HomeMy WebLinkAbout14-5854 JOEL A. SANCHEZ-SAENZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. J -
C rn
NICHOLE L. SANCHEZ, CIVIL ACTION - LAW :a
Defendant IN DIVORCE
<2
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend ag:ain-s-t <
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 the 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 :
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 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. 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 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
800-990-9108
Dennis J. Shatto, Esquire
Attorney I . D. No. 25676
828 Limekiln Road
New Cumberland, PA 17070
Tel . 717-547-6384
Attorney for Plaintiff
-3- .S- . a4
a -x ion
JOEL A. SANCHEZ-SAENZ, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
NICHOLE L. SANCHEZ! CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT UNDER SECTION 3301 (c)
OF THE DIVORCE CODE
1 . Plaintiff is Joel A. Sanchez-Saenz, who resides at 120
Linden Drive, Apartment 1B, Camp Hill (Lower Allen Township) ,
Cumberland County, Pennsylvania, 17011, since March 2014 .
2 . Defendant is Nichole L. Sanchez, who resides at 1756
Peyton Randolph Court, New Cumberland, Cumberland County, PA 17070,
since May of 2014 .
3 . Plaintiff and Defendant have both been bona fide residents
in the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of this Complaint .
4 . The Plaintiff and Defendant were married on April 9, 2014,
in Harrisburg, Dauphin County, Pennsylvania.
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 . The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests this Court to enter
a Decree of Divorce pursuant to Section 3301 (c) of the Divorce
Code.
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 .
Dated: vv' 2, 2p(L1
JOEL S NCHEZ-SAENZ - Plaintiff
Dennis J. Shatto, Esquire
Attorney I . D. No. 25675
828 Limekiln Road
New Cumberland, PA 17070
Tel . 717-547-6384
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
celA.(Alr -a n2 :
Plaintiff•
vs.
File No. )'-j "nzn 1 bo, \
\1C�_ A `e, L .3 ne e2 IN DIVORCECD c=, • "T;
"T,
.p 3
r*: COe� -4-
Defendant • -„
-4 -0
vs r"' w rT
NOTICE TO RESUME PRIOR SURNAME - r�
< co -r'
Notice is hereby given that the Plaintiff / Defendant in the above matter, zc
>CDS,
(select one by marking "X"). —1 C _>
„,\(#--C :-.7.?
prior to the entry of a Final Decree in Divorce,
or after the entry of a Final Decree in Divorce dated , hereby elects to resume
the prior surname of l l\n)C' ,V . n' gives this written notice avowing
his / her intention pursuant to the provisions of 54 P.S. • 70 '
Date: )p)/2:7 `�1 �\_��iti„k ��
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF f�1/1/...444/11:71
On the
a74
air
Signature of name be" g resumed
day of De/- , 414,1y before me, the
Prothonotary or a 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 / she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand and offs i I seal.
�C 1
rotho otary or Notary
00Pd dPAt-
Cash
0-0/2679
Prothonotary, Cumberland County, Carlisle, PA ti
My Commission Expires the First Monday of Jan: 2018