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Home My WebLink About04-0908OSVALDO ACUNA, VS. BETSY ACUNA, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. gZ> ~ - qc> ~ Civil Term 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 divome or armulment 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. Where the ground for the divome is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage coanselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD 'rAKE 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 Cotmty Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 OSVALDO ACUNA, Plaintiff VS. BETSY ACUNA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. tSq- qo~r Civil Term ACTION 1N DIVORCE COMPLAINT IN DIVORCE l. Plaintiffis Osvaldo Acuna, a competent adult individual, who has resided at 1 N. Pitt St., Carlisle, Cumberland County, Pennsylvania, 17013, since 2001. 2, Defendant is Betsy Acuna, a competent adult individual, who resides at 105 York St., 2nd Floor, Hanover, York County, Pennsylvania, 17331. 3. Plaintiffand Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiffand the Defendant were married in March 1993 in Cat'lisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plalntiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. 7. Plaintiffand Defendant have one child together, namely, Ashley Nichole Acuna, date of birth, November 13, 1998. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiffor Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. I verify that the statements made in this Complaint are tree 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. Osvaldo Acufia~ Plaintiff Respectfully submitted, ~ams, Esquire ID. No. 79465 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF OSVALD0 ACUNA, Plaintiff VS. BETSY ACUNA, De~ndant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. E)~ ~ ~-o~ Civil Term : : ACTION 1N DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated in February 2001 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 unswom falsification to authorities. r)ate: '05/ Osvaldo Acu OSVALDO ACUNA, Plaintiff VS. BETSY ACUNA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COLrNTY, PENNSYLVANIA : No. (~q--~O~ CivilTerm ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 3, 2004. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. l verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Osvaldo Acuna, Plaintiff WAIVER OF NOTICE OF INTENTION .TO REQUEST ENTRY OF A DIVORCE DECREE .UNDER §3301(c) AND §3301(d) OF THE D1VORCE CODE 1. I consent to entry ora final decree of divorce without notice. 2. I understand-that I may lose rights concerning alimony, division or'property, lawyer's fees ill do not claim them before a divorce is granted. orexpenses 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: Osvaldo Acuna, Plaintiff OSVALDO ACUNA, Plaintiff VS. BETSY ACUNA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COLrNTY, PENNSYLVANIA : : No. 04 - 908 Civil Term : : ACTION 1N DIVORCE AFFIDAVIT OF CONSENT_. ~. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 3, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 1 verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to [orities. Betsy A~un%~,~dant- ' ' WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE _UNDER §3301(e) AND §3301(d) OF THE DIVORCE CODE 1. I consent to 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 ill do not claim them before a divorce is granted. 3. 1 undemtand 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 correcl. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Betsy Acu?~a;-.D~ant ORiGiNAL OSVALDO ACUNA, Plaintiff VS. BETSY ACUNA, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 04 - 908 Civil Term ACTION IN DIVORCE ACCEPTANCE OF SERVICE PURSUAI~I.T TO PA.R.C.P 4 02{B) AND PA.R.C.P. 1920.,I I, Betsy Acuna, Defendant in the above-captioned matter, hereby accepted service of the Notice to Defend, Complaint in Divorce, and Affidavit of Sepazation via first class mail on or about April 2, 2004. I hereby waive any and all defects in service of the aforementioned Complaint or any amendments hereto. Date: ORIGINAL OSVALDO ACUNA, Plaintiff VS. BETSY ACUNA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 04 - 908 Civil Term : : 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. Ground for divorce: irretrievable breakdown under .~3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by regular mail. delivered on: April 2, 2004. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: By Defendant: 4. Related claims pending: None· 5. Date Defendant's Wmver of Notice in §3301(c) Divorce was filed w~th the Prothonotary: ~ / io l o Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: (~~Respectfully Submitted: . ,,,/-J~e Adams, Esquire // 1.~. No. 79465, {' 36//S. Pitt Stre~,,t k,,~arlisle, Pa. 1 7013 (717) 245-850.8 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OSVALDO ACUNA Plaintiff VERSUS BETSY ACUNA Defendant OF curvIBERLAND COUNTY STATE OF ,,¢'~~ PENNA. No. 04-908 CIVIL TERM DECREE IN DIVORCE AND N OW, ~~,~ (,'~ DECREED THAT Osvaldo Acuna AND Betsy Acuna IT IS ORDERED AND , PLAINTIFF, , 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; None ATTEST: .~ . - PROTHONOTARY ++++ +++ +++ ++ ++++ +++++ ++++++++++++++++++++++ + +++++ +4-++ ++++++++