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HomeMy WebLinkAbout04-6537DARSHANA PATEL Plaintiff Vo : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : 0'/'[,557 DIPAK PATEL : CIVIL ACTION - LAW Defendant : 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 by entering a written appearance personally or by attorney and file your defenses or objections in writing with the court. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered 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 without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. YOU SHOULD TAKE THIS NOTICE 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 Street Carlisle, Pennsylvania 17013 (717) 249-3166 DARSHANA PATEL : Plaintiff : V. .' : DIPAK PATEL : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - IN DIVORCE LAW Mechanicsburg, 17050. Road, COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE The Plaintiff is DARSHANA PATEL, currently residing at 805 Acri Road, East Pennsboro Township, Cumberland County, Pennsylvania 2. The Defendant is DIPAK PATEL, whose present address is 805 Acri Mechanicsburg, East Pennsboro Township, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been 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 January 18, 2001 in Petlad, Gujarat, India. 5. There have been no prior action for divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant is a member of the United States Armed services or any of its allies. 7. The parties have no joint marital debts or liabilities that require division or distribution. 8. The Plaintiff does not seek alimony and other property rights against the Defendant. 9. The Plaintiff and the Defendant will enter into a private child custody and support agreement. Those issues will not require court intervention. 10. The grounds upon which the Plaintiff requests a divorce are: both the Plaintiff and the Defendant agree that their marriage is irretrievably broken and it is best that the parties obtain an amicable divorce. 11. This action is not collusive as defined by the Divorce Code. 12. The Plaintiff has been advised of the availability of counseling and understands and is aware that either she or the Defendant has the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully prays your Honorable Court to enter a Decree in Divorce. Respectfully submitted, Attorney for DARSHANA PATEL, Plaintiff 805 Acri Road Mechanicsburg, Pennsylvania 17050 VERIFICATION I, DARSHANA PATEL, Plaintiff, do verify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, belief and information. I 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 DARSHANA PATEL, Plaintiff 7004 1160 0002 1104 3SFo,m~811,~m~o4 DARSHANA PATEL Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DIP AK PATEL Defendant NO. 04-6537 CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR DISMISSAL AND WITHDRAWAL TO THE OFFICE OF THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark as the public record the above-captioned Complaint In Divorce as "Dismissed and Withdrawn" by Praecipe of the Plaintiff. A copy of this Praecipe will be served on the Defendant by regular United States Postal Serviee mail. ~RM DARSHANNA PATEL, Plaintiff, Pro Se 805 Acri Road Mechanicsburg, Pennsylvania 17050 (717) 732-2345 cc: DIPAK PATEL 805 Acri Rd. Mech., Pa. 17050 --~\ r-o-. ------ --