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HomeMy WebLinkAbout04-1936WENDI M. PUCETA, Plaintiff VS. NATHAN PAUL PUCETA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2004 - 14.3 to Civil Term CIVIL ACTION - LAW 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 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. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 WENDI M. PUCETA, Plaintiff vs. NATHAN PAUL PUCETA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2004 - 1q36 Civil Term CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Wendi M. Puceta, an adult individual whose current address is 10 Briarwood Court, Camp Hill, Cumberland County, Pennsylvania 17011, and whose social security number is 172-62-9407. 2. The Defendant, Nathan Paul Puceta, is an adult individual, whose current address is 10 Briarwood Court, Camp Hill, Cumberland County, Pennsylvania 17011, and whose social security number is 184-56-7098. 3. Plaintiff and Defendant were married on September 8, 2001, in Harrisburg, Pennsylvania. 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There is one minor child born of the marriage; namely: William Alexander Puceta, born May 11, 1999. 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, BY. iane M. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: April 28, 2004 VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. WENDI M. PUCETA Date: April 28, 2004 c? D LAI) Ya i - ?jj `I) WENDI M. PUCETA, Plaintiff vs. NATHAN PAUL PUCETA, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2004-1936 Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE Please reinstate the Complaint in Divorce Under Section 3301(c) of the Divorce Code for service upon the Defendant. Respectfully submitted, 1017 Ntirth Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 71873 Date: June 8, 2004 c > o _ C. O T .71 i N ;J'; SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-01936 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PUCETA WENDI M VS PUCETA NATHAN PAUL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT PUCETA NATHAN PAUL but was unable to locate Him deputized the sheriff of DAUPHIN serve the within COMPLAINT - DIVORCE to wit: He therefore County, Pennsylvania, to On July 7th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin County 30.00 Mileage 10.35 77.35 07/07/2004 DILS & DILS Sworn and ?w this Y- d2(16I subscribed to before me day of 4p- j A.D. (1) k 4aii Pr hodr' in his bailiwick So answe s may. R. Thomas Klinl---! Sheriff of Cumberland County in The Court of Common Pleas of Cumberland County, Pennsylvania Wendi M. Puceta vs. Nathan Paul Puceta SERVE: sane No 04-1936 civil Now June 24, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a , 20, at o'clock M. served the copy of the original and made known to the contents thereof. So answers, Sheriff of COSTS Sworn and subscribed before SERVICE me this ____ day of 20? MILEAGE AFFIDAVIT $ County, PA (pf firr of t4r ,,`i?hrxtff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania , PUCETA WENDI M Vs County of Dauphin PUCETA NATHAN PAUL Sheriff's Return No. 5149-T - - -2004 OTHER COUNTY NO. 04-1936-CIVIL J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy AND NOW:June 29, 2004 at 12:24PM served the within COMPLAINT upon PUCETA NATHAN PAUL by personally handing AT&T WIRELESS to DEFT 1 true attested copy(ies) of the original REINSTATED COMPLAINT and making known to him/her the contents thereof at AT&T WIRELESS 2550 INTERSTATE DR HBG, PA 17110-0000 HOME ADDRESS: 10 BRIARWOOD CT CAMP HILL, PA 17011 PHONE #: 761-6068 Sworn and subscribed to before me this 30TH day of JUNE, 2004 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Highspire, Dauphin County My Commission Expires Sept. 1, 2006 So Answers, /??1L Sheriff f auphi C?un y, Pa. By W41 ` Deputy Sheriff Sheriff's Costs:$0.00 PD 00/00/0000 RCPT NO K COOK Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 0Y - 1 f 316 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573