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Home My WebLink About05-3991 II ,. JEANNE PELAYO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 0") - 3 qq I ~-r;,...- RONALD PELAYO, Defendant : CIVIL ACTION - AT LAW : 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. 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 AS SOCIA TION 32 S. BEDFORD STREET CARLISLE, P A 17013 (717) 249-3166 800-990-9108 II !I , ,. JEANNE PELAYO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; No. of. .3"19/ &;;..t ~ vs. RONALD PELAYO, Defendant : CIVIL ACTION -AT LAW : IN DIVORCE COMPLAINT IN OrvORCF. ITNOF.R SF.CTTONS :nOl(e) or 1:'~Ol(.-l) OF THF OIVORCF COOF The Plaintiff, Jeanne Pelayo, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., LLC makes the following Complaint in Divorce: COTTNT I - NO-F A TJT .T mVORCF. 1. The Plaintiff, Jeanne Pelayo, is an adult individual who currently resides at 13 East Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania 170 II. 2. The Defendant, Ronald Pelayo, is an adult individual who currently resides at 5306 San Benito Drive, San Antonio, Texas 78228. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on March 10, 2000, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff or Defendant may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. " WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. Date: 09-/0-.5/05 { I eph D. C cio10, Esquire aw Offices of Patrick F. Lauer, Jr., LLC 108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID#90919 Tel. (717) 763-1800 II I- JEANNE PELAYO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA Ys. : No. RONALD PELAYO, Defendant : CIVIL ACTION -AT LAW : IN DIVORCE VERIFICA nON 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. S 4904, relating to unsworn falsification to authorities. Si<"',,",Y{PM</ ~o JEANNE PELA 0 Date: 5- /- os- ~ c- .....I S, (J t<" ~ "'" - ~ ~ >J\ o G ~ .--'5>,. -= ....... .....- --< \? ?, -, ~ " e ~"), ';',11 I' (,:. en --' II ~ JEANNE PELAYO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 05-3991 RONALD PELAYO, Defendant CIVIL ACTION - AT LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 4,2005. I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 2. The marriage of the Plaintiff and the 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. 4. I veritY 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. Signature: /}1 j~/,;V/ /{.//u;'O JEANNE PELAYO II ~ JEANNE PELAYO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-3991 RONALD PELAYO, Defendant : CIVIL ACTION - AT LAW . IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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. 4. 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. (/ l ,/ ;.' ..' .- -,' Ic/"'-r'~;?c/ Signature~- d/p"" / JEANNE PELA YO Date:. ---. II 'I ~ JEANNE PELAYO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. No. 05-3991 RONALD PELAYO, Defendant CIVIL ACTION - AT LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 330 I (c) of the Divorce Code was filed on August 4, 2005. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. I verity 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. !i 4904 relating to unsworn falsification to authorities. Date:~.J'VIlZ ?<>)(.. Signature: Yz-Q a~_ RONALD PELAYO II ~ JEANNE PELA YO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 05-3991 RONALD PELAYO, Defendant : CIVIL ACTION - AT LAW : IN DIVORCE DEFENDANT'S W AlVER OF NOTICE OF INTENTION TO REQUEST ENTRY Of' A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. fees, or expenses if! do not claim them before a divorce is granted. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's 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. 4. I verii)' 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: ~1;:x)\. Signature: _ f2 'l-\0 (i2- RONALD PELAYO II ~ JEANNE PELA YO, Plaintiff, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-3991 RONALD PELAYO, Defendant, CIVIL ACTION - AT LA W IN DIVORCE AFFTOA VTT OF SFRVTf'F TO THE PROTHONOTARY: I, Marlin 1. Markley, Esquire, verifY that the Complaint in Divorce has been served upon the Defendant indicated above by first class, restricted delivery, certified mail # 7000-1670-0005-2769_4750, postage prepaid, return receipt requested, pursuant to the requirements ofPa. R.c.P. 1930.4. "" i Ii I ! GO = C o ~ Co ~"/A~ E ~- , 8 j;~o~ k ~ ~A-u<e.. c A ~, rx 7f').).? -Compet. lit"'" 1 andIor:2 for addf1ionaI services. I aJso wish to receive the -<'~:nplet.ltems a. 48, and 4b. following services (for an -Print YOur name and address on the reverse of this form 80 that we can retum this extra fS.8): ~~~ f .Attach lIlia to'"' to lhe '0.0 of Iha mel''''sce, '" on lhe ba"" if 'pace does not 1. 0 Addressee's Address . pennit. DL .Writ.'R"'m R_pt R"'IU08ted' on the meil"'.ce b.low Ill. .riiol. numb." 2. ~Reetr1cted Dellvety .1l aTh. Return Reo.ipt willahow 10 whom the .nid. woo d./iv."'d end th. del. il. d.llva..., C"nsull postmester for fee. _ 48. Article Number _ ! 70M 6lft1 Me') "z'769 1{7Jl? ~ 4b. Service TypEl ~ o Registered .. Certlfled '; o Express Mall 0 Insured .5 co o Return Receipt lor Merchandise 0 COD ~ 7. teot~ty s- _ -l/J-- O~ & ... It A" ressee's Address (Only If requested 'l! and~ee/s paid) ~ ' I \~::;':"/' \'.;/1./....; ,t'if",.irt; ,.:i.?<,;,< , .." 7-B-0179 Domestic Fleti.im Receipt ,lflm!1} ;'~1994 Date: .5 - I] -2 ;;.)O~ Respectfully submitted, ".:;:;t:~re Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 (") - --- 'I I JEANNE PELAYO, Plaintiff, ~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 05-3991 RONALD PELAYO, Defendant, : CIVIL ACTION - AT LAW : IN DIVORCE PRAFC'TPF TO TRANSMIT RFCORD To the Prothonotary: Transmit the record, together with the following infonnation, to the Court for entry of a divorce decree: I. Ground for Divorce: Irretrievable breakdown WIder S 3301(c) S JJOlfd)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Service by certified mail #7000-1670-0005-2769_4750, delivered on August 9, 2005. See attached Affidavit of Service. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by the Plaintiff M~rch 11 ?OOIl ~ by the Defendant MMCh R ?OOIl (b) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: Date of filing of the Plaintiffs affidavit upon the respondent: Date of service of the Plaintiffs affidavit upon the respondent: _. 4. Related claims pending: Nonp. No r.l::llm" fBi"pn 5. (Complete either paragraph (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, (b) Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: fileci ,imll1t~neOl"ly wfPmpcipe Date Defendant's Waiver of Notice in S 330](c) Divorce was filed with the prothonotary: fileci ,imlllt~nenll,ly wfPmpcipp Respectful ubmitted, --- ~ ~------- ] - J 32. 001./ Date: Mar in . Markley, Esquire Law Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 170] 1-4706 10# 84745 Tel. (717) 763-1800 II JEANNE PELAYO. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3991 vs. RONALD PEL Y AO, Defendant : CIVIL ACTION - AT LAW : IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDA VIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 7. 2003, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verity that the statements made in this affidavit are true and correct. I understand that false statements herein are madc subject to thc penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. DATE: c? //o/{/~ . ,.,"':+:;+; . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~"'~ ~"':+:~~~~~~~ ~"':+:~~~~~ ... .. . .. ~~ ~~~~~~~ "'''' "''''+.~+.~+.~+.+. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF JEANNE PELAYO, Plaintiff VERSUS RONALD PELAYO, Defendant . . . . . . . . . . . . . . . . . . AND NOW, PENNA. NO. 2005-3991 DECREE IN DIVORCE --r>? ~ .2;'" ,Z-D<J{,. ,IT IS ORDERED AND DECREED THAT JEANNE PELAYO , PLAINTIFF, RONALD PELAYO . . . . . . . . . . . . . . . . . . . AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; None. . . . . . . . . . . . . . . . . . . . . . . . . . BY;~O;l ATr: OTHONOTARY ~"""" :f.:f .. . . .. . :+;~+.;+; ;+::f.:+;:f. :+: ;t;+. ;t:+. "'Of. 'f.'+' 'l'Of'+' ;t;+.+.+.:+: H' :+:if.:t:+''l';ti . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . " . . "~p __'trPW ,:~'iL, 1J [f" [ ?rf"'W iF? 1'f1,,:" t"w/17 1J ,e.;: ~ '<.. ~ . 'f ~