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Home My WebLink About03-6655 KARENA INFANTE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - DIVORCE OMAR INFANTE Defendant NO. 03 - I./..SS C", u ~ l '--r E.IUYJ NOTICE TO DEFEND You have been sued in court. If you wish to defend aqainst the claims set forth in the followinq paqes, you must take action 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 aqainst you by the court. A judgment may also be entered aqainst you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other riqhts ~portant to you, includinq custody or visitation of your children. When the qround for divorce is indiqnities or irretrievable breakdown of the marriaqe, you may request marriaqe counselinq. A list of marriaqe counselors is available in the Office of the Prothonotary at the first floor in the Dauphin Court Courthouse, Front and Market Streets, Harrisburq, Pennsylvania. 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 ~Y 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 2 LIBERTY AVENUE CARLISLE, PA 17013 1-800-990-9108 KARENA INFANTE Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - DIVORCE OMAR INFANTE Defendant NO. 03 - ~I-~...s C.;~,-L~) COMPLAINT IN DIVORCE AND NOW, comes the plaintiff, Karena Infante, by her attorney, Gail Guida Souders, Esquire, and pursuant to Section 3301 (c) of the Pennsylvania Divorce Code, seeks to obtain a Decree in Divorce from the Defendant, Omar Infante, upon the grounds set forth: 1. The Plaintiff, Karena Infante, is an adult individual residing at 212 Noth 2nd Street, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant, Omar Infante, is an adult individual residing at 95th AG A/Btry, Fortsill, Oklahoma 73503. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months ~ediately previous to the filing of this Complaint. 4. Defendant was a bona fide resident of the Commonwealth of Pennsylvania but left for military service on April 22, 2002. 5. The Plaintiff and Defendant were married on November 22, 2002 in Winchester, Virginia. 6. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling and does not request the same. 7. There have been no prior actions of divorce or annu~ent between the parties in this or any other jurisdiction. 8. The Plaintiff and Defendant are both citizens of the United States of America. 9. The Defendant is a member of the United States Armed Forces. 10. The Plaintiff and Defendant have no minor children. 11. The cause of action and Section of Divorce Code under which Plaintiff is proceeding is the marriage is irretrievably broken under 23 Pa. Const. Stat. ~ 3301 (c) . WHEREFORE, The plaintiff requests this Honorable Court to enter a Decree of Divorce. Gail Guida Souders Attorney for Plaintiff Guida Law Offices, P.C. 111 Locust Street Harrisburg, PA 17101 Supreme Court ID # 68740 I, Karena Infante, 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 DATE: ~'t710'3 I':J ~ ~ ~ ~ o \ tv ..... C/) t ~ ~ II) 0- ~ t '< o r- ....., = = ._w ,~::; a r'l c, C-.) CJ f-.' r'>..) c.:; C' --n --j F.lp~ "T' ,n f;~:6 ;),~ ~ KARENA INFANTE : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. OMAR INFANTE NO.: 03-6655 CIVIL TERM CERTIFICATE OF SERVICE-; I hereby certifY that on January 12, 2004, I served the Divorce Compliant upon the person and in the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403. Service by Certified U.S. Mail to: Omar Infante 95th AG A/Btry Fortsill, OK 73503 ~~ Gail Guida Souders, Esquire Guida Law Offices, P.C. III Locust Street Harrisburg, PA 1710J 7J 7-236-6440 Dated: January 20, 2004 - o . CO . , . . U"" .. _ '.. . M . .'._ _. ._. e . '" . _ . " . "0". ~ F00Jft iF7t>.(; M ' '.' . '" Postage $ 0 0 Certified Fee 0 0 Return Reciept Fee (Endorsement RequIred) 0 Restricted Delivery Fea .-'l 0 (Endorsement Required) .-'l $0.60 $1.75 $0.00 m ToraIP_e.Fees $ $4.65 o to R ~iApi<l-M.C&L_._-J;_'I1:fm:l:~__ .' J ;:.o~-;;;4~;---~~-F--.AL~~i~~~~;:_-_~_~::_-_~-_- :11 II =l,~," . -'TJ;rIlll"'.'" "".- -."....c.___.._,..._..,....,...., .. i ~_..........;.;.......:-..o...;..;.~__ Exhibit A <"" -urn ITlfn 2}Z (;-!)~ ~::=O :to ==n )>c: Z ~ r-.' ,,::::;. =::: , , .c'r"j <- ..~ T f;'l I,; C. \ ,~ ) " " 1-' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ~ PENNSYLVANIA lj)a T rifJ 111 k : Plaintiff File No.(1CJo3- 0 ww5S IN DIVORCE Vs () mllf2 Tnfanfc:..- Defendant 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 L after the entry of a Final Decree in Divorce dated q I a I oc/ hereby elects to resume the prior sumame of Karena LCrnte r. <) I ,~d gives this g his / her intention pursu m;lsloof NOTICE TO RESUME PRIOR SURNAME '-- gg~i~:g~~~Nfct~rNIA ) On the d9!: day of ~ ~I ~ , 200 'I, 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. CluaL(1 ~/,kj~~ ~F-Notary Public i NOTARIAL SEAL i C' AUDIA A. BREWBAKER, NOTARY PUBLIC , Carlisle Boro, Cumoerland Counly , M, comrr"sslOn Expires April 4, 2005 ".-'- .,.---.. .,--_.._._-_........~. --~ ~ "" " '^ V'\ "<,\ " 1 >J \:) \J '\ ~ t ,.., <g :.c- ~ -0 N ...0 ~ -0\:71 t):)(f. .(..- ..-- ~;~t:> ~i~; ~::. ~ ~ 9.-n r\"\r: :;\?,rTI i'j9 ,-~"\~ "1::13 ,J~ -, ,c.. o .:A '"1:";' ~ ~ q N U\ . . . . KARENAINFANTE Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS : CIVIL ACTION - DIVORCE OMAR INFANTE Defendant : NO. 03-6655 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on December 30, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed form the date of filing and service of 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 '%/6 kil ---..,." '" C::5' .e;v? r" ' " .j... -,~.... r~ .. o -r.-. . KARENAINFANTE Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS : CIVIL ACTION - DIVORCE OMAR INFANTE Defendant : NO. 03-6655 CIVIL TERM AFFIDA VIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on December 30, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed form the date of filing and service of 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 th~t se statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to mis' n falsification to authorities. ,/ /,' ,}/ DATE 3 {5 ~ul o'-} ( cs ,e~? -~.. o -'-1 :~ -,.~} (.~=~. ~.=.. -''''.., KARENAINFANTE Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS : CIVIL ACTION - DIVORCE OMAR INFANTE Defendant : NO. 03-6655 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 the Court enters a divorce decree 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 Jk /6Cf I ~ ~ ,...'" C:'.:''::> ~ o -n r-<> .j:-' -'t:1 .....i2.. N (=~I ,- ~. KAREN A INFANTE Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERI..AND COUNTY, PENNSYLVANIA VS : CIVIL ACTION - DIVORCE OMAR INFANTE Defendant : NO. 03-6655 CIVIL TERM WAIVER OF NOTICE OF' INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 {c) OF THE DIVORCE COnE 1. 1 consent to the entry of a final decree in 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 J will not be divorced until the Court enters a divorce decree and that a copy of the decree will be sent to me immediately after it is tiled 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. /~/7 / // 7 / / DATE.~3 D :),,->\ c'-l ~ ~ ,.,..... ~".-<....' ._~ -,- f'J .J. .. 01 KARENAINFANTE Plaintiff VS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - DIVORCE OMARINFANTE Defendant NO. 03-6655 Civil Term PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for Divorce: irretrievable breakdown under Section 3301 (c) ofthe Divorce Code. 2. Date and manner of service of the Complaint: January 12,2004 by Certified Mail. 3. (a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce code: by the plaintiff August 6, 2004; by defendant July 30, 2004. 4. Related claims pending: No other claim pending. 5. Date and service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301 (dO (1) (i) of the Divorce Code. 6. Date of Plaintiff's Waiver of Notice in Section 3301 (c) Divorce Code was filed with the Prothonotary: July 12, 2004 7. Date of Defendant's Waiver of Notice in Section 3301 (c) Divorce Code was filed with the Prothonotary: July 12, 2004 &i~ ~ €S ~ I"-l (:,:::'.). C::.:..1 -1;- C'.:1 C"; ;Ii ;Ii ;Ii ;Ii ,;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii"';lioti ;Ii oti"'oti"';Ii"';Ii;li "';Ii ;Ii'" "''''oti oti "'''';Ii''' oti;li"'oti"'''''''''';Ii;li '" "'''''''''''''''''''''' "''''''' IN THE COURT OF COMMON PLEAS ;Ii OFCUMBERLANDCOUNTY ;Ii ;Ii ;Ii '" ;Ii ;Ii ;Ii '" ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii '" '" ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii oti STATE OF Karena Infante VERSUS Omar Infante ;Ii AND NOW, PENNA. No. 03-6655 DECREE IN DIVORCE ~pr~.A<< .2 , :1.00'1 ,IT IS ORDERED AND ;Ii ;Ii oti ;Ii ;Ii oti ;Ii oti ;Ii ;Ii ;Ii ;Ii DECREED THAT Karena Infante , PLAINTIFF, AN D Omar Infante , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii ;Ii;li ;Ii;lioti"';Ii"'oti"';Ii "';Ii '""';Ii;li;li;li"';Ii "';Ii"'''''''''';Ii''' ;Ii J../fJ "N f J. PROTHONOTARY ;Ii "'''' "';Ii"';Ii"'~"';Ii;li"''''~ -h z ~ ~#, M- ['-,9 ~P'%~~.rrP ~t?'~~6 : ~ -- . > ./-.:......! I' ~ . 4\5;'..,.s-' . . . ~