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HomeMy WebLinkAbout04-2725e IN THE-COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW S. owl a 121vera. Plaintiff : No. o y- ,271.5 Civil Term V. Ey n es}D Ai VW0-' IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOUIIAVEBEENSUED IN COURT. If you wish to defend against the claims set forih 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, 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) 24973.166 b I:e ban demandado a usted a Is corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la cone en forma escrita sus defensas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier que ja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERDER DINERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 A ?F ?GL+V t i C.? 12I V?eV'(?_ IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA VS. No. 04- ,?7,Z j CIVIL TERM Defendant IN DIVORCE COMPLAINT UNDER 0301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is S CAS Vl i Q Pi V eYO` who currently resides at Sol Popp "- ampl-,:U pA 1-i©t? d? Roy5 Cumberland County, Pennsylvania. 2. Defendant is ;Y' Y) if S? %' V Pl(<A who currently resides at r?.;5, , C-t3 F. No-, toc)cA Pcivj) hi 1I PA i-7i7iI. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at [?&6WO MWiMWChiA?- PA I7OS3? C1 1444 ViW 0 5. The marriage is irretrievably broken, and the parties separated on hug G a al 6. There have been no prior actions of divorce or annulment between the parties. least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on to I I ! t "I at D 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 4tc AL ?i I, -Ed h/a jl ."V 'aA Plaintiff, Pro Se verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unworn falsification to authorities as provided in 18 Pa. C.S. §4904. 12 Ite: Alaintf, Pro Se Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 cy F J x N 0 44, IN THE COURT OF COMMON PLEAS Idania Rivera, Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA V. INTO. 04-.Z?.%C CIVIL TERM Ernesto Rivera, Defendant DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Idania Rivera, Plaintiff, to proceed in forma au eris. I, Jessica Diamondstone, attorney for the party proceeding in forma au uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Jessica Diamondstone Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 r., hJ ? y r -ry:n N v Idania Rivera, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 04-2725 CIVIL TERM IN DIVORCE Ernesto Rivera, Defendant ACCEPTANCE OF SERVICE I, Ernesto Rivera, accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date Ernesto Rivera, Defendant _ N - cm .1 -, r N Q v fv`v? r Idania Rivera IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA V. No. 04-2725 CIVIL TERM Ernesto Rivera IN DIVORCE Defendant AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on June 15, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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: lb-JI-N Signature:u?, - Idania Rivera, Plaintiff Indania Rivera IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY PENNSYLVANIA V. No. 04-2725 CIVIL TERM Ernesto Rivera : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 0301(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. 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 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. Date: /U ,71'd `/ Signature: Idania Rivera, Plaintiff ll;;? Indania Rivera Plaintiff V. Ernesto Rivera Defendant N THE GouRr of Coboa JN PLEAS OF WGiv t6ti it yCOtJ??b 4NSYLVANIA I,jo. 04= 725 t?lm TERM IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on June 15, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. . Section 4904 relating to unworn falsification to authorities. Date: ) -z )--5 Signatur Ernesto Rivera, Defendant ow?.???+'+wwrw?ww?wwwww? suz L Z O Cam- .'A:: -T. l?- ? 4 Indania Rivera Plaintiff V. Ernesto Rivera Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 04- 2725 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &33010 OF THE DNORCE 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 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 unswom falsification to authorities. Date: I-t-3 65- Signature: Emest Rivera, :Defendant "A , Y . ' `, ,A ?n 00 e,vqlv Indana Rivera IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : No. 04-2725 Ernesto Rivero Defendant 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 under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on January 25, 2005 and it was filed on January 31, 2005. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, October 21, 2004; by Defendant, January 23, 2005. 4. Related claims pending: There are no outstandin c12 aims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: October 26, 2004. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: January 31, 2005. Plaintiffs Social Security Number: 039-50-3718 Defendant's Social Security Number: 582-81-4489 Jessica 6iamondstone Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 _ ., A ?\ (\"_ C` \ r Y?, Vf \ E " .( l t : ' f `'. ` T ?? t?J t L? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. INDANIA RIVERA PLAINTIFF NO. X14_7775 CIVIL TERM VERSUS DEFENDANT DECREE IN DIVORCE AND NOW, /Llivu4.? $Qa Ste, IT IS ORDERED AND DECREED THAT INDANIA RIVERA PLAINTIFF, AND -ERNESTO RIVERA DEFENDANT, 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; ,?oNE BY TH(EC?/.O-U RT: A J. PROTHONOTARY •- 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. Q / - '- Z s C 1 ?.? IN DIVORCE RiNES+o P.? yER A Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated Feb, 2005 , hereby elects to resume the prior surname of Dej Va I I? , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: ?bir i j I (U Oq LC!/,t/?'11?4 CLa Signature Signature 'of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 6-N66r/,z d) ' On the day of 200 9, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein,contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary Public NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 AE,--D- =_ OF THE PR" F7CNOT,ARY 2009 APR 16 AM 14. 1 3 Ct ? ;NTY