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Home My WebLink About04-2872 JESSICA M. SIERRA Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE LENIEL SOTO TORRES Defendant NO. 04 - ;)"P7'J.- O"Ol'C/~ NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prornpt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment rnay 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 rnarriage counseling. A list of rnarriage counselors is available in the Office of the Prothonotary at Dauphin County, Front and Market Streets, Harrisburg, 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, P A 17013 (717)249-3166 JESSICA M. SIERRA Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW DIVORCE LENIEL SOTO TORRES Defendant NO. 0'-1 - ;;u'7~ Ct.>,'l <-r- €/uy\. COMPLAINT IN DIVORCE 1. Plaintiff Jessica M. Sierra who currently resides at 20 Stephen Road, Apt. B3, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Leniel Soto Torres who currently resides 36 S. 28th Street, Harrisburg, Dauphin County, Pennsylvania 17103. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 17,1999, in Harrisburg, Dauphin County, Pennsylvania. 5. Two children were born ofthis marriage, Melena Soto (d.o.b. 7-17-01) and Melissa Soto (d.o.b. 8-18-03). 6. Neither Plaintiff nor Defendant are 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 Congress of 1940 and it amendments. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The parties have been living separate and apart since February 2004. 9. The marriage is irretrievably broken. 10. 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. 11. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce divorcing Plaintiff and Defendant and such other Orders as are just and appropriate. Respectfully submitted, ~d~cU Date: 4 -:;IJ-oz/ Melissa L. Van Eck, Esquire Attorney ID No. 85869 7800 A Allentown Blvd. Suite B P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 Attorney for Plaintiff VERIFICATION I, Jessica M. Sierra, verifY that the statements made in the foregoing COMPLAINT in DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are mad subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. k Date: (p...::J 1- () J 2 - f.... ~Ck/ YJ I ssica M. Sierra ~v 19. 7::J ~ - 'll ~ t _ ~ -- f' () ~---:)-s.) ~ p:. "f g ----z f~~ -< p":; r-....,) C) ~ ~n '.:i.~ c-: to,: \""'.) f'0 -, (;? ,) :< JESSICA M. SIERRA, Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-2872 CIVIL TERM LENlEL SOTO TORRES Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Cornplaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 22, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a Pinal 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 tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. -d~~ ~/~ Leniel Soto Torres ,- Defendant Date: C-,:L.D -05' (') ~ 0 = c: = -n ~ en -ocr, <-- :I!:o nll-I c:: ~Fii .-,..,. . ... .;;;,.- " I co ;00 -< -..I 9,:' ;.,--~ -,-'-"\'1 ,- J> --'~,1 ~~~~ :x Q~ ~ )~'c.: f--I '!? C:::i ~ N ~ (J'l -< - JESSICA M. SIERRA, Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-2872 CIVIL TERM LENIEL SOTO TORRES Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(C) or &3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 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. 94904, relating to unsworn falsification to authorities. Date: ,("-;26'-0 S /^~ ~ Torres o <;::; ';_:" ~~~~;" '-':1-' €i'! --0". (,:::.:,-- i~;: L:..., - -< ~ "'" cJ' 'e .- I -l ~ 'f! ~ ~:;!:! ~~i :J:-n 05 3m ~ 2" ~ N (J1 - JESSICA M. SIERRA Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE LENIEL SOTO TORRES, Defendant. : NO.: 04-2872 CIVIL TERM AFFIDAVIT OF SERVICE I do hereby state that I served a true and correct copy of the Complaint in Divorce, in the above captioned matter, by placing the same in the United States mail, first-class, postage prepaid, certified mail, return receipt requested, in Harrisburg, Pennsylvania, and delivered on June 26, 2004, as per the attached return receipt card, addressed to: Leniel Soto Torres 36 S. 28th Street Harrisburg, P A 17103 Respectfu\1y submitted, MM)0J V~i Melissa L. Van Eck, Esquire Attorney ID No. 85869 7810 A\1entown Blvd. Suite B P.O. Box 6662 Harrisburg, P A 17112 (717)540-5406 Attorney for Plaintiff Date: '1 - <i - D5 Complete items 1, 2, and 3, Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the mallpiece, or on the front if space permits. 1. Article Addressed to: Lmld ~m 'lOwG 31.0 S. ~ '8\-, ~"S~jP~ , 11103 2. Article Number (Transfer from service label) PS Form 3811. August 2001 D. Is delivery address dl'fferent from item 1? If YES. enter delivery address below; 3, Service Type ..xtCert\1'ied MaH ..- r::T-Registered o Insured Mail o Express Mail ~eturn Receipt for Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) 7002 3150 0001 4960 5168 Domestic Return Receipt DYes 102595-02-M-1035 ~ ~ 'c: ,- - N ~~; .;::, ::.;; q, :;t-n ('if:: -0 l(3 ~.D L C~L) ::--r~-::;;' '~Z: ~. 9 ""'"7 ~ ..,,;) -,' ~* 8 (.J'\ cP - JESSICA M. SIERRA, Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-2872 CIVIL TERM LENIEL SOTO TORRES Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 22, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of Notice of Intention to Request Entry ofthe Decree. 1 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.A. Section 4904 relating to unsworn falsification to authorities. Date: /;J - /5-0 S Csv~ ~a Sierra ~ CA..J ;;:; '3!. ,- c' r" - N ~ -' -r fi~le -orB -_,0 """' L o ~..\C) -"~C~ ,-)-- '7:0 OfT" ::0.\ :Ep :< -0 - ..,..;~... is? en cJJ JESSICA M. SIERRA, Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-2872 CIVIL TERM LENIEL SOTO TORRES Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY QF A DIVORCE DECREE UNDER &330l(C) or &330l(D) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without notice. 2. 1 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 deGree 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. 1 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. 94904, relating to unsworn falsification to authorities. Date: JJ~ I tf -0 5 ~:a~~ ~ q ~ ~;~~.':f L~ (''''"-',. ~.-: ~~; :2 ~ ~ '- c;: ,- N ~ ~..,., rne :gQ {JC.J ---:...-0\ ,,'~ \ ..c_.....;:, ;:40 f~lr(1 -:-.-:-"", ? :9. -<='. ::J.o. f9 <.11 a:> - JESSICA M. SIERRA Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : DIVORCE LENIEL SOTO TORRES, Defendant. : NO.: 04-2872 CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served via certified mail on June 26, 2004. Affidavit of Service filed simultaneously with this Praecipe. 3. Complete either paragraph (a) or (b). (a) Date of execution ofthe affidavit of consent required by Section 3301(c) ofthe Divorce Code: by plaintiff on June 15, 2005; by defendant June 26, 2005. (b)(I) Date of execution of the plaintiffs affidavit required by Section 3301(d) ofthe Divorce Code: N/A; (2) Date of service ofthe plaintiffs affidavit upon the defendant: N/ A. 4. Related claims pending: None. 5. Complete either (a) or (b). a. Date and manner of service of the notice of intention to file praecipe a copy of which is attached: b. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: Executed on June 15,2005; filed simultaneously with this Praecipe. Date Defendant's Waiver of Notice was filed with the Prothonotary: Executed on June 26,2005; filed July 7, 2005. Respectfully submitted, '1)~ rY. vw1c 0 Melissa L. VanEck, Esquire Attorney ID No.: 85869 7810 Allentown Blvd, Suite B Harrisburg, P A 17112 (717) 540-5406 Date: 1. '6'05 CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Jessica Sierra, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Praecipe to Transmit was served upon Leniel Soto Torres, by depositing same in the United States mail, first class, on July 8, 2004 addressed as follows: Leniel Soto Torres 36 South 28th Street Harrisburg, PA 17103 Date: '1 ~ 1 ~DS ~ t!. V()JL~H Melissa L. Van Eck, Esquire 7810 Allentown Blvd., Suite B Harrisburg, P A 17112 Telephone: 717-540-5406 Attorney for Plaintiff ~~-~ :1 -t''. ':\.-. r:s .' (.1\ 0:> Q, ...A.-'{"'\; ::f,~ f\ '_~\ :9}d ".,"L. {";~_"f'4. ~,(~-"l.~ ~;~.~~ -s:;\ lf1. .;;c. 0;;:3, ~ ~ ~ .- r-:> ~ ~~ ~ ~ ~ ~~ ~ ~ ~~~~~~~ ~~~~ ~~~~~~~+~~~~+.~~~+.~~~~~~+. +.~+.+.+.+.~+.+.+.+.~ . IN THE COURT OF COMMON PLEAS : . OFCUMBERLANDCOUNTY ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +."'+.+. PENNA. STATE OF JESSTCA M- STERRA VERSUS LENIEL SOTO TORRES No. !1i4-2R72 PLAINTIFF T\1O'lO'1O'T\TT"IlI.T\TT AND NOW, DECREED THAT AND . . . . . . . . . " . . " " . " " . " . . . . . . . . . " . . . . . . . . . " . . . . . . . . . . . . . . . . . . . . . " . . . " " . . +. +. +. ~ ~ +. +...,'+ DECREE IN DIVORCE 1~ 1'1 - 240~ IT IS ORDERED AND .TESSICA M. STERRA , PLAINTIFF, LENTEL SOTO TORRES , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT NONE . " PROTHONOTARY ~ +. +. +.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.+.++.++.++.~+.~+.+.+.++'+ '+ . . . . . . " . " . . . . . . " . . . . . . . " . J. ~ }' ~ ~ SOr?C'L f[J~ fr :$ ~ 4w -rl 57 OV'-L " ,.-1" -