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Home My WebLink About08-6130o j ELISE NELSEN, vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ALEXANDER GALLEGOS, Defendant CIVIL ACTION -LAW NO. 08 - (Q ~ ~ CIVIL TERM 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 divorce or annuhnent 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 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, 17013. 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, GO TO OR TELEPHONE 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 INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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, Pennsylvania, 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. ELISE NELSEN, vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ALEXANDER GALLEGOS, Defendant CIVIL ACTION -LAW NO. 08 - G / 3o CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Elise Nelsen, an adult individual, who resides at 20 N. Pitt Street, Cazlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Alexander Gallegos, an adult individual, who resides at 452 Casselman St., Chula Vista, California, 91910. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 31, 2002 in Deposit, New York. 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 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: 10 ~ l y ~ O --T-T Respectfully submitted, BAYLEY & MANGAN Mazk F. Bayley, quire 17 West South St. Cazlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff ELISE NELSEN, vs. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ALEXANDER GALLEGOS, Defendant CIVIL ACTION -LAW NO. 08 - CIVIL TERM IN DIVORCE VERIFICATION I, ELISE NELSEN, 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 unsworn falsification to authorities. Date: ~ / ~~ ' Elise Nelsen, aintiff ~, (~ ~i ~ 4 ~ vvvv W~ O C3 °; ~ ;~'~` ,~,. ~~~' ~ ~ C+J I.. AFFIDAVIT OF SERVICE commorwwaith of Pennsylvania Case Number. 08-6130 Pk*. Elise Nelson VS. Defendant: Alexander Gallegos For: Bayley & Mangan County of Cumberland Common Pleas Court Received by Pennsylvania Professional Process Svc. to be served on Alexander Gallegos, 436 North Euclid Ave ., Apt.12, Pasadena, CA 91101. 1, Can o Palacios being duly swom, depose and say that on the - 10thday of DRcPmtpr , 20Q9 at 5 U? .m., executed service by delivering a true copy of tine o , Divorce, Complaint Under Section 3301(c) of the Divorce Code, Acceptance of Service, LeM rr i -i with state statutes in the manner marked below: tr r n z? INDIVIDUAL SERVICE: Served the within-named person. W r- r i= ::a? () SUBSTITUTE SERVICE: By serving as r- C - 0 () NON-SERVICE: For the reason detailed in the Comments Below C7 c-7 () OTHER COMMENTS: I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. D. AzMI Commission # 1840536 Z Notary Public - California > z Orange County M Comm. Ex cress Ma X013 Subscribed and Sworn to before me on the 14 day PROCESS SERVER 8 6204 of December 2009 by the afGant who is Appointed in accordance 17=1 me. with State Statutes Pen nsyhrania Professional Process Svc. NOTARY PUBLIC 48 W. High Sty P.O. Box 1148 Carlisle, PA 17013 (800) 863-2341 Our Job Serial Number: 2009000582 CopyApht O 1M-20X D@bb=e Services, Mo. - PMom S~s Toolbox VSA Aj n ` 7011 ELISE NELSEN, VS. ALEXANDER GALLEGOS, Defendant CIVIL ACTION - LAW NO. 08 - 6130 IN DIVORCE AFFIDAVIT OF CONSENT C') -rs m CIVIL' KZ-!! ?- ' c-) Z c= - 5. ? w 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on October 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff 6 /'?&/ 1) rlk??i Date Elise Nelsen JUN 2 0 2011 ELISE NELSEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNgL)9*NA VS. ALEXANDER GALLEGOS, Defendant -0:r --q rnm =-n ra CIVIL ACTION - LAW ? t ? NO. 08 - 6130 CIVILAkm:6 --lo IN DIVORCE "<° ?' te' w ° r AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on October 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. 14 20tt 0 Date Alexander Gallegos ELISE NELSEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CNIL ACTION -LAW n r ALEXANDER GALLEGOS, NO. 08 - 6130 CIVIL M` xa -I =-n Defendant IN DIVORCE S rte- rz r- -<? D O o D r -:r -+c) e c? ? ?? z -n -n WAIVER OF INTENTION TO REQUEST -tea ° ENTRY OF A DIVORCE DECREE UNDER ..? 43301(C) OF THE DIVORCE CODE ' 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 THE FOREGOING 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 Elise Nelsen ELISE NELSEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. ALEXANDER GALLEGOS, Defendant 1. 2. CIVIL ACTION - LAW NO. 08 - 6130 IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. CIVIL TL3tN%?g z r of r? -?ca .[C) i =-n ° C 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 THE FOREGOING 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. V, r\ e 1 y Date Alexander Gall os BAYLEY & MANGAN Mark F. Bayley, Esquire Attomey I.D. #: 87663 17 West South Street Carlisle, PA 17013 (717) 241-2446 ELISE NELSEN Plaintiff VS. ALEXANDER GALLEGOS, Defendant FILED-OFFICE 1. THE PROTHONOTAR 2011 JUL -B PM 3: 44 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-6130 CIVIL TERM 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: Filed on October 14, 2008 and Defendant was personally served on June 14, 2011 (a copy of Affidavit of Service is attached). 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff on June 30, 2011 (original is attached); by the Defendant on June 28, 2011 (original is attached). 4. Related claims pending: None 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing (original is attached). Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing (original is attached). Date: ? /I J, z Mark F. Bayley, Esgtfire BAYLEY & MANGAN 17 W. South St. Carlisle, PA 17013 717) 241-2446 Supreme Court I.D. # 87663 ELISE NELSEN V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALEXANDER GALLEGOS NO'. 08-6130 DIVORCE DECREE AND NOW, it is ordered and decreed that ELISE NEL EN , plaintiff, and ALEXANDER GALLEGOS , 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 By the Court, AUesL J. t'rotnonotary ?p fi' ? Ga' J