HomeMy WebLinkAbout05-5340
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CRYSTAL J, RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
NO. OS:?3'1OCIVIL TERM
FLOR RIVERA, JR.,
Defendant
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 or divorce or annulment may be entered against you by
the court. A judgment may also be entered against you for other claims 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 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. Bedford Street
Carlisle, P A 170 I3
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court, You must attend the scheduled conference or hearing.
CRYSTAL J. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
NO. OS-53'/'CIVIL TERM
FLOR RIVERA, JR.,
Defendant
The plaintiff, Crystal Rivera, by her attorneys, the Family Law Clinic, sets forth the
following cause of action for divorce:
COMPLAINT UNDER 23 Pa.CoS. && 3301 (c) and (d) OF THE DIVORCE CODE
I. Plaintiff is Crystal Rivera, who is currently resides at 516 A Market Street, Lemoyne,
Cumberland County, Pennsylvania, 17043, since August 2005,
2. Defendant is Flor Rivera, Jr., who currently resides at 756 Erford Road, Camp Hill,
Cumberland County, Pennsylvania, 170 II, since May 2004.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 10, 2002 in Dillsburg, York
County, Pennsylvania.
5. 'Plaintiffand Defendant have lived separate and apart since May of 2004.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
marriage.
Respectfully Submitted,
Date
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DC 0 STON-WALSH
ROBERT RAINS
ANNE MACDONALD-FOX
THOMAS M, PLACE
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2368
VERIFICATION
I verify that the statements made in the foregoing Complaint for Divorce are true
and correct, to the best of my knowledge, information and belief. I understand making
any false statement would subject me to the penalties of 18 Pa.C.S. S4904, relating to
unsworn falsification to authorities.
Date: ~!DS'
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CRYSTAL J. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
CIVIL ACTION - LAW
IN DIVORCE
FLOR RIVERA, JR.,
Defendant
NO..?{-S3YO CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Crystal Rivera, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis,
certifies that we believe the party is unable to pay the costs and that we are providing free
legal service to the party.
Date Oc:r~l."" 11. 'U>fJ5'
/
rtUM
. PLACE
ROBE T INS
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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CRYSTAL J. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
FLOR RIVERA, JR.,
Defendant
NO. 05-5340 CIVIL TERM
PRAECIPE TO REINSTATE THE COMPLAINT
To the Prothonotary:
Please reinstate the Complaint in the above-captioned case filed at the
Cumberland County Courthouse on October 12,2005.
Date: /cf1 / /.5/ 0_7-
I I
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UCY TON-WALSH
ROBER E. RAINS
THOMAS PLACE
ANNE MACDONALD-FOX
Counsel for Plaintiff
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
-------
CRYSTAL J. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL,v,ANtA
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v.
CIVIL ACTION - LA W
IN DIVORCE
NO.O)~ CIVIL TERM
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FLOR RIVERA, JR.,
Defendant
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NOTICE TO DEFEND AND CLAIM RIGHTS
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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 or divorce or annulment may be entered against you by
the court, A judgment may also be entered against you for other claims 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'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 LA WYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIA TION
32 S. Bedford Street
Carlisle, PAl 7013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing,
CRYSTAL J. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
FLOR RIVERA, JR.,
Defendant
NO.
CIVIL TERM
The plaintiff, Crystal Rivera, by her attorneys, the Family Law Clinic, sets forth the
following cause of action for divorce:
COMPLAINT UNDER 23 Pa.C.S, && 3301 (c) and (d) OF THE DIVORCE CODE
1. Plaintiff is Crystal Rivera, who is currently resides at 516 A Market Street, Lemoyne,
Cumberland County, Pennsylvania, 17043, since August 2005.
2. Defendant is Flor Rivera, Jr., who currently resides at 756 Erford Road, Camp Hill,
Cumberland County, Pennsylvania, 17011, since May 2004.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 10,2002 in Dillsburg, York
County, Pennsylvania.
5. Plaintiff and Defendant have lived separate and apart since May of 2004.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
marrIage.
Respectfully Submitted,
Date
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~~vall
Certi led Legal Intern
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tUCY JOHNSTON-WALSH
ROBERT RAINS
ANNE MACDONALD-FOX
THOMAS M. PLACE
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2368
CRYSTAL 1. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS 01'
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
FLOR RIVERA, JR.,
Defendant
NO. 05-5340
CIVIL TERM
AFFIDAVIT OF SERVICE
I, Laurie L. Wolf, hereby certify that I personally served a true and correct copy of the
Divorce Complaint and Praecipe To Reinstate Complaint, on Flor Rivera, Jr., at: The
Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013, at 10:00 a.m. on
Thursday, December 15, 2005.
I verify that the statements made in this Affidavit of Service are true and correct to the best
of my personal knowledge and belief. I understand that false statements herein are made subject
to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities.
Date: /~1/16/Ci)
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~/Laurie L. wiJ!(
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45 North Pitt Street
Carlisle, PA 17013
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CRYSTAL J. RIVERA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
FLOR RIVERA, JR.,
Defendant
: NO. 05- 5340
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
1l3301(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.
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. 94904 relating to unsworn
falsification to authorities.
Date
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CRYSTAL J. RIVERA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
FLOR RIVERA, JR.,
Defendant
: NO. 05-5340
CIVIL TERM
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under SS 330 I (c) of the Divorce Code was filed on December
13,2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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.
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. S4904, relating to unsworn
falsification to authorilies.
Date
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CRYSTAL J. RIVERA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
FLOR RIVERA, JR.,
Defendant
: NO. 05- 5340
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
&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 in 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.C.S. 94904 relating to unsworn
falsification to authorities.
Date $ .11./t
Wal ~fL;
Ms. Crystal J. Rivera, Plaintiff
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CRYSTAL J. RIVERA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
FLOR RIVERA, JR.,
Defendant
: NO. 05-5340
CIVIL TERM
AFFIDAVIT OF CONSENT
l. A Complaint in Divorce under SS 3301(c) of the Divorce Code was filed on December
13,2005.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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.
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. S4904, relating to unsworn
falsification to authorities.
Date g. ~q()1.o
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Ms. Crystal J. Rivera, Plaintiff
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CRYSTAL J. RIVERA,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION-LAW
DIVORCE
FLOR RIVERA, JR.,
Defendant
: NO. 05 - 5340
CIVIL TERM
CERTIFICATE OF SERVICE
I, Jeffrey Stovall, Certified Legal Intern, Family Law Clinic, hereby certify that I served a
true and correct copy of the Plaintiff and Defendant's Affidavit of Consent and Waiver of Notice
wlder g3301(c) of the Divorce Code on the following person by first class U.S. Mail, Postage
prepaid, on April 5, 2006:
Flor Rivera, Jr.
6165 Haymarket Way
Mechanicsburg, P A 17050
Date: 1/sk-
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Certified Legal Intern
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ucy s on-Walsh, Esq.
Supervising Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
Fax: (717) 243-3639
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CRYSTAL J. RIVERA,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION- LAW
: IN DIVORCE AND CUSTODY
FLOR RIVERA, JR.,
Defendant
: No. 05-5340 CIVIL TERM
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 divorce: irretrievable breakdown under S3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Served on Defendant by hand delivery at
the Cumberland County Prison, 1101 Claremont Road, Carlisle, P A 17013. Service was
complete upon receipt by Mr. Flor Rivera, Jr., at 10:00 a.m. on December 15,2005.
3. Date of execution of the affidavit of consent required by S3301 (c) of the Divorce
Code: by plaintiff- March 29,2006; by defendant-March 29, 2006.
4. Related claims pending: none
5. Date plaintiff's Waiver of Notice was filed with the Prothonotary: April 5, 2006.
Date defendant's Waiver of Notice was filed with the ,prothonotary: April 5, 2006.
t-r/rz,/06 ' ~. - -
m~~rn -~
William G. Martin
Supervising Attorney
F AMIL Y LAW CLINIC
45 N. Pitt Street
Carlisle, PAl 7013
717-243-2968
Fax: 717-243-3639
Attorneys for Plaintiff
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
CRYSTAL J,
RIVERA,
Plaintiff
VERSUS
FLOR RIVERA,
JR,
Defendant
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AND NOW,
DECREED THAT
AND
PENNA,
No,
2005
5340
DECREE IN
DIVORCE
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,200 b, IT IS ORDERED AND
CRYSTAL J,
RIVERA
, PLAINTIFF,
FLOR RIVERA,
, DEFENDANT,
JR,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
MARY ANN DYARMAN
PENNA.
STATE OF
No.
05.5508
VERSUS
SETH H. DY ARMAN
DECREE IN
DIVORCE
AND NOW,
~ Q,', \
MARY ANN DYARMAN
, 1,(\()(", IT IS ORDERED AND
1b
DECREED THAT
, PLAINTIFF,
AND
SETH H. DY ARMAN
, 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
YNljt~~~ltafiltTE RED;
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PROTHONOTARY .
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By T\~~O~T: ~\, \,
ATTEST: -a-
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Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
CRYSTALJ. RIVERA,
v.
: CIVIL ACTION- LAW
: IN DIVORCE AND CUSTODY
FLOR RIVERA, JR.,
Defendant
: No. 05-5340 CIVIL TERM
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above matter, having been granted
a Final Decree in divorce from the bonds of matrimony on the 20th day of April, 2006,
hereby elects to retake and hereafter use her previous name of Crystal J. Itri, and gives
this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S.
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Wishes To Be Known As:
Crystal J. Itri
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
On the _ day of July, 2006, before me, a Notary Public, personally appeared
Crystal J. Rivera, known to me to be the person whose name is subscribed to the within
document, and acknowledged that she executed the foregoing for the purpose therein
contained.
IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal.
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NOr RY PUBLIC
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LINDA M. CARVER, NOTARY PU8U,
CARLISLE BORG" CUMBERLAND COUI'I
I MY COMMISSION EXPIRES DEC. 5, 20fJG .
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