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HomeMy WebLinkAbout08-4386/' f ' Charles Douglas Del Cabrera, Plaintiff V. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. el? _ 113 g'6 IN DIVORCE NOTICE 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, High and Hanover Streets, Carlisle. 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 FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. Charles Douglas Del Cabrera, Plaintiff vi. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 3 p U-IY rGIv c ``?"t Cm IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Charles Douglas Del Cabrera, who currently resides at 65 North Bedford Street, Cumberland County, Carlisle, Pennsylvania, since June, 2007. 2. Defendant is Maila Grace Gallegos Hilario Cabrera, who currently resides at 5605 N. Miltimore Avenue, Unit 2S, Chicago, Illinois, since April, 2007. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on March 29, 2007, in Cook County, Skokie, Illinois. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff is in the United States Army. 9. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: /if 24MB Respectfully Submitted ROMINGER & ASSOCIATES Mi? Mi 1 O. Palermo, Jr., Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #93334 (717) 241-6070 VERIFICATION I 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 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. Date: 17Ju, 2 *8 Charles Douglas Del Cabrera, Plaintiff Y ? d a Q J -n ITI i r?- r7l U f; "t .) D??- Charles Douglas Del Cabrera, Plaintiff V. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 08-4386 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 22, 2008 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: X(/VI?ZAi?8 Charles Dou las Del abrera Zz Sto ''y Charles Douglas Del Cabrera, Plaintiff V. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 08-4386 IN DIVORCE 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: /??SW8 Charles ouglas Del abrera 4 W Charles Douglas Del Cabrera, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 08-4386 Maila Grace Gallegos Hilario Cabrera, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 22, 2008 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: DEC 0 4 2008 Maila ra Gallegos Hilario Cabrera -rr c.' C= r C)o '.° 2 Charles Douglas Del Cabrera, Plaintiff V. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 08-4386 IN DIVORCE 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: gUa 4 2nna M ila race Gallegos Hilario Cabrera ^r? - r ) r C:7 C? Charles Douglas Del Cabrera, Plaintiff V. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 08-4386 IN DIVORCE PROOF OF SERVICE OF DIVORCE COMPLAINT EXHIBIT "A" ¦ 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 vm can return the card to you. ¦ Attach thin card to the back of the mailpiece, or on the 0nit if space permits. 1. Article Addressed to: id t4lJ Cc'a A Sigr?a .0- p Agent X 0 Addrremee B, by ( Printed Name) C. Date of Dellmy D. Is delivery address diiterent from Item 11 ? YA If YES, enter delivery address below: NrNo as 4P 3. sserylce Type Mail ta:txpress mail ? Registered ? Return Receipt for MOMWK O ? Insured mail ? C.O.D. 4. Restricted 0eNrery9 Pl*a F44 2 Article Number (rmnsterfrom service 7007 0220 0202 2521 4897 PS Form 3811, February 2004 Domestic Return Receipt 1025e542-Wl540 c . co t Charles Douglas Del Cabrera, Plaintiff V. Maila Grace Gallegos Hilario Cabrera, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 08-4386 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: July 26, 2008, by certified mail/return receipt/restricted delivery. Attached as Exhibit "A". 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff 11/14/08; by the Defendant 12/4/08. 4. Related claims pending: None 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 12/8/08. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: 12/8/08. Date: 2008 - Michael O. Palermo, Jr., Esqu 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 93334 an ?i C= }' - Charles Douglas Del Cabrera IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Maila Grace Gallegos Hilario Cabrera NO. 08-4386 Attest: DIVORCE DECREE AND NOW, ber?__ le ,? , it is ordered and decreed that Charles Douglas Del Cabrera plaintiff, and Maila Grace Gallegos Hilario Cabrera , 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.") None J. A6 ---? W1, thonotary r7 Lei " b! cal' 07 `11 Cl a * a NI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Charles Douglas Del Cabrera Plaintiff Vs File No. 08-4386 IN DIVORCE Maila Grace Gallegos Hilario Cabrera Defendant NOTICE TO RESUME PRIOR SURNAME Notice to hereby given that the Defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or x after the entry of a Final Decree in Divorce dated December 18, 2008, hereby elects to resume the prior surname of I31'lario, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: May 13, 2009 Signature Signature of ame being resumed STATE OF ILLINOIS ) COUNTY OF COOK ) On thq/.] *ay of , 200 , before me, the Prothonotary or the notary public, personally appear d 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 hands hereunto set my hand and official seal. Public OFFICIAL SEAL LOURDES HERNANDEZ NOTARY PUBLIC • STATE OF ILLINOIS MY COMMISSION EXPIRES:04/03/t0 --------------- k&e YGl , t.d?"''' r 3 ?` aaS.