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Home My WebLink About08-0918a CARMELITA MANGALINDAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PEDRO E. MANGALINDAN, NO. 4/- Defendant IN DIVORCE NOTICE TO DEFEND 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 SAIDIS, FLOWER & LINDSAY SAIDIS, FLOWER &z LINDSAY 26 West High Street Carlisle, PA By UafNu Matas, squire Su a Court ID # 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff CARMELITA MANGALINDAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 48 x'113 C?vrl ??.? PEDRO E. MANGALINDAN, Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Carmelita Mangalindan, an adult individual currently residing at 720 Forge Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Pedro E. Mangalindan, an adult individual currently residing at 168 Km Baokok, Nagbalayong, Morong, Bataan, Philippines. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 10, 1968, in Floridablanca Pampanga, Philippines. 5. There has been no other prior action for divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to ?RR ? FI LINDSAY 26 West High Street Carlisle, PA request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 7. The parties' marriage is irretrievably broken. 8. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P. S. Section 3301(c) of the Domestic Relations Code. Respectfully submitted, Marylou tas, Esquire Attorney o. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attomey for Plaintiff SAJDIS' FLOWER & LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904, relating to unsworn falsifications to authorities. DATE: -Z Carmelita Mangalindan, P6 ff IS, ? FLOWER WERR & LINDSAY 26 West High Street Carlisle, PA rri ?r co l r CARMELITA MANGALINDAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PEDRO E. MANGALINDAN, NO 9 S Lrv, C` ft rN^ Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Carmelita Mangalindan, Plaintiff, to proceed in forma au eris. I, Marylou Matas, attorney for the party proceeding in forma au eris certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Respectfully submitted, J Z,? Marytas, Esc?t&e Attorne ... 0.84919 Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAMIS FLOWER '& LINDSAY 26 West High Street Carlisle, PA C7 N C f = -n cry ? ?. co eri co K.?';.. la 1 fV ?7 CARMELITA MANGALINDAN, Plaintiff V. PEDRO E. MANGALINDAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-918 IN DIVORCE ACCEPTANCE OF SERVICE I, Pedro E. Mangalindan, Defendant, accept service of the Complaint in Divorce in the above-captioned matter. Aa ?_ dro E. ngalindan SAIDIS, FWVVER & LIlVDSM K I 1-IAW 26 West High Street Carlisle, PA Dated: March 3, 2008 ? Q 3 rr: .?:?.: ?=?' ss ? r ? s::. ??t ? ? ? ? ..:?- ? y . , ? ..? r` ? ?cfi rri -1cj ? ? . -c CARMELITA MANGALINDAN, Plaintiff v PEDRO E. MANGALINDAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-918 - CIVIL. TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed February 8, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. V Date: _2 d - A .QM Carmelita Mangalindan PLAINTIFF'S 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 of Divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAWIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. 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 " ? ` OX08 i rmelita Mangalindan JUN 0 9 2008 r; x {gyp CARMELITA MANGALINDAN, Plaintiff V. PEDRO E. MANGALINDAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-918 - CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce. Code was filed February 8, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: edro E. M galindan DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAWIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. 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: Li '-?? ? 1 Pe ro E. Mangaf dan PO CO '., w C_ ; CARMELITA MANGALINDAN, Plaintiff V. PEDRO MANGALINDAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-918 - CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on March 3, 2008, via regular U.S. mail. Proof of service was filed with the Court on March 5, 2008 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: On June 6, 2008 and filed with the Prothonotary on June 11, 2008. By Defendant: On July 22, 2008 and filed with the Prothonotary on July 28, 2008. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: On June 6, 2008 and filed with the Prothonotary on June 11, 2008. By Defendant: On July 22, 2008 and filed with the Prothonotary on July 28, 2008. SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY --X?oa't q?L -?60 Mary o atas, ire Supre Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 ?, ? s t: C r :..3 -,,? t_ `. ? ? ?? - 2`'..r ?. -? ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. CARMELITA MANGALINDAN VERSUS PEDRO MANGALINDAN No. 08-918 DECREE IN DIVORCE AND NOW, 'j01 , ZOo?, IT IS ORDERED AND CARMELITA ANGALINDAN DECREED THAT , PLAINTIFF, AND PEDRO MANGALINDAN 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; BY THE COURT: ROTHONOTARY ???' '? r Ica I£ -72