HomeMy WebLinkAbout04-3269
In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
)
)
)
)
)
)
No. 2004 _3 .;I.{,9 ~?;...
CIVIL TERM
IN DIVORCE
vs.
DONNA M, GONZALEZ,
Defendant.
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.
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 at:
Office of the Prothonotary
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'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
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
DONNA M. GONZALEZ,
Defendant,
)
)
)
)
)
)
No. 2004 - 32,(.9
CIVIL TERM
IN DIVORCE
vs.
NOTICE OF A V AILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302(d) of the Divorce Code, you may request that the court require you and your
spouse to attend marriage counseling prior to a divorce being handed down by the court. A list
of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver
of your right to request counseling.
Michael S. Travis
ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 1701 J
(717) 731-9509
In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
)
)
)
)
)
)
No, 2004 - 3 ~ (. <t
CIVIL TERM
IN DIVORCE
vs,
DONNA M, GONZALEZ,
Defendant,
COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
Plaintiff, by his attorney Michael S. Travis, respectfully represents:
I. Plaintiff is Israel Gonzalez Soto, who resides at 802 Bridge Street, Apt. 2, New
Cumberland, Cumberland County, Pennsylvania, 17070, since 2000.
2. Defendant is Donna M. Gonzalez, who resides at 20 Franklin Avenue,
Merchantville, Camden County, New Jersey, 08109, since July 1999.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 20, 1998, in Cumberland
County, Pennsylvania.
5. A prior action for divorce, filed in the State of New Jersey, Family Court
Division, Docket No. FM-04-1555-02 was dismissed for lack of prosecution on December II,
2002. A second action, in the same Court, docketed FM-04-860-04 was also dismissed for lack
of prosecution on May 26,2004.
6. The marriage is irretrievably broken.
7. The parties have been living separate and apart. At a subsequent time, Plaintiff
may submit an Affidavit that the parties have lived separate and apart for at least two (2) years.
8. 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.
9. Neither party is in the Military Service in the United States.
10. Plaintiff requests the court to enter a decree of 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. g 4904, relating to
unsworn falsification to authorities.
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
DONNA M, GONZALEZ,
Defendant,
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No, 2004 - 0:3269
CIVIL TERM
IN DIVORCE
ISRAEL GONZALEZ SOTO,
Plaintiff,
vs,
ACCEPTANCE OF SERVICE
I accept service of the Complaint in divorce.
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Donna M. Gon&D~
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Date: 1#19/01
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
DONNA M. GONZALEZ,
Defendant.
)
)
)
)
)
)
No. 2004-03269
CIVIL TERM
IN DIVORCE
vs.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on July 7,
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 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. 904 relating to unsworn
falsification to authorities.
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
)
)
)
)
)
)
No. 2004-03269
CIVIL TERM
IN DIVORCE
vs.
DONNA M. GONZALEZ,
Defendant.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S 3301(c) ofthe Divorce Code was filed on July 7,
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 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, S 4904 relating to unsworn
falsification to authorities.
DATED: tb/tS Joy
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
DONNA M. GONZALEZ,
Defendant.
)
)
)
)
)
)
No. 2004-03269
vs.
CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER ~ 3301(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,
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,
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
ISRAEL GONZALEZ SOTO,
Plaintiff,
DONNA M. GONZALEZ,
Defendant.
)
)
)
)
)
)
No. 2004-03269
CIVIL TERM
IN DIVORCE
vs.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER ~ 3301(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! 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, S 4904 relating to unsworn
falsification to authorities,
Date: !c!t J JOY
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Michael S. Travis
lD No. 77399
3904 Trindle Road
Camp Hill, PA 17011
(717) 731-9502
ISRAEL GONZALEZ SOTO,
Plaintiff,
In the Court of Common Pleas of Cumberland County,
Pennsylvania
)
)
)
)
)
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No. 2004-03269
vs.
DONNA M. GONZALEZ,
Defendant.
CIVIL TERM
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 S 3301(c)(1) ofthe Divorce
Code,
2. Date and manner of service of the complaint: Complaint was accepted by
Defendant on July 10,2004, Acceptance of Service, filed on July 19,2004,
3. Date of execution of the affidavit of consent required by S 330l(c) of the Divorce
Code: by Plaintiff on October 12,2004; by Defendant on October 15,2004,
4, Related claims pending: No economic claims were raised,
5, Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the
prothonotary: /P - :JO , 2004,
Date Defendant's Waiver of Notice in S 3
prothonotary: /0' <~ , 2004,
ivorce was filed with the
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IN THE COURT OF COMMON PLEAS
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STATE OF
ISRAEL GJNZALEZ sara,
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NO. 2004-03269
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VERSUS
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I:::O\lNA M. GCl'JZALEZ,
Defendant.
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DECREE IN
DIVORCE
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DECREED THAT Israel GJnzalez Sato
, PLAINTIFF,
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, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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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;
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_~! PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
~Oto r.~wl 6MZala
Plaintiff
Vs
File No. 01.{- 5.2(/1
IN DIVORCE
GDVl7a Iez.. DoV\Y\tl M
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff I defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
. or L after the entry of a Final Decree in Divorce dated~,
hereby elects to resume the prior surname of 5trD 11 ? ' and gives this
written notice avowing his I her intention pursuant the provisions of 54 P.S. 704.
Date:~
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Signature at name be(ng resumed
COMMONWE,(\LTH OF PENNSYLVANIA
COUNTY OFr!...U.I'l/;}E/fUW/})
On the d/!!!- day of :1:/11.. ,2005, 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 I she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
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seal.
otary Pub
NOTARIAl SEAL
PROTHONOTAIIY. NOTARY PUBLIC
CAIlUSlE CUM.Sll.ANO COUNlY COURT HOUSE
MY COMMISSION EXPt~ES JANUARY 2. 2006
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