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Home My WebLink About04-2089 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : No. Cl../ - :lOp? Ci(')I-L'-r-~ : Civil Action - Law vs. : In Divorce Carlos A. Zayas Defendant 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 in divorce or annulment may be 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 the custody or visitation rights 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 at the 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 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNIY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : No. 04 - J.D?1 C'lu~l~EIu-1 : Civil Action - Law vs. : In Divorce Carlos A. Zayas Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Penelope A. Zayas, who currently resides at 271 Newville Road, Shippensburg, Cumberland County, Pennsylvania, since August 30, 2000. 2. Defendant is Carlos A. Zayas, who currently resides at 271 Newville Road, Shippensburg, Cumberland County, Pennsylvania, since August 30, 2000. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on April 7, 2001 Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. (\ H:;~hOny Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 I verify that the statements made in this Complaint 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. Date, t:iF(CJf &~O~ COrcJLtftf) (.J A)T1l .tf- 'F- - ~ tl ~ ~ -...() -tQ. - ..0 o ~ o ~ J ~ (') ~"=; 11 ...- :i ~;:-~ -'.ic; i')('_, .:~ --r: (~) ;:~; ~::' co =-; -r, ='( w ,f' ~- ; C.,) 0-' '-on :.< ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNiY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : No. 0 "1-- aosq (', tJ', J ~ \er~ : Civil Action - Law vs. : In Divorce Carlos A. Zayas Defendant AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Carlos A. Zayas, of 271 Newville Road, Shippensburg, Pennsylvania, 17257, certified mail, return receipt requested on May 15,2004 and was accepted on delivery by Carlos A. Zayas on May 17, 2004. ~~, -:> H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Oran~le Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this ~day of Ma 2004. ,r~^""'~_".' --l;:[;t::'?:~::-;- i". J.Jegqy A . .;~ll.~'", usal ic'.v'OIJcn"....,'.';BG"SOil, Notan, Pub/,'c f"' "lJw.~ ora C ',/,. MY CcmmfSSiQn EXp' umbetland Cou. nty 'res Aug 31 "' Member: P . I ~~D4 , ennsYlVani"Assoc" -=--"" tationotN~lar;es .:~..:.;t<<..; <.,/,;,;.; , '""I 7003 7597 00_ Rolum AoooIpI 1J 0NI161O ij ij ill ......, = = J:" c...... c:; ~,... - o -n ..... :r~ fll-D r"- -o1TJ -'16 o -.-j J ~~~ ::;~~ :iJ -< -::, ty Ul (II IN THE COURT OF COMMON PL.EAS OF CUMBERLAND COUNTY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : No. 04-2089 : Civil Action -- Law vs. : In Divorce Carlos A. Zayas Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 10, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filling of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the decree. 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. Section 4904 relating to unsworn falsification to authorities. Date:# ~GlZO'('fn Penelope A. Zayas " -:J I '~ --"J (," f\,) C;, tU C) IN THE COURT OF COMMON PL.EAS OF CUMBERLAND COUNTY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : No.04-2089 : Civil Action -- Law vs. : In Divorce Carlos A. Zayas Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced untill a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. Date: /6/;/3/0V I I ' l:7 V tf,C) Penelo e A. Zayas IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : No. 04-2089 : Civil Action - Law vs. : In Divorce Carlos A. Zayas Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 10, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the decree. 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. Section 4904 relating to unsworn falsification to authorities. Date:~ r /1/( {\, ( ~.. I, _~ </Carlos A. Zayas {/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : NO.04-2089 : Civil Action - Law vs. : In Divorce Carlos A. Zayas Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsificatio to authorities. /' / ,I / 1/ I' r , . ( . rCarlos A. Zayas I Date: ///f/oV I / f ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Penelope A. Zayas, Plaintiff : NO.04-2089 Civil Term : Civil Action - Law vs. : In Divorce Carlos A. Zayas Defendant 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 under 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on May 15, 2004. An Affidavit of Service has been filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff October 18, 2004; by Defendant November 18, 2004. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice was signed on October 18, 2004 and was filed on October 25, 2004 and Defendant's Waiver of Notice was signed November 18, 2004 and is filed herewith. ~? --::> H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 ,.,;f.;f.:f.:f.:f.;t;;f.;Ii;+;T..:f.T.T.T. . . . . . . . . . ,; . ,; . . . ,; . . . . . ,; . ,; . . . . . ,; . . . . . . . . . . . . . . . . . . ,; . . . . . . . . . ,; . . ,; . . . . . . . . ,; . . . . . . . . ,; . . . . . . . . . . . . . . . . . . ,; . . . . ""T.T.T.T. T. :f.:f.:f.:f.:f.:f.T.T.T.;f:f.:f.:f.;f.;f.:f.:+;:f.:f.;f.:f.:f.:f.:f.T.T.+++++++++++++++++++++++++:f.+:f.++:f.+++++~ . . . . . . . . . ,; . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +++++:f.+++ +++ T.:f.:f.+++++++:f.:f.+ + ++ +:f.+:f.++++ T.T++ ++ TT.++++++++:f.++ +++++T.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Penelope A. Zayas PENNA. STATE OF No. 04-2089 Civil VERSUS Carlos A. Zayas DECREE IN DIVORCE 1)e.L 22 , 2ao ~/.' IT IS ORDERED AND AND NOW, Penolope A.Zayas DECREED THAT , PLAI NT] FF, AND Carlos A. , DEFENDANT, Zayas ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None ATTES By THE COUR PROTHONOTARY J. ?~~ ~ y ~lkPrr1 Qclr11't?l .~;JZ 1f1?~d .I,?~';'L, /70. ee'E/ ~ % ~~"1F4?'~ /Jr.?'C'Ce/ -. '. . .' \ ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Penelope A. Zayas, Plaintiff : No. 04-2089 : Civil Action - Law vs. : In Divorce Carlos A. Zayas, Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 12th day of December, 2004, hereby elects to resume the prior name of Penelope Allison Pugh, and gives this written notice pursuant to the provisions of 54 P.s. Section 704. Date:.l:OD.dl.o . , Penelope A. zayas, ()) ~o~)Q..O 00 i1~\It- ~ Penelope Allison Pugh .. ... ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND On the 20th day of January, 2006, before me, a Notary Public, personally appeared the above affiant Penelope A. Zayas requesting to resume the name of Penelope Allison Pugh known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing document for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. c.-" .....l~.~..~. Notary Public ...-.","" My Commission Expires: Notarial Seal H. Anthony Adams, Notary Public Shippensburg Boro, Cumberland County My C\)mmis~\\)n Exprres May l5, 2006 Member, Pennsylvania Association ot Notanes ~ \".J ~ -J & r--..\ d ~ i o c: ;::'~. "'i)l'Fl ('\"1,' ~:~ '? ~~: ~. r;:.;:. }?: (' 3:;~ ::::...1 ..( "" c.? c.;? 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