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Home My WebLink About05-1319 . NATHANC. WOLF,ESQUlRE ATTORNEY In NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JAIME GUADALUPE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION . LAW IRMA L. VASQUEZ, : NO. 05 - ;J I '7 : IN DNORCE CIVIL TERM Defendant 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 in 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 propeny 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 maniage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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. IFYOU 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 . NATHAN C. WOLF, ESQUIRE ATTORNEY In NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JAIME GUADALUPE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW ; NO. 05 - i:J I Of : IN DIVORCE CIVIL TERM IRMA L. VASQUEZ, Defendant COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 (C) and 3301 (D) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Jaime Guadalupe, an adult individual residing in the Borough of Camp Hill, Cumberland County, Pennsylvania 17011. 2. The defendant is Irma L. Vasquez, an adult individual residing at 2214 Grand Cayman Court, Kissimmee, Orange County, Florida 34741. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on November 28, 1996, in Amsterdam, Montgomery County, New York 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. . 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. 7. Pursuant to the Divorce Code, Section 3301(d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties have been separated since sometime during September of 2001, a period in excess of two years. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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.CS. Section 4904, relating to unsworn falsification to authorities. I JI'I ~ ,2005 " JIi~ IV . ,2005 11~ -k;L --- .....a C> \'- - ~ -- Y--J C> ~ - ...[J '---C: ~ ;v 1- l-.' r-- --I -i- -ii'l :,::;1, .... '~. 'I f:} (:', 1;.)'; /l;) ;',' NATHAN C. WOLF, ESQUIRE AlTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARL1SLE PA 17013 (717) 241-4436 AlTORNEY FOR PLAiNT1FF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JAIME GUADALUPE, v. : CIVIL ACTION - LAW Defendant : NO. 05 - /J I r : IN DIVORCE CIVIL TERM IRMAL. VASQUEZ, PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of maniage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of a. C.S. Section 4904 relating to unsworn falsification to authorities. / <;jN ,2005 I t;?; ..--:) r:.? C:'" ._,l, NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARliSLE PA 17013 (117) 241-4436 ATTORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JAIME GUADALUPE, v. : CIVIL ACTION - LAW Defendant : NO. 2005 -1319 CIVIL TERM : IN DIVORCE IRMA L. VASQUEZ, ACCEPTANCE OF SERVICE I, Irma 1. Vasquez, certify that I am the defendant in this matter. Funhermore, I hereby certify that on .-j- / ~ - 0 S- , 2005, I received a certified copy of the divorce complaint filed in this action. .z; !/~/~5 ,2005 ~ C /;(Yf/J?q-c:S Irma L. Vasquez Defendant r-~.':' ,......~, 1._.'; ;-~.:::.:. --,:~\ c.n rid\ ';"v U-! -,"", ,;:- r., N NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JAIME GUADALUPE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW IRMA L. VASQUEZ, Defendant : NO. 05 -1319 CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I panicipate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. <-;/175,2005 q)vtV1i;! . Irma L. Vasquez, ndant ~, ,~-:; \:;; .:{) ,,' \'," (Ji ....0 r') ('C, NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JAIME GUADALUPE, Plaintiff v. : CIVIL ACTION - LAW IRMAL. VASQUEZ, Defendant : NO. 05-1319 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about March 14,2005, and served upon defendant on April 12, 2005 (see affidavit of service filed April 25, 2005). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C S. Section 4904 relating to unsworn falsification to authorities. ~. July 2.> ':;" , 2005 .l.-> ! C) C., ......, C::) ,:::;:) <.0 p.,') G.n -r) r:? en Cl ~i.~ --, r~l~l '._~i c' -"', ~l" f~,;~ NATHAN C. WOLF, ESQillRE A"ITORNEY III NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 A"ITORNEY FOR PLAINTIFF JAIME GUADALUPE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW IRMA L. VASQUEZ, Defendant : NO. 05-1319 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in tills matter on or about March 14,2005, and served upon defendant on April 12, 2005 (see affidavit of service filed April 25, 2005). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the enuy of a final decree in divorce after service of notice of intention to request enuy of the divorce. I verify that the statements made in tills affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C S. Section 4904 relating to unsworn falsification to authorities. JulyJ.L-,2005 ~r ;0 . . / ) 'L0 IRMAL.V QU Z~ ~ If '<:> <:v ;:s' "'; & ~ ii; (;; '<' o c:. .-' c;::::> c;. cP r..~, '? \"" (..n Ui;-" r ~ -' ~"'C -r~ (;--\~ -(lS'~A ,...1 -:.>. C~ ..-.;'" -" -" ..~ -:', ~:-\:(->~ -'7 ~~~~ r:--? ("r"', CJ NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JAIME GUADALUPE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW IRMAL. VASQUEZ, Defendant : NO. 05-1319 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOIJEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to the entlyof a final decree of divorce without notice. 2. I understand that I may lose rights concerrling 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 ProthonotaIy. 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. Section 4904 relating to unsworn falsification to authorities. d~6' July "Z. .)- ,2005 JAIME UADALUPE r:3 t") ;;;..? .;;~-, "-,, c__.~ c::.. '1'"" 1'''' U' -" \~;-' (n c;. NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTiFF JAIME GUADALUPE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW IRMA L. VASQUEZ, Defendant : NO. 05-1319 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOIJEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(<:) 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.CS. Section 4904 relating to unsworn falsification to authorities. July dl, 2005 ~ IRMAL. VA QUEZ ~ ~ ~ ~ t$ ~ ~ c) C ,:,., '" c;_ C'J c..:1 ~':":.-.:: r c> 01 .-\ i+~:D ,-- S'~ f',,' en --:;:1 N r,n c.:r NATHAN C. WOLF, ESQUIRE ATTORNEY III NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF JAIME GUADALUPE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW IRMA L. VASQUEZ, Defendant : NO. 05-1319 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infonnation, to the court for enuy of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about April 12, 2005, defendant was served with a copy of the divorce complaint via regular mail, addressed to the defendant. (See Acceptance of Service previously filed on or about April 25, 2005.) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: July 25, 2005. By the defendant: July21, 2005. (b) (1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N1A (b) (2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/ A 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/ A (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: July25,2005 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 25, 2005. July~2005 "" S'::::~ c:n ( r" U"; f'J t.t1 C (", ";fJ :? i'i:;ff~ c:t: 'j" c) 3-; (-') 1'-,-1 , , . . . , . . . . . . . . . . , . . . . . "'''' :+: :.""'1;:+0:+ "''''''' "'''''''''' "'~"''''+++++++++++++++++++ +++++~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ". . . . . . . . . . . . . . . . . . . . . ++++++~+++++++++++++++++++++++++++? :ti:ti ."'+ct: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Jaime Guadalupe VERSUS Inna 1. Vasquez PENNA. No. 2005 1319 DECREE IN . . . . AND NOW, JI.J\l Jaime Guadalupe . . . . . . . DECREED THAT Inna 1. Vasquez . AND . DIVORCE zt7 , 71105", IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . THE COURT RETAINS JURISDICTION OF THE FOL.LOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT ? :+ ++ +. ++++++++ +++ , . , . . . , . . , none . . . . . . . . . . . . . . . . . . . . . . . '. . BYTHECOURT: 1 of? !. AT'11 . () - V ,~~ - PROTHONOTARY J. , ,~ .~~ ~ ~ 5r7-~'L k p:z. ~~ 'r'"9 5Cl' !>e't. . .. ."'~'<-' ".. ".' '. ,,~<