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HomeMy WebLinkAbout06-0654 \ !~Vf\ C>I'I\iO Sr. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 0(, . (.5'({ CIVIL TERM '1 \(.ell~ CA'ltU Defendant : 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 grounds 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, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMIONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YORU LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINDOUT WHERE YOU CAN GET LEGAL HELP. COURT ADMNINISTRATOR 4lli Floor Cumberland County Courthouse One Courthouse Square One Courthouse Square Carlisle, P A 17013 (717) 697-0371 . tJJ:y'f~ Gtro Sf Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA VI. : CIVIL ACTION - LAW t 'feVG. CV\irt> : NO. 0(, - (,S1f CIVIL TERM Defendant ; IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is an adult individual residing at ~ (Iv I \ \ )f!eu) 8~'(,I.l- ~&. I (\f\(J..( II s, U I \ \e., County, Pennsylvania, 17053. 2. Defendant is Sre.\.JO.... &1'rO, an adult individual currently residing at ~O'3 \.&1\\\lLt- ~.) C~t\'S\o \7.Cl3 3. Plaintiff and Defendant were married on ~s+ ~\ \qqll ,in \~l...'\ K\'n~r,,)+o.~n \ PA- Plaintiff and Defendant were separated on ~ () \ A (I ("I 5. The marriage is irretrievably broken. 'd 00 ~ 4. 6. There has been no prior action for divorce or annulment of the marriage between the parties in this or any other jurisdiction. 7. Plaintiff and the Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing ofthe Complaint. 8. Plaintiff has been advised ofthe availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. . Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 9. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, Ninety (90) days from the date ofthe filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff prays for divorce from the bonds of matrimony existing between the Plaintiff and Defendant pursuant to 23 P.S. Section 3301 <<;l of the Domestic Relations Code. RESPECTFULLY SUBMlTIED, \M0J\AQN'\ ~jl~ , Plaintiff Date: :J -01- of; 0 "'" <::;;:;> 0 c: (;:;:~ -n .,- c,-,. ~ ..,., -l r ~ rrl :C-n c:: rnp I -,::)18 ,"--' ~/J9 .(.: :::B, -::J,,") - '" -n 1~j ';',-. '" \-. ::i,~: ') :':) :',:_.("'1 ~ "" 1':-:" ,,'c;,fl"1 .. " "" ~=--1 -- ':;;-,.. v, '':> = :D "-l:; " CD -< v;) . l~v\/\X~, d{~ !j~VI\ C!\\1O Sf'. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. Or. - it, ::,-C{ CIVIL TERM \'f.ev(,- Ulitre Defendant : 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 grounds 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, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAJM FOR ALIMIONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RlGHT TO CLAIM ANY OF TW'M. YOU SHOULD TAKE THIS PAPER TO YORU LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINDOUT WHERE YOU CAN GET LEGAL HELP. COURT ADMNINISTRATOR 4TI1 Floor Cumberland County Courthouse One Courthouse Square One Courthouse Square Carlisle, P A 17013 (717) 697-0371 tHU:::: Cf\t'" ~::!~:'.\H j"'''''''OR'''' '''\ Y'~~~i,;;;1Jj:J:r-j'j ~,' :._,'. ~,_' I" "',,,"',; ,;,_~;c';"'J '{t,\f r:'.'!;:,.... ,'-t ""Jt 'Z~~i "~,";,, . :)-. j! ;.)': :,':f~~,f"; ~~~,:~:;i~(b:;::~:::_ r,; 1 ;ItS I ~ :.lay r)iJ4~,'I' -?aor." .... }=i'" 0 )l",~~, ~7'~- Pl't~'"' " .\_ r). Sr:. L\J..:Vf\'<<'" Uv<<w-e Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYL VANIA VI. : CIVIL ACTION - LAW -r teVo- C~\\'L) : NO. 0(,. (,5'/ CIVIL TERM Defendant ; IN DIVORCE COMPLAINT IN DIVORCE I. Plaintiff is an adult individual residing at ~. ily)\ lc)tEuJ ~&. I M(l 'rltS\J\ \ \e- ~ f' n / County, Pennsylvania, 17053. - .J 2. Defendant is Sr€.\Ja... &1'('0, an adult individual currently 303 \&:x\f\\1\1- lCl~~\ C~ke:,\o \7.6l3 residing at 3. Plaintiff and Defendant were married on ~~\}L{qq . ,in~U-sl- J\:i:.lk"i K;~ ~ ~ ~n PPr i--l 1L1'1Y I 4. Plaintiff and Defendant were separated on ~ n'i I (I {' "f 5. The marriage is irretrievably broken. 'd 00 ~ 6. There has been no prior action for divorce or annulment of the marriage between the parties in this or any other jurisdiction. 7. Plaintiff and the Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of the Complaint. 8. Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. , Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 9. Neither the Plaintiff nor the Defendant are members of the United States Anned Forces or its Allies. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, Ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff prays for divorce from the bonds of matrimony existing between the Plaintiff and Defendant pursuant to 23 P.S. Section 3301 (\;) ofthe Domestic Relations Code. RESPECTFULLY SUBMITTED, \JJCA.^J.Q/\,,\ CJ~~ , Plaintiff (JJ1 Date: ~ - () {- 0 b ~-ll-OG \)J~ ., - DIVORCE INFORMA TfON SHEET PURSUANT TO ACT 2001-82. VITAL STATISTIC FORMS ARE NOT REQUIRED BY THE STATE EFFECTIVE JANUARY 1. 2002. THE PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF THE VITAL STATISTICS FORM PLEASE Fill IN THE APPROPRIA TE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DOCKET NUMBER: ceo - 05L{ DATE OF MARRIAGE: ~\,~C/>'S+ /)7, 1 Ctg~ ./ " \.i ~.... I ! t!' c;;;t;..ir: ~~; g~ -" ~~' r) h" "! '. ~ \' lJ) -C C .s -~ . :ol,!!l;~'E.O~ -!' ,,; ~ ~ B 13 E .f-',. - ~i:gs~~ "7j'')'CQ- .,jo'9 E" a 'c. r:: ,... Ri 1;!.?- 0 .;>- :;Ultl~;;~ B .( C!) ~c\ij~\3'C ~ t'.' ,0 '" '$" '" ",g ~ 3 ~~~!;S~ ~ o..~ >(!S-fi~ ~ EEt:.~ttlO (.) 8~;fg~o ~ . . . H 021 ~ 1~~ - "] ~.~) ,- Ii: !l' -J H ,i\5 '" . 'i 1 h i ~" ~~ "''' o 1\ 11 ~ I f" >'. ;. ~ .g ,,\@i ::; a: ~ ..i..6Q! ,;,'U::; e 000 ~ (;\' ~ ~ ;3, % "Ii ..0 ~ ~ .. r'l " - !il~ '" g ~ 8a:E. o .; ::0 0) - f-t...., "".- n L~ ~f ~ o ~ o tr rr ru Cl r'l Cl Cl Cl Cl Cl r'l Cl ..0 Cl Cl f'- i~ ".X\ r'l (~ ,,) - :- '? - f :- :- ~ - ::- ::- ::- :- ~ -:- ~ :- - ::- :- - ::- ~ '?,. ~ ~ ~ $ ~ '" ." ". ?- ~ 'e ~ ~ ~ '&. 9;- ~ ~ 0- ~ ~ ... .l> ~~ ~ r;; '" ~ . 3=Z~ \' \" ;--f . ~ ') f:> .J.. ::::> \J' c c D =-., O. ,.0 - S"" c; J 0 ~1? ~ -::y '<:-' -.J ~ () J\ v. - .-.-'- C -z ~ o <B ~ <Jl ;;~:, t:.," . . ~'"i:\ ' oj). ,-J ':" 1J ~; G\ '~ '1) ,-",l "P' .~ ~ ~ .:> , 'I, -- -- ",- "",.,"~ Wet 'I' (e r> ((-,NO A c\ n i. \- \. sr. '\I, C)e.f'Q0J'-I.n-L AFFIDAVIT OF CONSENT. \ ~QVCA. eOtre) ,.Ln Uv; Court Q{ (o(T1r{)<) 71J?45 9J- C uflIbeclc;(> J Co v \1 ~ / Pu" n::; 'i \ V<'_u'pc, C \ v, \ A=cbOI) - Lc" u.l (lJo c) L" - (s S-y CWo \ , ,;.;:rr< . \ tV O'U()r\.J- 1. A complaint in divorce under 9 3301 (c) of the Divorce Code was filed on c.OJlJ, A~ 0; )oD0 . Date 2, The marriage of plaintiff and 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, 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: "l - G - Ofp w~ Ch9 (PLAINTIFF) Date: L(Q ~O (d ~f)l1P rD FENDANT) r-_' C? C) ~~~::: -n C,f'; r;"' I en -:"",!. N C".) :~j~l~ ?f5 -< \],,,7,(0.1'1 "'\ (' r J; '" n V C\.ln"t;I~" Ln tk.... court <;;> LOm(Y'lOn ,,1J;1(t; all 'l) Sr. II os. Com~,-'C\()d CC)l.)(\'1& 9<<on5'11lAl . . DQ~'l1~~'IL . : ('In\ CALt-JOn - Lu~ \(QJct CClI(C) (Caption) : NO. Q{x- ~SL..\ CIUI\ T~r", WAIVER OF NOTICE OF INiE~TlcrN\ ~8 ~~ 22PLa QUEST ENTRY OF A DIVORCE DECREE UNDER! 3301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce degree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: ~-(e - 0 lc lA b Jv.~~AD (PLAINTIFF) Date: _'6' - Co -O~ miF ^O~JTA D ~~ (D ENDANT) . o c~, ,..-> t::::::' c::-:;:-' C;'" en \ (-, 1'"j -\ ~I:; ~ \ . \ (..r'. N .. L;) \)Arqn Cq I ro Sc \ ,,<-va, CD I rC) ~ .l-f\ "' \--v. (ovr+ Q.c. (OMl1'CX\ (I) 1>QS of: C\.IM \H:d4 ()(-l {aVO ~1/itl)r,s,)1 vbtn, : CIVIl P!G\-'C")I1'- Ltlw (Caption): NO. 0\9 ~ GS~ C \ V' 1\ lQrrn : .\-f\ DIVO,Q.. 2,000 NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301 (C) DIVORCE DECREE 9\ Q. \ 0b f-\- V Q.Q ~~<HjcV'\L ~ "- TO: =-1 '{eve.... W\('O (PLAINTIFF) ( FENDANT) You have signed a 9 3301 (c) affidavit consenting to the entry of a divorce decree. Therefore, on or after -J(,ll~ 7 ,200 "'h ,the other party can request the court to enter a final decr e 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 claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAN NO AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. (Name) (Address) (Telephone) The above lines are to completed with the name, address and telephone number of the officer, organization, agency or person designated by the court in accordance with Rule 1018.1 (c). The date to be inserted in the first paragraph of the notice must be at least twenty days after the date on which the notice was mailed or delivered. I, \ ~ CVV ,^,rJ' V\J 9; r-' C,:;. .;.,-:? .;::,'" (f) , (J'i -0 \'-) c..) <.-c () '-'n .-i ~.~ ," :;J --<. IN THE COURT OF CCMMON PLEAS OF CUMBERLAND COUNrY, PENNSYLVANIA WAJ....Q.'iN c..a.~rO, S K . NO. 0&-6.'>-1( CIVIL & ;),006. vs. \~e"A- C4((() 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 3301 (d)(l) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: f1\ A12-c II mk,::',E;O (y\C(d(/~-tv~f\ (-((flfl reoonf-.ed II .)DO b I U I t\ 3. Canplete either Paragraph A. or B. 8 Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff by the defendant ~ (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: _~- ~~bJ'e-{\?J. 4. Related claims pending: Ai //l' 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code ~a~- D.e II tJ'fJ\.9..eV. ~ ~-q-(b ~Q)JfJ [) CA~ Attorney for Plaintiff/Defendant ....., C? C::.l c:"> () --n -j ".,- r-~'1 f~l -l--;(f\ )l:.j , </,; I c..;, -0 N (A' CoT) IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY DECREE IN DIVORCE AND NOW, ~.apJo.L (, DECREED THAT ~~ ~\IO SV AND -W.a.vc-. ~\.\'O STATE OF ~\o.(' ("2. A CS; \ r () Sf VERSUS \(200. lOllC) . . . PENNA. No. 0<'0 l.:.'5l..\ c, V \ \ -r Uf'n 2..0 () (:p ~. IT IS ORDERED AND , PLAINTIFF, , 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; V~ ATTEST: J. - PROTHONOTARY >_< "'. -,-\." '" y ,1 .... h --- ~Jt-, 'lQ- L " "'If' :.;:.... "W -I"? 'Il' l. 'I .~ .. .- .' ' -. ~".... _ .'-'. ..' "',," . ~ r', ~ ".,;JJ. ,) ^ ,- ~ .-.