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Home My WebLink About02-1412IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FA24ILY DIVISION Shawn Anthony Salazar : 3020 Market Street Apt 4 : Camp Hill, Pennsylvania 17011 : SS#516-98-6684 : vs. Julie Mae Anest 1135 Dorthy Lane Billings, Montana 59105 SS#517-94-2226 Defendant Plaintiff : 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 Di- vorce 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 Plaintiff. You may lose money, property or other rights important to you, including the right to demand marriage counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, 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 TA!~E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE: Yellowstone County Bar Association Lawyer Referral Service (406) 449-6577 IN THE COURT OF COMMON PLEAS OF CUMBERLAND PENNSYLVANIA FAMILY DIVISION COUNTY, Shawn Anthony Salazar SS#516-98-6684 Plaintiff VS. Julie Mae Anest : SS#517-94-2226 Defendant : DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. Plaintiff is Shawn Anthony Salazar, who currently resides at 3020 Market Street Apt 4, Camp Hill, Pennsylvania 17011, at least since January 1, 2002 2. Defendant is Julie Mae Anest, who currently resides at 1135 Dorothy Lane, Billings, Montana 59105, at least since November 5,2001 3. Shawn Anthony Salazar has been a bona fide resident in the Commonwealth for at least six months immediately pre- vious to the filing of this Complaint. 4. The plaintiff and defendant were married on June 20,1998 , at Billings , Montana , County of Yellowstone 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The plaintiff is aware of the availability of coun- seling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is at- tached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that defendant will also file such. an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to ~3301 (c) of the Divorce Code. Date: 03/21/2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Shawn Anthony Salazar SS#516-98-6684 Plaintiff VS. Julie Mae Anest : SS#517-94-2226 . Defendant : No. 02 -,, VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA. C.S., Subsection 4094, relating to unsworn falsification to authorities. Plaint iff j ~ -- DATE: 03/21/02 S/IA It;Y A,'YTIIO,\'y % L, Z/ R . , ' a man. ',','hose residence ~ t- .............. '- ~'-, , ;,,,,,,~;,an,, .............. whose aae is..2.~ ...>'ears, bom at !}Ii:.INGS, YELLOWS'FON~' CO :vON"\NA on SEPYEMBE~ 29 19 75 and ;','ho has. not ....... been previouMy married, His Father's Name DARIO MARQUES SALAZAR His Mother's Maiden Name was T/V¥IMY ANN K]: M ........................................................................ , a woman, whose residence is. Billings, Yellowstone Co M a a .... ¥ ............................. whose age is....~I .... years, born at MILES GTY. CUS"E{ C( M'ONTANA NOVEMBER 22 19. ................................................. on .................... 76 and who has ........ been previously married.. Her Father's Name WILLIAM OUIS AN :'g"~ ......................................... Her Mother's Maiden Name wa~ CAROLYN M,,LR E 5., OBER ~Y ~ ..... ~!r~7: o,o'' IN' WITNEaSS WIqF REOF. I have h ..... to set my h,nd and . ~¢~.O.. You are hereby authorized to join in bwful wedlock and celebrate within this state the rites and ceremonies of Marriage between 72481 ' '- STATE OF MONTANA, } County of Yellow~tone, TO ANY PERSON AUTHORIZED TO SOLEMNIZE ~ gZ~'UTh MARRIAGES, GREETINGS: Jean A. Thomgeon IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA FAMILY DIVISION Shawn Anthony Salazar SS#516-98-668 Plaintiff vs. Julie Mae Anest SS#517-94-2226 Defendant : Divorce : No. Op. -IV/? AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a No- tary Public in and for said County and State, Shawn Anthony Salazar, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his own knowledge that the Defendant Julie Mae Anest herein is not in the military service as defined in the Solders' and Sailors' Relief Act of 1940 and its Amendments thereto, for the following reasons: Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. 'gnature of Plai~f IN WITNESS THEREOF, I have hereunto set my hand and seal. Da ted: IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA FAMILY DIVISION Shawn Anthony Salazar SS#516-98-6684 Plaintiff vs. Julie Mae Anest SS#517-94-2226 Defendant No.02-1412civil DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Di- vorce Code was filed on 03/22/2002. 2. The marriage of Plaintiff and Defendant is irretrieva- bly broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. 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 verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA C.S. Sec 4904 relat- ing to unsworn falsification to authorities. S WV"[...I~ ' ~O~__ ~ U~I B E D BE F~~~ .~~DAY De ~e~dant IN THE COURT OF COMMON PLEAS OF Cumberland. COUNTY, PENNSYLVANIA FAMILY DIVISION Shawn Anthony Salazar SS#516-98-6684 Plaintiff vs. Julie Mae Anest SS%517-94-2226 Defendant No.02-1412civil DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Di- vorce Code was filed on 03/22/2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. 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 verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA C.S. Sec 4904 relating to unsworn falsification to authorities. Plaintiff Dated: ~~ ! ~, ~ SWORN TO AND SUBSCRIBED BEFORE ME THIS~ DAY NOTARIAL SEAL~---'-'~ SUSAN J. MILLER, Nota~ PubliC. Camp Hill Boro, Cumberland County My comrnissio~ EI~,~,iSe-pt'_~19'.2,005~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Shawn Anthony Salazar SS#516-98-6684 Plaintiff vs. Julie Mae Anest SS#517-94-2226 Defendant N0.02-1412 civil ACCEPTANCE OF SERVICE I, Julie Mae Anest, hereby state that I have accepted service of a true correct copy of the Complaint in Divorce in the above captioned matter at '~48 ~,r$onAw~l~l-O~by personal service. The server was~Av~¢K ~. ~A~ , whose age is ~ and whose address is - ~- De~e~--dant ~ ' 'IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA FAMILY DIVISION Shawn Anthony Salazar SS#516-98-6684 Plaintiff vs. Julie Mae Anest SS#517-94-2226 Defendant No. 02-1412 civil DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following informa- tion, to the Court for entry of an appropriate Decree: 1. Ground for Divorce. Irretrievable breakdown under ~3301 (c) of the Divorce Code. SELECT CATEGORY (A) OR (B): (A) [] Mutual Consent Date of execution of the affidavit of consent By Plaintiff: 4/28/03 By Defendant: 4/25/03 (B) [] Parties have lived separate and apart Date of execution of plaintiff's affidavit: Date of service of the plaintiff's affidavit upon the defendant: Date and manner of service of the notice of in- tention to transmit the record: (A copy is attached). 2. Date and manner of service of the complaint: 3. (a) Related claims pending: None 4. The following is requested: [] Decree in divorce with property settlement attached. If yes, attach a true and correct copy of the fully executed agreement to the proposed Decree that is submitted herewith. [] Decree in divorce with the court to retain jurisdic- tion over unresolved claims which shall be listed for a hearing. ~ Decree in divorce with no other relief granted. ~ Order for a hearing on unresolved claims. 5. Pennsylvania vital statistic form is attached. ~ Plain~fl~ ~o Se) Shawn Anthony Salazar SS#516-98-6684 Plaintiff vs. Julie Mae Anest SS#517-94-2226 Defendant No.02-1412 civil ACCEPTANCE OF SERVICE I, Julie Mae Anest, hereby state that I have accepted service of a true correct COpy of the Complaint in Divorce in the above captioned matter at ~k~k4 8 ArSon A~Ii.o~ by personal service. The Server was~,¢~ ~. ~ · whose age is 31 and whose address is - IN THE COURT OF COMMON CF CUMBERLAND COUNTY ST/~'FE OF .~.. PENNA. No. VERSUS PLEAS DECREE IN DIVORCE AND NOW, DECREED THAT AND ~ Il ~P_ , IT IS ORDERED AND 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; ATTEST~ j. PROTHONOTARY