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HomeMy WebLinkAbout09-1710MAI N. CARRERA, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. NO: ~~l' ~~/G 2009 GREGORY CARRERA, CIVlL ACTION -LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CL_dJM 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 in'etrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAW'YER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. The Court of Common Pleas of Cumberland County is required by law to comply with the Amercians and Disabilities Act of 1990. For information about acxessibte 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 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 LAWYER REFERRAL SERVICE 2 Liberty Avenue Carlisle. PA 17013 Teleahone: (717) 249-3166 BATURIN &BATURIN By: ~m C~ HARK . BA URIN, ESQUIRE 2604 N. Second Street Harrisburg, PA 17110 (717) 234-2427 Attorney I.D. No. 83006 MAI N. CARRERA, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA v. NO: d S - ~ 7 ~d 2009 GREGORY CARRERA, CIVIL ACTION -LAW Defendant DIVORCE COMPi.A1NT UNR SECT1+~i~ 3-, 3~1(C) OF THE DP/d1RtCE CODE AND NOW, this day of , 2009, comes the Plaintiff, MAI N. CARRERA, by and through his Attorney, Hany M. Baturin, Esquire, of the Law Offices of BATURIN &BATURIN, and respectfully represents the following: 1. The Plaintiff is MAI N. CARRERA, an adult individual, sui juris, who currently resides at 919 Maplewood Lane, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant is GREGORY CARRERA, an adult individual, sui juris, who currently resides at 919 Maplewood Lane, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 18, 2005, in Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant have continued to live apart and not as husband and wife since September 25, 2008. 6. There has been no prior action for divorce or annulment of the marriage between the parties hereto in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member on active duty of the Armed Forces of the United States of America nor any of its allies. 9. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling and which list is available to the Plaintiff upon request. Being so advised, Plaintiff does not request that the Court require that the parties participate in counseling prior to a divorce decree being handed down by the Court. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Honorable Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant and for such further relief as the Court may determine equitable and just. Respectfully submitted, BATURIN &BATURIN Hany M. Baturin, Esquire Attoryney I.D. No. 83006 (Attorney for the Plaintiff) 2604 North Second Street Harrisburg, PA 17110 (717) 234-2427 t ` r t II MAI N. CARRERA, Plaintiff v. GREGORY CARRERA, Defendant . IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PA . NO: 2009 . CIVIL ACTION -LAW . DIVORCE VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. '4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. n ~ -_- ~ -~7 ~„ ~,' ~ ~ ~ ` W a ~ ~ .~ ~ O "s Mai N. Carrera, V. Gregory Carrera, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1710 DIVORCE DECREE AND NOW, ~/a~-~ Y ~o q , it is ordered and decreed that Mai N. Carrera, plaintiff, and Gregory Carrera, ,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. AND, FURTHERMORE, the Marital Settlement Agreement dated September 22, 2008, and executed by the parties hereto, is incorporated with, but not merged into, the Divorce Decree; the parties are directed to_camply with the t~x'o~^sions thereof By the Court,