HomeMy WebLinkAbout09-4767IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BRENDA TORRES,
Plaintiff,
V.
ROBERTO ESCALET,
Defendant.
oQ - y71o7 C tv i t arm
NO: of 2009 G.D.
COMPLAINT FOR DIVORCE
FILED ON BEHALF OF:
Plaintiff, Brenda Torres
Counsel of record for Plaintiff:
Thomas B. York, Esquire
Attorney I.D. No. #32522
THE YORK LEGAL GROUP, LLC
3511 North Front Street
Harrisburg, PA 17110
(717) 236-9675
Fax: (717) 236-6919
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BRENDA TORRES,
Plaintiff, NO: Y767 of 2009 G.D.
V.
ROBERTO ESCALET,
Defendant.
COMPLAINT IN DIVORCE NOTICE TO
DEFEND AND CLAIM RIGHTS
You have been sued in court for:
[X] Divorce [] Annulment of Marriage
[] Support [] Custody & Visitation
[J Equitable Distribution of Property [] Alimony
[] Attorney Fees
[] Costs [] Other Claims
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 IRRETRIEVABLE BREAKDOWN
OF THE MARRIAGE, YOU MAY REQUEST COUNSELING. A LIST OF MARRIAGE COUNSELORS IS
AVAILABLE IN THE OFFICE OF THE WASHINGTON COUNTY PROTHONOTARY.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.
LAWYER REFERRAL SERVICE
Dauphin County Bar Association
213 North Front Street, Harrisburg, PA 17101
ph. 717.232.7536 fx. 717.234.4582
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BRENDA TORRES,
Plaintiff,
V.
ROBERTO ESCALET,
Defendant.
NO: V7& 7 of 2009 G.D.
COMPLAINT FOR NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE
PENNSYLVANIA DIVORCE CODE
AND NOW comes Plaintiff, BRENDA TORRES, by and through her attorney, Thomas
B. York, Esquire, of the YORK LEGAL GROUP, LLC filing the immediate Complaint for
Divorce and respectfully represents:
1. Plaintiff is BRENDA TORRES who currently resides at 4 Hazelwood Path,
Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is ROBERTO ESCALET, who currently resides at 1465 Hill Crest
Court, Camp Hill, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are sui juris and both have been bona fide residents of the
Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding
the filing of this Complaint.
4. The parties were married on May 23, 1997, in Harrisburg, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
6. There has been no prior action for divorce or annulment instituted by either of the
parties in this or any other jurisdiction.
7. Plaintiff has been advised of the availability of counseling and of the right to
request that the Court require the parties to participate in counseling.
8. The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff, BRENDA TORRES states that if both parties file affidavits
consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this
Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to
Section 3301(c) of the Divorce Code.
Respectfully submitted,
THE YORK LEGAL, GROUP, LLC
'03
Thomas B. York, Esquirt /
PA I.D. No. 32522 l
3511 North Front Street
Harrisburg, PA 17110
(717) 236-9675
Fax: (717) 236-6919
Email: work orklegalgroup.com
Attorneys for Plaintiff
Date: July ' W_, 2009
VERIFICATION
I, BRENDA TORRES, hereby verify that the facts set forth in the foregoing
COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and
belief. I understand that any false statements therein are made subject to the penalties of 18
Pa.C.S.A. § 4904 relating to unsworn falsifications to authorit' s.
BRENDA TORRES
OF THE
2009 JIUL 16 Fi 2: =r4
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
BRENDA TORRES,
V.
Plaintiff,
ROBERTO ESCALET,
Defendant.
NO: 09-4767 Civil. Term
ACCEPTANCE OF SERVICE
I, ROBERTO ESCALET, do hereby accept service of the Complaint in Divorce in the
above captioned matter.
Date:
s•
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ROBERTO ESC I ET
1465 Hill Crest Court
Camp Hill, Pennsylvania 17011
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