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HomeMy WebLinkAbout01-1023LISA M. GONZALES, RALPH P. GONZALES, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- //,2.3 IN DIVORCE CIVIL TERM NOTICE 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 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 the divorce is indignities or irretrievable breakdo~vn 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 Court House, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 LiSA M. GONZALES, RALPH P. GONZALES, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- ]1o~.3 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Lisa A. Gonzales, an adult individual who currently resides at 8 Forgedale Drive, Carlisle, Cumberland County, Pem~sylvania, since March 1998. 2. Defendant is Ralph P. Gonzales, an adult individual who currently resides at N. Progess Avenue, Apt. K13, Harrisburg, Dauphin County, Pennsylvania, since October 1999. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth lbr at least six months immediately previous to filing of this Complaint. 4. The Parties were married on August 5, 1995, at Carlisle, Cumberland County, PA. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. Plaintiffrequests the Court to enter a Decree of Divorce. ANDREWS & JOHNSON By: Carlisle, PA 17013 (717) 243-0123 I verify that the statements made in this Complaint are true and correct. I understand that t~lse statements herein are made subject to the penalties of l 8 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: Lisa A. Gonzales~laintiff LISA A. OONZALES, RALPH P. GONZALES, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 01-1123 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 27, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a 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. ~ 4904, relating to unswom falsification to authorities. Ralph P. Gonzales, ~ LISA A. GONZALES, RALPH P. GONZALES, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-1123 IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a 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. § 4904, relating to unsworn falsification to authorities. Date: '-7 0 I nzales, Plaintiff LISA A. GONZALES, RALPH P. GONZALES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO, 01-1123 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF TIlE 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. §4904, relating to unsworn falsification to authorities. Date: Eisa A. Gonzales, Plm'nfif~ LISA A. GONZALES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : CIVIL ACTION - LAW : RALPH P. GONZALES, : NO. 01-1123 CIVIL TERM Defendant : 1N DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE i. 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. §4904, relating to unsworn falsification to authorities. Date: RaSh P. Gonza~efendant LISA A. GONZALES, RALPH P. GONZALES, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-1123 IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND AND NOW, this .~// day of ~ 2001, I, Taylor e. Andrews, Esquire, attorney for Lisa A. Gonzales, Plaintiff in the abovb-captioned action, hereby swear that I have served a true copy of the Complaint in Divome, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter, upon the Defendant at his residence at 301 N Progress Avenue, Apt. KI3. Harrisburg, Pa 17109, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on March 5, 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Sworn and subscribed to before me this ANDREWS & JOHNSON By:__ ~ey for Plaintiff ,2001. NOTARIAL SEAL S,ELLY S~0N..OT/~RY PUSUC C^RUSLE 00R0, CO,Bm~ COU,~ LISA A. GONZALES, RALPH P. GONZALES, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 01-1123 CIVIL TERM : IN DIVORCE NOTICE OF ELECTION TO RETAKE PREVIOUS NAME Notice is hereby given that Lisa A. Gonzales, the Plaintiff in the above matter, hereby elects to retake and hereafter use her previous name of Lisa A. Ney. v )LisaA. Oonzales TO BE KNOWN AS: COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) On the ¢ day of~ ~,~,e_ ,2001, before me, a Notary Public, personally appeared Lisa A. Ney, 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, ! have hereunto set my hand and official seal. NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BOBO, CUMBEBLAND COUNTY MY COMMISSION EXPIRES APRIL 2§, 2003 Member. Fennsylva~L~A.~,~iatioll of NOt~le~ LISA A. GONZALES, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RALPH P. GONZALES, Defendant CIVIL ACTION - LAW :NO. 01-1123 : IN DIVORCE CIVIL TERM PRAEC1PE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: March 5, 2001 by restricted delivery, certified return receipt requested 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff August 7, 2001; by Defendant August 3, 2001 4. Related claims pending: None _. 5. Date PlaintifFs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date: August 5, 2001 AND By: T~. 2¢. Ar~rews, Esq. ~1 ~t, PP~m l~t0 lS~reet (717 243-0123 Su >reme Court ID No. 15641 IN THE OF CUMBERLAND STATE OF ~ COURT OF COMMON COUNTY PENNA. PLEAS Verstls .... D~fendant .......... DECREE IN DIVORCE AND NOW ...... I~.u. ~).~.~..'~...[~ ......... ]~.Z..o~. ~, it is ordered and decreed that n~sA A. CONZ^~.ES plaintiff, and .................~. ?. ~. ?.... 99~..~ .&~ .~.~ ......................... 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;