marriage of: Tara L. Lopez, Plaintiff v. Peter Lopez, Defendant And in the interests of minor children Mia Gisella Lopez (Age 3) Term, 2007 Case No. 05015 ACCEPTANCE OF SERVICE I, Peter Lopez, am the defendant in the above-captioned matter and hereby acknowledge that I have received, on or about the 27th day of August 2007, a copy of the Divorce Complaint filed on August 22, 2007 Date: ~ -a S ~ ~ Sworn~nd subscribed to before me this ~S day of ~ ~.~ a r 2008. ___ // f ~ ,J I Notary Public ..~t~. Peter Lopez COMMONWEALTH_OFPENNSYLVANlA Notarial Seal Tina M. Robertson, Notary PubNc My CommieaiortTWP~~ Ctmberiand Cotmty E~ires Nov. 15, 2011 Member, Pennsylvania Association of Notaries ._ I N THE COURT OF .COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~~;,, y. No. ~Oa7-05015 veRSUs DECREE 1N DIVORCE AND NOW, v~~y `T~~ ~~ ~W", 1T IS ORDERED AND DECREED THAT ~CR0.a L. 1,.dQ~Z. PLAINTIFF, AND l ~+.~~~ ~O~C~ ,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; PROTHONOTARY ~~~ ~ ~~' '`~~ ~v- /~' -~ e%~-~ ~ G~''-° '~~ -~~ gip' ~~' ~ i