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Home My WebLink About01-1880 RAJESH B. PATEL ' IN THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA VS. - · NO. ~ 2001-/~'~ JOANN PATEL ' CIVIL ACTION - LAW Defendant · IN I:NVORCE TO JOANN PATEL: 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 enter~ against you by the CourL. 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 dghts important to you, including custody or visitation of your children. When the grounds for the divome 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 17013. J.F._Y,_O._U._D_O_N_O_'I'_FILE A CLAIM Foe ALIMONY, DtV~ON OF PROP . w¥cK U FEES OR EXPENS ' ERTY, ............ ES BEFORE A DIVORCE OR ANNULME ~eL, RNrEU, YOU MAY LOSE THE RIGHT NT IS TO CLAiM ANY OF THEM. DoYON~TSHHOAUvLED ~A~~~A_PER TO YOUR LAWYER AT oNCE. IF YOU TELEPHONE THE OFFICE SET ?~,..C~~T_...AF_.F, ORD ONE, GO TO_ OR CAN GET LEGAL HELP r~r;.n t~t:LUW TO FIND OUT WHERE YOU CUMBERLAND COUNTY BAR ASSOCiATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 RAJESH B. PATEL · IN-THE COURT OF COMMON. PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA ¥$. - · NO. S 2001 - / o~" go ~ -'/"~ JOANN PATEL · CIVIL ACTION - I~W Defendant · IN DIVORCE COMPL~.INT UN_nI=R SECTION 3301(d) OF THE DIVORCE CODE 1. The plaintiff is RAJESH I~ PATEL~ ~ho. currently resides at 30 Stephens Road, Camp Hill, Cumberland County, Commonwealth of Pennsylvania 17011. 2. The defendant is JOANN. PATEL who. p£esently resides at 1533 Route 38, Mount Holly, New Jersey 08060. 3. Plaintiff has been a. bona fide resident, in the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint in Divorce. 4. The parties were married on July IQ~ t997 in Virginia Beach, Virginia and separated in July, 1998. 5. There has been ne pri~ act[on for_ d[~eme er. annulment between the parties in this or any other jurisdiction. 6. Neither plaintiff nor.. defendant_ is a_ member Qf the United States Armed services or any of its allies. 7. The grounds upon which the plaintiff seeks a divorce are: (a) the marriage of the parties is irretrievably broken. (b) the parties have lived separate and.. apadL_fo~ a. period of at least two (2) years immediately preceding the filing, of this Complaint in Divorce.. 8. Plaintiff has been ad~isecltt~'ceu~se~ag~ av~table and_ that Plaintiff · maY have the right to request that the Court require the parties to participate tn counseling- 9. Plaintiff avers that no children were born of this marriage. 10. Plaintiff avers that the parties have no ioint marital debts and no marital property to distribute or divide. 11. Plaintiff does not seek atimc~Y~ speusat suPP°t~L o[ atterney's fees andexpenses. WHEREFORE, the plaintiff respectfullY requests that This Honorable Court grant his prayer and enter an Orde[ gr_antLng, the pallas a D_ec[ee in Divorce. ~' ~,~, e X, 30 S[ephens Road Camp Hill, .Pennsylvania 17011 Date · · tN. THE cOURT OF COMMON pLEAS ..... RAJESH B. pATEL CUMBERLAND COUNTY, PENNSYLVAN~ Plaintiff vs. NO~ S 200~ · LAW :~ · CIVIL ACTION - JOANN PATEL . LN DIVORCE Defendant VERIFICATION I verify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best .of my kno~Ntedge~ belie[ and.information. ! understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating.to. ~.[t fats[fication to the authorities : aESH Date RAJESH B. PATEL · IN THE COURT OF COMMO. N PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA VS- ' · NQ. S. 2001 JOANN PATEL · CIVIL ACTION - LAW" Defendant · IN DIVORCE COUNT~R-AFFI_nAVIT UNDER SECTION _ 1. Check either (a) or. (b): (a) ( ) I do not oppose the entry of a Divorce Decree. (b) ( ) I oppose the entry c~[ a.D[~erce Decree. because (Check (i), (ii) or both)' (i) ( ) The parties to this act[on ha~e not.lived separate and apartfor a period of at least two (2) years. (ii) ( ) The marriage is not irretrievably broken. 1. Check either (a) or (b): (a) ( ) I do not wish to. make_ any claims fo~ ~.omic mlLef. ! understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before adi~ome is_ g~anted. (b) ( ) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses ~ other important rights. NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU. DO NOT WISH TO.. MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. I verify that the statements in. the foregoing Affidavit. are true and cor£ect. ! understand that false statements herein are made subject to the penalties of'18 Pa. C.S. {}4904 relating to unsworn falsification to the authorities. Date J.OANN PA'I]EL~ De~endant RAJESH B. PATEL . IN THE. COU-RT OF. CO.MMQN. PLEAS _ · CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . · vs. · NCL S- 2001 · CIVIL ACTION - LAW:' JOANN PATEL Defendant · IN QtVORC E , AFFIDAVIT UNDER SECTION PLAINTIFF S ENTS SET FORTH IN THIS AFFIDAVIT, IF YOU WISH TO DENY ANY STAT_EM N TWENTY .(2J)) D_AYS ER-AFFIDAVIT WITHI U OR ~HE YOU MUST FILE A COUNt._.. ;'==N SERVED ON ¥O AFFIDAVIT H~=~ AFTER THIS STATEMENTS WILL BE AQMt~ED- 1. The parties to this action separate(/in ~ ~998 and ha~e. continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably-bcoken. 3. Neither the Defendant nor I is a member of the United States of America military or that of any of its allies. 4. I understand that l may lose rights concerning alimony, division of property, lawyer's fees or expenses if t do _.not claim-the[~ before the c~vor_ce is granted. I verify that the statements-in., the {oregoLrtg/~[da~are-true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to uns~fa[sific'efion to theauthodt[es- RAJESH- B. PATEL Date