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HomeMy WebLinkAbout10-4947r, FILf_ Tit, JANE ADAMS r ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com ---------------------------------------------- 2 5 10 r4 ADELINE DE CASTRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. ALFRED DE CASTRO, Defendant No. /4 --Llqy' Civil Term ACTION IN DIVORCE 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 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 a o op d- -, tl j e.?C S9 V- 7 .e y5- L'U/4 JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esqadams@gmaii.com ---------------------------------------------- ADELINE DE CASTRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term ALFRED DE CASTRO, : ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Adeline de Castro, a competent adult individual, who resides at 118 Strayer Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Alfred de Castro, a competent adult individual, who resides at 655 East Jersey St., Elizabeth, New Jersey, 07206. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on January 21, 1956 in New Jersey. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have four children together, however, all are adult individuals. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. §4904 relating to unsworn falsification to authorities. Date: 1o l Adeline de Castro, Plaintiff Ily submitted A P Adams, Esquire I. No. 79465 Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF JANE2010 _ADAMS ATTORNEY AT LA)Pf'?` Attorney I.D. No. 79465- 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esyadamsQgmail com ---------------------------------------------- PL 2010 JUL F ADELINE DE CASTRO, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. ALFRED DE CASTRO, Defendant No. l6 `/9,4 9,417 Civil Term : ACTION IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on December 16, 2005, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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: I _k6 - 10l 2. Adeline de C AUG 2u PM 12: 24 ADELINE DE CASTRO, IN THE N. PLEAS Plaintiff CUMBERLA PENNSYLVANIA V& No. 10 - 4947 Civil Term ALFRED DE CASTRO, ACTION IN DIVORCE Defendant AFFIDAVILQF- SEVV ?? 1, the undersigned, upon oath, deposes and says: I, Ben de Castro, am an adult individual, over the age of eighteen (18) and am of sound mind and body. My address is 740 Park Road, Morris Plains, New Jersey, 07950. I personally hand-delivered and served a copy of the Notice to Defend, Complaint in Divorce, and Affidavit of Separation, upon my brother, Alfred de Castro, as follows: j i Location Served: Date Served: I(? Time Served: S u` ; il> f Person Documents Delivered to Signed: 1k i`r Ben de Castro 740 Park Road Morris Plains, NJ 07950. Sworn to and Subscribed before me this y f day of t.-'tc4 2010 4Qwj&jblic Sate of New Jersey ADAM D. FROMME My Comrrusslon Egkn July 10, 2013 0f C0 (David 1n. Buell Me;, Renee � Simpson Prothonotary ,� 1St Deputy Prothonotary J 0 -�_r„2 j' •2 p y 0 ,,,-,,,,,,,,a_....0,4 Irene E. Morrow Kirks. Sohonage, ESQ, . � ;y,-� Solicitor 1750 2nd 1Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania /a _ -4 QL/7 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square O Suite 100 6 Carlisle, PA 17013 0 (717)240-6195 • F'a., (717)240-6573