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HomeMy WebLinkAbout05-4889 ~ .. DARSHANA PATEL IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 05 -4PP? (J'(.)~L 't-~ CIVIL ACTION - LAW IN DIVORCE v. DIPAK PATEL Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. H 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 are 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 court house square, Carlisle, Pennsylvania17013. 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 ASSOCIA nON 32 South Bedford Street Carlisle, Pennsylvania 17013 Ph: (717) 249-3166 v. IN THE COURT OF COMMON PLEAS CUMBERLM'D COUNTY, PENNSYLVANIA NO. OS -A/;?? Ct'oLLY~ CIVIL ACTION - LAW IN DIVORCE DARSHANA PATEL Plaintiff DIPAK PATEL Defendant COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is DARSH.d>.NA PATEL, currently residing at 805 Acri Road, Mechanicsburg, East Pennsboro Township, Cumberland County, Pennsylvania 17050. 2. The Defendant is DIPAK PATEL, whose present address is 805 Acri Road, Mechanicsburg, East Pennsboro Tmvnship, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant has 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, 2000 in Anand, Gujarat, India. 5. There has 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 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. \\THEREFORE, Plaintiff respectfully prays your Honorable Court to enter a Decree in Divorce. Respectfully submitted, ~ Attorney for DARSHANA PATEL, Plaintiff 805 Acri Road :t\.1echanicsburg, Pennsylvania 17050 PeAL 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. 94904 relating to unsworn falsification to the authorities. Date qr2.D~6S- ~f~L DARSHANA PATEL, Plaintiff ~ - ~ ~ tJ1 ~ .-------- ~ -- ~ \) B -0 P- ~ (') s: ~ = c.n (/) Cti N Q ~ :1 . ~~g -0 \:? ;~q. -cJ :r:: ..., 1 ~ DB -"'" ;~: rr\ :::: :3 ~ Th uJ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Darshana Patel, v. NO. 05-4889 Civil Term Dipak Patel, CIVIL ACTION - LAW IN DIVORCE Defendant ACCEPTANCE OF SERVICE I accept service of the above captioned complaint in divorce on S EfJ'T 2.. 0 ,2005. I certify that I am authorized to accept service as the defendant. :P~ Dlpak Patel 805 Acri Road Mechanicsburg, PA 17050 DEFENDANT 2 0 2.00~ S G.DT DATE Respectfully submitted: 11~ r;~~ Darshana Patel 805 Acri Road Mechanicsburg, P A 17050 C) ,-- ~-, c;:..~ 'i]~ y-' .~",., _.,.~ C) -" .-\ ~-r.:-n ~~E; )l,... ))., '\~.,:\:\ '..~~\ ~~\ "~~\ ~ o rn c' 1''' - - ;;C" -------- - DARSHANA PATEL Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DIPAKPATEL Defendant NO. 05-4889 CIVIL LAW 2005 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint In Divorce was filed between DARSHANA PATEL, Plaintiff and DIP AK PATEL, Defendant on September 20, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken , all efforts at reconciliation have failed and ninety (90) days have elapsed from the date of filing and service of the Complaint In Divorce. 3. I, DASHANA PATEL, consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of a Divorce Decree. I, DARSHANA PATEL, Defendant, do hereby verify that the facts set forth in this Affidavit of Consent are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.e.S. 94904 relating to unsworn falsification to authorities. J2.-<.o.-o') ~'- JJ~ Date DARSHANA PATEL, Plaintiff ~.~2 "', C;-.1 .;:::;> ,~_..., (~ ~T1 -I ~l':::o ,(1r-. -nrr uC.? '::.} S~~ ~.<~ ~~ ~'5iTl --J ~15 .< c:::J r....l " ;""0 > :3;:; DARSHANA PATEL Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. DIPAK PATEL Defendant NO. 05-4889 CIVIL LAW 2005 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed between DARSHANA PATEL, Plaintiff and DIP AK PATEL, Defendant on September 20, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken, all efforts at reconciliation have failed and ninety (90) days have elapsed from the date of filing and service of the Complaint In Divorce. 3. I, DIPAK PATEL, consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of a Divorce Decree. I, DIP AK PATEL, Defendant, do hereby verify that the facts set forth in this Affidavit of Consent are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.c.S. 94904 relating to unsworn falsification to authorities. la--~o'- 0( gJt>>- Date DIP AK PATEL, Defendant (~ r--"') (-y (i:;;:~ '-.1 ~'-, C) r.1 .C") N , ~;: Darshana Patel, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-4889 Civil Term Dipak Patel, CIVIL ACTION - LAW IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 113301(c) OF THE PA 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 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 statement 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. D€.c 20 2DDS DATE a~ PLAINTIFF f",-~ (2 ~, ;:; C.l. :;;;; --1 ~"'Tl rnp CQ 'r' c.> -y, ","; 2(":; . ...1 , ~::\ ~:;-. "-X:; :< o f""l ,) '"'" :;0' --.::: .,1:- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Darshana Patel, v. NO. 05-4889 Civil Term Dipak Patel, CIVIL ACTION - LAW IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 113301(c) OF THE PA 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 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 statement 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~- ~O-O( DATE ~~ DEFENDANT ----- c-' c-:? C' cj'-1 o f';'\ ("-' rV --- ,---) '::-i.... .-\ 4-(_~ h"-;;;;;' . --~:(;:} _',\\o( 'i~CO: '"J1" r":;: --- --- -).-e:, , II" -c'., "y,.Y ::;). .~ .','.:" -" - DARSHANA PATEL Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DIP AK PATEL Defendant NO. 05-4889 CIVIL LAW 2005 CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF A ~3301 (cl DIVORCE DECREE To DIPAK PATEL: You have signed a S3301 (c) Affidavit of Consent consenting to entry of a Divorce Decree. Therefore, on or after December 20, 2005, the Plaintiff, D ARSHAN A PATEL, can request the Court to enter a final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the date in the paragraph above, or the Court may grant the Divorce and you will lose forever the right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect your economic claim. A COUNTERAFFIDA VIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS A IT ACHED TO THIS NOTICE. 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. THIS OFFICE CAN PROVIDE YHOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIR A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 r-' C'P C) c.Y\ o r';"': ("") \',) ./ -.... :::> -(1 -' :1;:!). f1:'r- -~~~:~ -- j,'- .1 ',-~ ,. ~::f. ...C'- .~ ~: -- DARSHANA PATEL Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DIP AI< PATEL Defendant NO. 05-4889 CIVIL ACTION - IN DIVORCE CIVILLAW LAW 2005 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree. 1. Ground for the Divorce is irretrievable breakdown under section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: September 20 2005, by acceptance of service (copy attached). 3.Date of execution of the affidavit of consent required by section 3301 (c) of the Divorce Code: by the plaintiff D tc~f'1 BER. 20 2/J05: by the defendant }) eel::. M 13E-1Z--- 2.0 2.005 . 4. No related claims are pending. 5. The Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached, was filed on SlP 1" 2.. 0 2005. ~P~l DARSHANA PATEL, Plaintiff C-., g CJJ C) -" :?T ill;=! --rJl'l~ ~jCl , ' CJ fTj ,) r,.) -'"'~> -.0' \-.-- ~ ('~" -;-~J ;-"(1 ::-:::-: :li -< GO ~'i':+: + Of . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . z . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . n. ++:+;;!;:+::+:+;f.:+: . . . . . . . . .. :+::+:+:+::+::t:+:+:+:e+; . . :+:+'Of+.+.:t::+:+:+++:+: :+:+:++:+:+++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS DIVORCE \)~7-1 DECREED THAT "bAR S l-lt-\N.A. blPAK DJ\R5HANA VERSUS ~k. 'C AND NOW, AND OFCUMBERLANDCOUNTY STATE OF PENNA. No. 05- Lf88<i YATEL DECREE IN ~-, -CiiLLk)7) IT IS ORDERED AND P~TE.L , PLAINTIFF, PATEL , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT ~6NE " ,. "' -.. ;' - '7; .- ~ ''';~", -~ ~ , '-" . '- !-... , , or --' :0 ;::-" -- " ~ ~~~~~~~~ ~~~~~~~~~~~o.~~~ ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+::+:'i'++Of:+;++:+:++++:+:+? ..// / / / ATTE'T' ~ '---, c?v~ POO"'ONO"O' ... :+:Of:+:+: +:+:+:+:+ :+::+;:+;:+':+:+:+:+++'1':+::+:+:+ J . !?:Pc Of- /'3] 1l:1.-V ~"1-0cy U:fJri at- n-'~"" f..,I~~ f'3O'~""O ~O/ -'1/ I " . '."