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HomeMy WebLinkAbout08-7232 JOSEPH L. ORTEGA, PLAINTIFF v. SHERRY L. ORTEGA, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. b8.7a~a l~ i Vi l T,ern~ DIVORCE ACTION 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 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 (814) 486-3355, Cameron County Courthouse, 20 E. Fifth Street, Emporium, PA 15834. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 JOSEPH L, ORTEGA, IN THE COURT OF COMMON PLEAS PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 6 ~- 7~ 3,2 ~ ~- SHERRY L. ORTEGA, :DIVORCE ACTION ~_.. DEFENDANT . COMPLAINT UNDER SECTION 3301 jcl OR SECTION 3301(d1 OF THE DIVORCE CODE 1. Plaintiff, Joseph L. Ortega, is an adult individual who currently resides at 2012 Columbia Avenue, Camp Hill, PA 17011. 2. Defendant, Sherry L. Ortega, is an adult individual who currently resides at 2006 Columbia Avenue, Camp Hill, PA 17011. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six mon#hs immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on October 27, 2006, in Palmerton, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 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 of Divorce. ,.. .. WHEREf=ORE, Plaintiff, Joseph L. Ortega, urges this Honorable Court to enter a Decree of Divorce. ,mil 5~~ ~ Respectfully NEALON Gt By. "1 ~ ~ U James G. Nealon, Nl, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 VERIFICATION I, Joseph L. Ortega, verify that the statemenrts made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. JO P L.ORTEGA Dated: ~ N ~ ' c" ~ Cp ~ i ~ l# c 7 t;r~ ~ „~ pp i c~ _ Y' ~ ~ c` . ~"Y'^ 1 c": . d v r _- ,,,~ JOSEPH L. ORTEGA, IN THE COURT OF COMMON PLEAS PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 08-7232- Civil Term SHERRY L. ORTEGA, :DIVORCE ACTION DEFENDANT ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint on behalf of Sherry L. Ortega, and satisfy that I am authorized to do so. one Adams, Esquire T W. South Street arlisle, PA 17013 1 ~,'? c:esa '~ .,~.~ t ~.) i, ~" t..1~ ~ . , ~~ti «aY i ~,t' ~ ~~ t ~._ .7 ~~~~o-a~~ic~. Q~ 1'>~E pROTHOt~©7ARY 201Q SEP 22 Ate 9~ G8 Ct~~16E ~ YLVA~tA ~~ P~Id JOSEPH L. ORTEGA, : IN THE COURT OF CQMMON PLEAS Plaintiff :CUMBERLAND COUN ,PENNSYLVANIA V. : NO. 08 - 7232 CIVIL tERM SHERRY L. ORTEGA, :CIVIL ACTION -LAW Defendat : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in t~is Affidavit, you must file a counter-affidavit within twenty days after this affidaviti has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATIO~1 1. The parties to this action separated on August~3, 2008, and have continued to live separate and apart for a period of at least two year . 2. The marriage is irretrievably broken 3. I understand that I may lose my rights concernin alimony, division of property, lawyer's fees or expenses if 1 do not claim them N~efore a divorce is granted. verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~ 1 ~ l(7 Sherry L. Ort a, fen an JOSEPH L. ORTEGA, Plaintiff V. SHERRY L. ORTEGA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 - 7232 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME To the Prothonotary: Notice is hereby given that the Plaintiff in the above matter: _ prior to the entry of a Final Decree in divorce. OR after the entry of a Final Decree in Divorce - C) c. -D . hereby elects to resume the prior surname of KEITH avowing her intention pursuant to the provisions of 54 P.S. §704. Date: ,) 1 16)113 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Sherry L. Ortega, Defendant Prior Name Sherry L. Keith, Defe dant Signature of Name being resumed ):ss On this, the 4::\ day of FtJow'a t 2013 before md; the undersigned officer, personally appeared SYyZVwu Lr k &i 01 , personally known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official ELIZABETH AGUIRRE KEITH Commission #t 1916500 Notary Public - California San Francisco County Comm. Ex ires Dec 11, 2014 Not Public My commission expire: Si?1+Ote0? r M?? ?tiv- 4 a 3- °° JOSEPH L. ORTEGA, Plaintiff V. SHERRY L. ORTEGA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 7232 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME To the Prothonotary: Notice is hereby given that the Plaintiff in the above matter: _ prior to the entry of a Final Decree in divorce. OR `' after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of KEITH avowing her intention pursuant to the provisions of 54 P.S. §704. P` Date: -? ----. a_ -5?-' Sherry L. Ortega, Defendant Prior Name Sherry L. Keith, Defendant Signature of Name being resumed COMMONWEALTH OF PENNSYLVANIA i 1:Ss COUNTY OF CUMBERLAND On this, the q day of T-vav:? 2013 before meAhe undersigned officer, personally appeared .5kWrvu -L, Or , _ personally known to me, (or satisfactorily proven) to be the person whos'K name is subscWhed the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. No y Public .,. ,: C Nom o?M?siOn # 191850Q My commission e4ires:: , . ` Cower" PIIMMc inn Ico Cow" 1 14,