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Home My WebLink About07-5303~`; ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE Defendant "N THE COURT OF COMMON PLEAS OF UMBERLAND COUNTY, PENNSYLVANIA NO. O'~- d' 3b 3 ~.~ T~~.-, CIVIL ACTION - 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 at: Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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 F±1~TD OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 r ANTONIO M. ALATORRE; Plaintiff v. CARLA M. ALATORRE Defendant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - IN DIVORCE 1. Plaintiff is Antonio M. Alatorre (SS# 163-64-1680), a citizen of Pennsylvania whose primary residence is located at 435 West Louther Street, Cazlisle, Pennsylvania, 17013. as 1~ Ih, 2. Defendant is ~~er~xe M. Alato*re (SS# 193-58-1352), a citizen of Pennsylvania whose primary residence is 120 ~Hickorytown Road, Carlisle, Pennsylvania, 17015. 3. Plaintiff and Defendant are sui~uris. Plaintiff has been a bonafide resident of the Commonwealth of Pennsylvania for at least six months immediately ,preceding the filing of this Complaint. 4. The parties are husband and wife and were lawfully married on June 1, 2007 in Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. There was no children born of this marriage. COUNT I. Request for No-Fault Divorce Under 3301(c) and (dl of the Divorce Cade 9. Paragraphs one through eight aze incorporated as if fully set forth herein. .~ 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. 12. Plaintiff has been advised of the availability of counseling and that Plaintiff and Defendant have the right to request the Court to require the parties to participate in such counseling. 13. Defendant is not now and has n.~ ver been a member of the armed forces of the United States. WHEREFORE, if both parties file affidavits to a divorce after ninety days have elapsed from the filing of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(c) of the Divorce Code. In the alternative, should the parties continue living apart for a period of time greater than two yeazs, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(d) of the Divorce Code. Respectfully submitted, DATE: .L 2 0 J. Rosen, Esquire for Plaintiff 11 1 North Front Street H 'sburg, Pa 17102 ID # 10625 (717) 234-4583 e,•' , ~. ANTONIO M. ALATORRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. CARLA M. ALATORRE :CIVIL ACTION - IN DIVORCE Defendant VERIFICATION I, ANTONIO M. ALATORRE, hereb:~ verify that the information contained in the foregoing Complaint is true and correct to the best of my knowledge, information and belief. I also understand that false statements made herein are subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. DATE: ~ g1 ~~ ~~~~ ` ANTONIO M. ALA ORRE s~ ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 'CIVIL ACTION - IN DIVORCE CERTIFICATE OF SERVICE AND NOW, thisv~ day of , 2007, I, Aimee L. Paukovits, for the Lawfirm of Krevsky & Rosen, P.C., on behalf of Plaintiff, ANTONIO M. ALATORRE, hereby certify that I have this day served a copy of the Complaint in the above-captioned matter, via First Class, Certified, U.S. Mail, on the fotowing: CARLA M. ALATORRE 435 WEST LOUTHER STREET CARLISLE, PA 17013 Aimee L. Paukovits 1101 North Front Street Harrisburg, PA 17102 (717) 234-4583 ~ ~ , ~~ ~~ ~~ ~ r v J o ~ ~ J v~ V °O a CJ C O ° }~, -~ _ ~ r=~ ~- S s ~ -r t'r; _ C1"1 ~ ~ { ~ {~ 1 ~ ''_ ~ T3~~ 1~ : - N ~ - i tT'i ~" ~ fX7 "~ i ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5303 CIVIL ACTION - IN DIVORCE AFFIDAVIT OF SERVICE I, Lawrence J. Rosen, attorney for Plaintiff, Antonio M. Alatorre, served the Notice to Defend and Complaint in Divorce on the Defendant, Carla M. Alatorre relative to the above matter. Said service was made on September 19, 2007 by U.S. Certified Mail, returned receipt requested at the following address: CARLA M. ALATORRE 435 WEST LOUTHER STREET CARLISLE, PA 17013 Lawrence J. Rosen, Esquire Attorney for Plaintiff 1101 North Front Street Harrisburg, Pa 17102 ID # 10625 (717) 234 ^ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the maiipieoe, or on the front if space permits. 1. Article Addressed to: C~.~ (~ M - A I ~-~ rt.~ ~f 3 S' ~ e s + ~ o~ S~~- ~.c.~ l ~s(e. ~ ~~. I `Io 13 ^ Agent by (Prirrt~iNarrre) ~ C,.,p~te of Delivery D. b delivery address different from item 1? O Yes ff YES, enter delivery address below: D No 3. Se ~ lype ~Certifted Mail O Express Mail ^ Registered ^ Return Receipt for Meroharrdise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery'1(Extra Fee) ^ Yes 2. Article Number (Transfer from service label) ? d I7 ].~ 19 4 D t] ~ ~ 4 16 8 6 4 511 PS Form 3$11, February 2D04 Domestic Return Receipt io25ss-a2-M-~5ao C? C_~. ~~ r- L-:a -s-1 " '' ---a ~', ~-rz ~5 r) ~ Z - 1 '. _~--~ ::~ 4.~_. r } ~- E~i~ ,J ~,~.y_~F~ ^i ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5303 CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 5, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken. Ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of final decree of divorce after service of notice of intention to request entry of decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 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: ~`1~~, ANTOl~JIO M. ALATORRE coo ' - ~ r - c~ a~ rrTt r~: ~. ..+t `~ :" ~ . ~ . u7 =~, ~' ...e ;. ~~ ~ ..- y.~ N .~ ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5303 CIVIL ACTION - IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose my 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. DATE: ~~ ~ _ ANTONIO M. ALATORRE ra ~ ~ '°~ T~j ~ ,w:. ~' t~ ~ ~. ~.~ '~ ~_ ~ ~_ ~' ~ ~ f ~ W -+C .~'" ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-5303 CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 5, 2007. 2. 'The marriage of plaintiff and defendant is irretrievably broken. Ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of final decree of divorce after service of notice of intention to request entry of decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 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. ~r ~ ~ DATE: ,~J D -~~2~ _ __ . CARLA M. ALAT RRE C~~ n,, b ~~ ~` e Z- ~ '~ ~~ { ,. , ~ ~~~ '~r ~~ ,ti < - ~. f •.- r 'r" °'~, ..~ ~`~. ,.~. ANTONIO M. ALATORRE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 07-5303 CARLA M. ALATORRE :CIVIL ACTION - IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose my 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. DATE: S CARLA M. AL TORRE ~' ~ ~ ,°- c~ ~ --~-r r_ : ~y~} ~~ ~~ ~{ ttk „ ~-~ r.+4 + ~/ s+y~ .aq~. ANTONIO M. ALATORRE, Plaintiff v. CARLA M. ALATORRE, Defendant IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA N0.07-5303 CIVIL ACTION - IN DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Grounds for divorce: Irretrievable Breakdown under Section (x) 3301 (c) the Divorce Code. 2. Date and manner of service of the Complaint: 9/19/07 via First Class. Certified Mail. 3. Date of execution of the Affidavit of Consent & Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301 (c) of the Divorce Code required by Section 3301 (c) of the Divorce Code: by the Plaintiff on Apri125, 2008; by the Defendant on November 25, 2008. 4. Related claims pending: n/a. ~~~~ ~ Lawrence J. Rosen, Esquire Attorney for Plaintiff ~~ ~- ..~, -~ --~ t .'~ ;j ~J ~3 ~/3 ..,. .., . y ,,.... ,+ „) ~i~ut~~~~ M A\R-meQc v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA l..l'~~L.P~ N~ - P.~ ~u~ No. D`7 - ~ 2A 3 DIVORCE DECREE AND NOW, S~ ~, ~Od~_, it is ordered and decreed that ~~~~~ ~ . ~~~~~~ ,plaintiff, and I~~Q-l!~ l ` ~ . ~ ` T~ Q~, ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") ~~~ By Attest: / ~. ry ~~~ ~~~ ~~'~ `^ ~~ ~ ~~ ~h ~ i, y,,,,~a...~ `+ •.,.~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, j'j7, PENNSYLVANIA ~J~I n7~1't 1 D LQ'_~ Plaintiff rn vs LL ~L~JY~CL V~Q~ r-'~i Defendant • File No. %t 0 d 7` a5.3 0~ : IN D1VOItCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /defendant in the above matter, [select one by marking "x"J prior to the entry of a Final Decree in Divorce, or ~ after the entry of a Final Decree~in D/~ivorce dated a ~ ~ D9 hereby elccts to resume the prior surname of ~ V OC,~fZ ,and gives this written notice avowing his l~gintention pursuant to the provisions of 54 P.S. 704. Date: .~"~' j1~ / ~~4~ -_..._ Signature a ~~ Signature of name being resumed COMMONWE TH OF PENNSYLVANIA COUNTY OF On the Jr~ day of ~ _, 200,, 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 aclaiowledged 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. aorapuu. sEA< CARLISLE Ct~NNBN£ORI~D ~p~y ~ al'HOUSE MY COMMISSION DQ'IRES JANUARY 4, 2010 Notary ublic ~, F, ~~ ~:: ~~` a ut `~~ Z :,