HomeMy WebLinkAbout09-0186
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Mario F. Arroyo-Ramos
Plaintiff
v.
Sandra M. Rosado-Rivera
Defendant
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO.O,- bl 8(o 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 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 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, 1 Courthouse Square, 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 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
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Mario F. Arroyo-Ramos IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
v. NO.O$- ~ l PL CIVII. TERM
Sandra M. Rosado-Rivera
Defendant IN DIVORCE
COMPLAIN" T UNDEER §3301(c) or (d) OF THE DIVORCE CODE
1. Plaintiff is 1?~i-~'o~c~ ~ ~~~~/ d ~ ~~~ who currently resides at
Cumberland County, Pennsylvania.
2. Defendant is ~°7"" "- ~~ `m Ste- ~ ~~,'~l'~o~>~ently resides at
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3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint. ,
4. Plaintiff and Defendant were married on ~~ at
5. The marriage is irretrievably broken, and the parties separated on
6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
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given in Paragraph 2 above.
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8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
Date
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Plaintiff, Pro Se
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I, /~/~ ,verify that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 Pa. C.S. §4904.
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Date:
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Plaintiff, Pro Se
Assisted by:
Michael J. Whare, Esq.
Law Offices of Michael J. Whare
37 E. Pomfret Street
Carlisle, PA 17013
(717)243-3561
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Mario F. Arroyo-Ramos
Plaintiff
v.
Sandra M. Rosado-Rivera
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO.O~- OI8(o
CIVIL TERM
IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Mario F. Arroyo-Ramos, Plaintiff, to proceed in forma ap uperis.
I, Michael J. Whare, attorney for the party proceeding in forma ap uperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the
party.
V~ ~~
ichael J. Whare, squire
Attorney for Plaintiff
Law Offices of Michael J. Whare
37 E. Pomfret Street
Carlisle, PA 17013
(717) 243-3561
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Mario F. Arroyo-Ramos IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
v. NO. 0~- p~$IO CIVIL TERM
Sandra M. Rosado-Rivera
Defendant IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter affidavit within twenty days after this affidavit has been served on you or the statements
will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER
§3301 (d) OF THE DIVORCE CODE
1. The parties to this action separated on ~~~ ~ ~ ~ ~ and continued to
live separate and apart for a period of two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of marital property,
lawyer's fees, or expenses if I do not claim them before a Divorce is granted.
I, ~/~~~ ~ ~ /~/~~'Q o art~?~yerify that the statements made in this Affidavit are
true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 P.S. Section 4904.
Date
Plaintiff, Pro Se
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