The URL can be used to link to this page

Home My WebLink About08-2033Danielle H. Clark, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Ricardo M. Alamo, Defendant pg-? NO. BT- CIVIL TERM 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 right 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, Cumberland County Courthouse, Carlisle, 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 MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE LAWYER, GO TO OR TELE PHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford St. Carlisle, PA 17013 (717) - 249-3166 A. 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 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Danielle H. Clark, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Ricardo M. Alamo, Defendant NO. 07- a 0 3 3 CIVIL TERM DIVORCE COMPLAINT UNDER TITLE 23 Pa C S &&3301(c) and (d) OF THE DIVORCE CODE The Plaintiff, Danielle H. Clark, by her attorneys, the Family Law Clinic, sets forth the following causes of action in divorce: 1. Plaintiff is Danielle H. Clark, who currently resides at 28 Appalachian Trail Road, P.O. Box 173, Gardners, Cumberland County, Pennsylvania, 17324. 2. Defendant is Ricardo M. Alamo, who currently resides at 373 Gardners Station Road, Gardners, Adams County, Pennsylvania, 17324. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 15, 2005, in Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since August 2007. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the marriage. Date ROB &T E. RAINS THOMAS M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-3696 Fax: (717) 243-3639 Respectfully submitted, VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge 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. Dated: XZ2,,,? y! aacad-- Danielle H. Clark H r- :J r?. i? Danielle H. Clark, Plaintiff V. Ricardo M. Alamo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE OT - z NO. 9r- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Danielle H. Clark, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date a'? ./&::? Llk ROBE E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ?? C_ ? c... _, -Fi C.,Y,,.) .mar ?..? _r _,,.. __ ± . -•-, - - ? ??? Danielle H. Clark, Plaintiff V. Ricardo M. Alamo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 08-2033 CIVIL TERM CERTIFICATE OF SERVICE I, Marc Aoun, Certified Legal Intern, Family Law Clinic, hereby certify that I served a zi N W ? OD j O? Ln O' _A •a a =w n' w rr _ G L_ 1 f t? true and correct copy of the Divorce Complaint on Ricardo M. Alamo, residing at 373 Gardners Station Road, Gardners, Adams County, Pennsylvania, 17324, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Ricardo M. Alamo, he 4' day of April 2008 as evidenced by the attached green card. grtifi d egal Intern A "v Anne ac "i ald-Fox, E.. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 art T .+^ Op A Danielle H. Clark, Plaintiff V. Ricardo M. Alamo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 08-2033 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on March 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 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 711 OZ L. - W cg"'L Danielle H. Clark, Plaintiff 't'? t"?' c..- G,,, ?? ? ? ! ? '?t? ?. ?? ? ?? - Y'r'? ??v :i ? ? ? ? .i4 „ Danielle H. Clark, Plaintiff V. Ricardo M. Alamo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 08-2033 CIVIL TERM 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 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 7 f -7 in $ G e Danielle H. Clark, Plaintiff r-a ca ..? w Danielle H. Clark, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Ricardo M. Alamo, Defendant NO. 08-2033 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on March 31, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the 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 _OfZ&L Ricardo M. Alamo, 11e'fendant rx tv r' Danielle H. Clark, Plaintiff v Ricardo M. Alamo, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 08-2033 CIVIL TERM 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 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 unworn falsification to authorities. Date Ricardo M. Alamo , De endant L 1 4J ^ 2 1 e? Danielle H. Clark, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW V. : IN DIVORCE AND CUSTODY Ricardo M. Alamo, Defendant : No. 08-2033 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: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Defendant, Ricardo M. Alamo on April 4, 2008. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by Plaintiff- July 7, 2008; by Defendant- July 15, 2008. 4. Related claims pending: none 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: July 9, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary : July 2,5, 2009. gn4 Dat MICHAEL LIGHTF1 Certified Legal Intern A ACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff ? ? =5' ??t A. ?` ? '?"- -rs ?-r?-•- r'r " rc ? ? y ??.. ?' ' -? : - ?__? ?? . ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Danielle H. Clark, Plaintiff No. 2008 2033 VERSUS Richard M. Alamo. Defendant DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT Danielle H. Clark PLAINTIFF, AND Richard M. Alamo ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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 ,emu, jv )Jff -? 'sa