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HomeMy WebLinkAbout09-2450.~ Pennsylvania. Filing Forms 4 A ~ I Mega~i Irene Morales, v. Andrew Charles Morales, IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. j}~ ~C/~~ DEFENDANT ) NOTICE TO DEFEND AND CLAIM RIGHTS Page 1 of 1 YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 NDGMENT 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 CHILD(REN). WHEN THE GROUND FOR THE DIVORCE ARE 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 IN PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES BEFORE A DNORCE 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. LAWYERS REFERRAL SERVICE ia~.iatl i~ ~,Pt~ t~tal3 Telephone: 1(`7 7 ) Peti er Signature 260 North 21st Street Camp Hill, Pennyslvania 17011 717-370-1559 https://ss1-001.vdshosting.com/OURDIVORCEAGREEMENT COM/States/StateForms/Pe... 4/5/2009 _ .: ~vacuarilingForms . ,~ Page 2 of 2 signa~re Name: Sw rn to and subs 'bed before me this q day of 20 ~ I ---• NOT Y ~`BLIC TWOS T~'ikl'Cl,UN '. hlOTAl:lflL SEAL ~. + i.... nl~;:..^.2~ T' 7.r::~''u'F .is::)1 e~ ~ r.~ jU https://ssi-001.vdshosting,com/~U~j~.y,~RCEAGREEII~E NT COM/States/~ratP~,,....,._,,, Fe~nsvlvania Filing Forms ~, -, Megan Irene lvlorales, 1N THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA v. ) CIVIL DIVISION Andrew Charles Morales, ) NO. U 9 - ~ y Sti ~ ~*~- DEFENDANT ) COMPLAINT IN DIVORCE Page 1 of 2 COMES, the Plaintiff, Megan Irene Morales, by FILING PRO SE, who files this Complaint in Divorce a statement of which is as follow: 1. The Plaintiff is Megan Irene Morales, an adult individual currently residing at 260 North 21st Street Camp Hill, Pennyslvania 17011. 2. The Defendant is Andrew Charles Morales, an adult individual currently residing at 1712 Lincoln Street Camp Hill, Pennsylvania 17011. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Respondent were married on December 24, 1999, in the State of Pennsylvania. 5. There are two minor children born to or adopted by the Parties. The names and dates of birth are: Christopher Logan Morales, 05108/Ol; Xavier Charles Morales, 02/06/04. 'The wife is not now pregnant. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither party is a member of any branch of military. 8. The marriage is irretrievably broken. 9. Plaintiff has been advise that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. The Plaintiff, Megan Irene Morales, respectfully requests that this Court grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the Divorce Code and that a Decree of Divorce be entered. I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A Section 4904, relating to unsworn falsification to authorities. Respectfully submitted, Si - e of Plaintiff Megan Irene e , Dated: AFFIDAVIT COMMONWEALTH OF PENN5YLVANIA ) County of CUMBERLAND ) Before me, the subscriber, a Notary Public in and for said Commonwealth and Cumberland County, personally appeared Megan Irene Morales, who, being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his/her knowledge, information, and belief, and that he/she is authorized to make this Affidavit. ~----~• ` ABvP,ll. "r::aEs~tfiR', Pir+~~~ F'c!;lic S;iscr 5~:~~ lea., G~rrna~r~~w+:'d ~s'~.r!;'i R/ly CO~rnlff~iBn ~X~6i~'.E July a3, ?itiT) https://ss1-001.vdshosting.com/OURDIVORCEAGREEMENT COMIStates/StateForms/Pe... 4/5/2009 (~ TH4 f~C' »~~~~{~~'~Y 209 ~i'~i i 7 P-°3 3~ L i ... ~ a (`r J. ~.' ~~ t~r a-~ Od ~~3~. s~ P/~F lash ~e~ Pe~xlsvlvania Filing Forms Me:gan Irene Morales, IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA v. Andrew Charles Morales, DEFENDANT ) CIVIL DIVISION NO. MILITARY AFFIDAVIT Page 1 of 1 I, Andrew Charles Morales, Defendant, being sworn, certify that the following information is true: I am not on active duty in the armed services of the United States. I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. /~ i DATED: Signature of Defendant Andrew Charles Morales 1712 Lincoln Street Camp Hill, Pennsylvatua 17011 717-856-6737 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND On the ~ day of ~ ~ t , 20 ©~ ,before me, a Notary Public, personally appeared Andrew Charles orates, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set myhand/~and seal. _ tt~ , Notary Pub is _ r S;"ror S;~f•«s~g'6;~;:,., Cur;•~a©rks:u ~~:~u^'/ F.~y Cornrrsissior~ t:.xy~i,tia J~aty 2:,, ~~1t1 httnc•//ccl_(1(11 vdchnetino rnm/(1TTRTITV[1R( RAC'.RF.FMRNT (`(111~1CtatPC/CtatPFnrms/Pe al5/~nn9 e„4i°~~. ~IL~.". ~r ~!'~~P~ ~~~~3 APB ~ ~ ~~ ~~ ~ ~ ;~,~ ;fit ..: t ~~/ J Pennsylvanra. Fling Forms Page 1 of 1 Megan bent: Morales, IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, ~.s PENNSYLVANIA ~:' ~~:: ,•. ~,. ~ t Y_ ~ r v. ) CIVIL DIVISION a'r:. = +... Andrew Charles Morales, ) NO. U ~p'9 ~ ~T,c t;? DEFENDANT ) ;,,~ ~? e ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE PLEASE take notice that I, Andrew Chazles Morales, Defendant, was provided with a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept service of same. I further enter my appearance in this action for all purposes 1 Q~ Andrew Charles Morales 1712 Lincoln Street Camp Hill, Pennsylvania 17011 71?-856-6737 https:!/ss1-001.vdshosting.com/OURDIVORCEAGREEMENT COM/States/StateFormslPe... 4/51209 ~-L~~r;C~ f~E-,:; , 2Q09 APR i ? ~'~ 3~ fl 2 1 y*~'tl