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Home My WebLink About09-1296Christina Carrero, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Manuel Carrero, : Defendant :NO. 09- J a y& CIVIL TERM 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, Cumberland County Courthouse, 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, 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 INFORMATION 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, Pennsylvania 17013 (717) 249-3166 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. CHRISTINA CARRERO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE MANUEL CARRERO, Defendant : NO.09- 1 X7v CIVIL TERM DIVORCE COMPLAINT The plaintiff, Christina Carrero, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. § 3301(d) OF THE DIVORCE CODE 1. 2. 3. 4. 5. 6. 7. 8. 9. Plaintiff is Christina Carrero , who currently resides at 500 Third Street, Carlisle, Cumberland County, PA 17013, since June 2008. Defendant is Manuel Carrero, who currently resides at 135 Blandon Avenue, Berks County, PA 19510 since December 2006. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on August 31, 2002 in Ephrata, Lancaster County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since December 2006. There has been a prior action for divorce in the Court of Common Pleas of Berks County Docketed at 05-4941-01. This action was withdrawn on June 8, 2006 The marriage is irretrievably broken. 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. Defendant is not a member of the armed services. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Rachel Allen Certified Legal Intern MEG RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date g&g Plaintiff Christina C'?J 3 r e`?J i =c Fri f.1 t t/ ? T * top co -? Christina Carrero, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Manuel Carrero, Jr. Defendant NO. 09- J.Zq( CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Christina Carrero, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. / Respect ly submitted, Date 2 /Z Rachel Allen Certified Legal Intern MEG RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 4 z7 t co Christina Carrero, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Manuel Carrero, Jr., Defendant : NO. 09 - 1296 CIVIL TERM CERTIFICATE OF SERVICE I, Rachel Allen, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Manuel Carrero, Jr., residing at, 135 Blandon Avenue, Blandon PA 19510 by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Manuel Carrero, Jr., on the the 6th day of March 2009 as evidenced by the attached green card. CJ R j I a Ln ru m -a i ru m I Wd/ C? ? Rachel Allen Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ra ?, u s,-? :? r-T '?1 t. 1?f i^`e --! i..1 '? := '-?^ ..9- > t"? ??? ..,,,; "r Christina Carrero Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Manuel Carrero, Jr. . Defendant : NO. 09 - 1296 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in December 2006 and have continued to live separate and apart for a period of at least 2 years. 2. The marriage is irretrievably broken. 3. 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. 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. DateW a7 200 Christina Carrero Plaintiff ---? ? -n ?-fi ^`r ?;', r'1V? t"FR . ; ? Christina Carrero, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Manuel Carrero, Jr., Defendant NO. 09 - 1296 CIVIL TERM CERTIFICATE OF SERVICE I, Rachel Allen, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Plaintiffs Affidavit on Manuel Carrero, Jr's attorney Jennifer Spears, by depositing a copy of the same in the United States first class mail, postage prepaid addressed to Martson Law Offices, 10 East High Street, Carlisle, PA 17013. Rachel Allen Certified Legal Intern T :; r Christina Carrero , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Manuel Carrero, Jr., Defendant NO. 09 - 1296 CIVIL TERM CERTIFICATE OF SERVICE I, Rachel Allen, Certified Legal Intern, Family Law Clinic, hereby certify that I served a copy of the Notice of Intention on Manuel Carrero's attorney Jennifer Spears, by depositing a copy of the same in the United States first class mail, postage prepaid addressed to Martson Law Office, 10 East High Street, Carlisle, PA 17013 on this 17th day of April 2009. ?91z2. Rachel Allen Certified Legal Intern RI =PACE OF THE RE n.T,Hn*"XTfARY 2099 APR 17 PM 12= 3 n Amanda Carbaugh on behalf of Ky Carbaugh Plaintiff V. Jessica Mauer and Andrew Mauer On behalf of Lindsey Mauer Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN CUSTODY NO. 09 - 2100 CIVIL TERM CERTIFICATE OF SERVICE I, Amy Hirakis, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Custody Complaint on Lindsay Mauer, residing at 500 1" Street, Summerdale, PA 17093, by depositing a copy of the same in the United States mail, first class, regular delivery, postage prepaid, on April 17, 2009. FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Supervising Attorney OF THE PRIC.Tr'OOiARY 2009 APR 17 P 12: 3 'y?klt? ??IFS ??t Christina Carrero, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : DIVORCE Manuel Carrero, Jr., Defendant : NO: 09-1296 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT PLAINTIFF intends to file with the court the attached Praceipe to Transmit Record on or after MAY 11, 2009 requesting that a final decree in divorce be entered. Apr; I ;? '?, Date 141,0 Rachel Allen Certified Legal Intern 6' Meg ' Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2698 Fax: (717) 243-3639 2009 MAY 12 All 9: 40 Christina Carrero , Plaintiff V. Manuel Carrero, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09- 1296 CIVIL TERM CIVIL ACTION - LAW 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. Ground for divorce: irretrievable breakdown and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant, Manuel Carrero, Jr. by depositing a copy in the United States mail, certified restricted delivery, return receipt requested, postage prepared. Service was complete upon receipt by Manuel Carrero, Jr. on March 6, 2009. 3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code: March 27, 2006; Date of filing and service of the plaintiff s affidavit upon the Defendant's attorney: filed on March 27, 2009 and served March 27, 2009. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: service on Defendant's attorney Jennifer Spears, Esq., at Martson Law Offices, 10 East High Street, Carlisle, PA 17013 on April 17, 2009; by US mail, first class. Date Ap,,'[ J 7, 206rl &, Rachel Allen Certified Legal Intern Megan Pesesmeyer, Esquire Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 FLE+„ !fir ??r ^ f 'sT{``1 20091 MAY 12 AN 9: 4 1 CHRISTINA CARRERO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : MANUEL CARRERO, JR. NO. 2009 - 1296 CIVIL TERM : CIVIL ACTION - IN DIVORCE ORDER OF COURT AND NOW, this 20!H day of MAY, 2009, it appearing that the service of the 3301(d) affidavit is defective in that no attorney has entered an appearance on behalf of the Defendant, the Plaintiff's request for the entry of a final decree in divorce is DENIED without prejudice. 4th ; ' I Edward E. Guido, J. Megan RiesmeYer, Esquire Family Law Clinic 45 North Pitt Street Carlisle, Pa. 17013 ,'Jeruufer Spears, Esquire 10 East High Street Carlisle, Pa. 17013 sld co?? e S' ma.?lscl, ?Z :6 1=1V 7,z A 14 HE 1 t • FIOLESTfients\5492 Mid Pem\5492.80\5492.80.pra Revised: 5/26/09 10:38AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant CHRISTINA CARRERO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-1296 CIVIL ACTION - LAW MANUEL CARRERO, JR., Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON LAW OFFICES on behalf of Defendant in the above matter. MARTSON LAW OFFICES By ( v ears, Esquire Jennife .71 Ten E aft Nigh Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant Dated: May 26, 2009 N CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy & Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Rachel Allen, Certified Legal Intern Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 MARTSON LAW OFFICES y ncia D. Eckenroad Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: May 26, 2009 R f n LEL? Christina Carrero , Plaintiff V. Manuel Carrero, Jr. Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 09- 1296 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant, Manuel Carrero, Jr. by depositing a copy in the United States mail, certified restricted delivery, return receipt requested, postage prepared. Service was complete upon receipt by Manuel Carrero, Jr. on March 6, 2009. 3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code: March 27, 2006; Date of filing and service of the plaintiff's affidavit upon the Defendant's attorney: filed on March 27, 2009 and served March 27, 2009. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached: service on Defendant's attorney Jennifer Spears, Esq., at Martson Law Offices, 10 East High Street, Carlisle, PA 17013 on April 17, 2009; by US mail, first class. Date -j12 ?r/G 4dllx Rachel Allen Certified Legal Intern Meganiesmeyer, Esquir Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Christina Carrero, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. : DIVORCE Manuel Carrero, Jr., Defendant : NO: 09-1296 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT PLAINTIFF intends to file with the court the attached Praceipe to Transmit Record on or after MAY 11, 2009 requesting that a final decree in divorce be entered. Ptpn1 17,ZQ Date & 14 Rachel Allen Certified Legal Intern Megmt,Riesmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2698 Fax: (717) 243-3639 "F THE 47 r ?`" Christina Carrero, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Manuel Carrero, Jr. NO 09-1296 DIVORCE DECREE AND NOW, it is ordered and decreed that Christina Carrero, plaintiff, and Manuel Carrero, Jr. defendant are divorced from th bonds of matrimony. %I- 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 Attest: J. Prothonotary !a •3 •OS' C?'.f. C? .r ? i'G. _ ???a? ?, a ?\ Christina Carrero, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE Manuel Carrero, Jr., Defendant : NO. 09 - 1296 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having bees a Final Decree in divorce from the bonds of matrimony on the June 2, 2009, hei to retake and hereafter use her previous name of Christina England and gives th notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § uzee' istina Carrero Wishes To Be Known As: Christina England COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the/ Aday of , 2009, before me, a Notary Public, perso appeared Christina Carrero, known to me to be the person whose name is subsc; the within document, and acknowledged that she executed the foregoing for the therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial S ARY"PUBLIC ! - Notarial Seal Laurie L. Wolf, Notary Public Carlisle Boro, Cumberland County MY Commission Expires Feb. 14, 2010 by elects > written to se FILED-OffrT OF THE PM-,- THOIN 1TARY 2004 JUN 10 PM 12= 5 4 FFN NS,iVA.N1A //. 00 ,OC(, e,2aa-4