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HomeMy WebLinkAbout06-1864 TV AN SOLA, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA :NO: Ole, -/fLL[ (};u~L~0Z-\ v. : crVIL ACTION - LA W CHERYL SOLA, : TN mVORCE 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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, 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 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 ASSOCIATION 2 LIBERTY AVENUE Carlisle, PA 17013 (717) 249-3166 IVAN SOLA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: ~ - /PLY : CIVIL ACTION - LAW CiQL{L0V~VL CHERYL SOLA, IN DIVORCE Defendant. COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Ivan Sola, by and through his attorneys, Mancke, Wagner and Spreha, and files the following Complaint in Divorce: I. The Plaintiff, Ivan Sola, is an adult individual residing at lIS I York Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant, Cheryl Sola, is an adult individual residing at 39 Hedge Drive Levittown, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on May 27, 1995, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. r 7. Plaintiff has been advised of the availability of counseling and that he has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based are: A. that the marriage is irretrievably broken pursuant to S3301(c) of the Divorce Code; and B. That the parties separated as of October 2000, therefore, the parties have lived separate and apart for a period of at least two (2) continuous years pursuant to S3301(d) of the Divorce Code. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce. Respectfully submitted, Mancke, Wagner & Spreha ---~ 'P. Richard Wagner, Esquire J.D. #23103 2233 North Front Street Harrisburg, P A l7ll0 (717) 234-7051 Attorneys for Plaintiff Date: .3/.?l?1/ cJ~ , VERIFICATION I verifY that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. ! ~'\~. c: .I. _A. / i)y'J;) -I- -- \ -_ DATE: 3/27/0(.J i ~ ~ '-- Gv C) ~ ~ G ~fps! ..p- () -'"1 -- :l"' ::,,~ :'11 (., o ('.) ;. ~ r-.'1 -'? :'. ..L! c....; I .-< rc~ IV AN SOLA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 2006 1864 : CIVIL ACTION - LAW CHERYL SOLA, : IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 30, 2006. 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. 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 are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: (}(JjfJIJJA /1; JOO& flh4t~ Cheryl ola 0 r--.:> <= 0 c <= " <..... c;r. L)tXi C> ~ mrr. C"? ~ :z: ".::: -l ze- N (fl." -<:.~: C> .-:'- <- ,-.. ::tT, "'~~ -0 -. "T1 z<.' :r. ;~o 5~ om z ~ :< +:'" ~ N IVAN SOLA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 2006-1864 : CIVIL ACTION - LAW CHERYL SOLA, : IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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. IhA~jj,h' Cheryl la DATE: (}~/7ItJf-</<h20(;'& (") c ~ -ore t:p!=: ...-. ~";"e' 9jSi ~=::: ?;~::; ..P r-- Z ~ ~ t::::::> = er- a n -f N o -u :3': o ." ~:o Ml :8y 00 ::;j -r- ..,!-- -ri (-'0 Zm o --I ~ ..... N ...... IV AN SOLA, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 06-1864 CIVIL ACTION - LAW CHERYL SOLA, IN DIVORCE Defendant. CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of Mancke, Wagner, Spreha & McQuillan, do hereby certifY that on this date a copy of the Complaint in divorce was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Ms. Cheryl Sola 39 Hedge Drive Levittown, P A 19054 By rUt,. _ ~, A jJ".}~~L~~ Debra K. Spinner, S~cretary Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, P A 17110 P. Richard Wagner, Esquire Attorney for Plaintiff Date: 1//3/01/ / I .. LI1 ....D .:T LI1 U.S. Postal ServiceTM CERTIFIED MAllrM RECEIPT (Domestic Mail Only; No Inswance Coverage Provided) ...-'l ru rrI rrI ...-'l CJ CJ CJ CJ ....D ...-'l ...-'l LI1 CJ CJ I"- Postage $ ,t3 Certified Fee ). t.f 0 Postmark Return Receipt Fee j.g!f Here (Endorsement Required) Restricted Delivery Fee ~,10 (Endorsement Required) Total Postage & Fees $ .2'!] Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and-address on the reverse so' that we can return the card to you. . Attath this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: }j~, CI~~/~~~tv 31 (J!.J~ ~ 7f~/?C0 / r t?6t C. Date of Delivery --, 'l)'uk> D. Is delivery ad 55 different from Item 1? 0 Yes If YES, enter delivery address below: 0 No ~ 3. ~rvice Type ~ Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (rransfer from seNice label) PS Form 3811 , February 2004 7005 1160 0001 3321 5465 Domestic Return Receipt 102595-02-M-1540 , ......c ~ () fi r-..' ~~ r.:-~ o -n -l :I-fl r:lp en '::J C- c:-..., ~.._) \}. ,::' " IV AN SOLA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 2006 1864 : CIVIL ACTION - LAW CHERYL SOLA, : IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 30, 2006. 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. 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 are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authOritieJ ~D ~ ~ DA TE:/:;! - /.g / d Ie, ~ _/ -\ccA Ivan Sola a ,..-..... ~~~ (" ~ = = -.... c..... :r> 2 C1 ~:~ -;:... L:) co IV AN SOLA, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2006-1864 : CIVIL ACTION - LA W CHERYL SOLA, : IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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. ~4904 relating to unsworn falsification to authorities. J~ YJ] \ C' , ..... ... . . LW~ I van Sola DATE: I Z,' I t> 0 & (') C -.7P -...... ~~ ;' .~, r-:> = r;:.::J --J <- :J';~ :?~ o '"11 ~-r1 f;lp -(1 O~ -"1......' ;ifl~), ;{~~~)\ ":0 ~ 0"\ ~.;..,.. -:.~~ t..~l \.P If -~ IV AN SOLA, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 2006-1864 - CIVIL TERM : CIVIL ACTION - LAW CHERYL SOLA, : IN DIVORCE Defendant. PRAECIPE TO TRANSMIT THE 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 Section 3301(c), 3301(d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: July 13, 2006, by certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 12/18/06 By Defendant: 10/14/06 (b) (1) Date of Execution ofthe Plaintiff's Affidavit required Section 330l(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301 (d) (1)(i) of the Divorce Code: . -" (b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: 01/11/07 (c) Date Defendant's Waiver ofN e was filed with the Prothonotary: 10/19/06 /"''''''~ P. Richard er, Esq. mey for Plaintiff (') C~~~. \D 1"--, c::::. ~:-:::) ........ (- ~;:: o -n -f :r:-,-. fJ'j~ -nJl-; ~,-(S -..-. -"j, .'c -(', ~Ff1 ~ c, :!".:.:: -'.... '..:::) !Ii!li!li "'''' !Ii !Ii !Ii !li !Ii !Ii !Ii !Ii !Ii !li !Ii !Ii !Ii !Ii ff. !Ii ff. ff. !Ii ff. !Ii ff. ,!Ii !Ii !Ii !li ff. !Ii !li !Ii PROTHONOTARY !Ii !Ii !Ii !Ii !Ii!li!li!li!li !li!li!li!li !li!li!li !li!li!li!li!li!li !Ii!li!li!li!li!li!li!liff.!li!li!li!li!li~ if.if. if. if. if. if. ff.if.if.if.if.if.if.if.if. if. !liff.!liff. !Ii !Ii !Ii !Ii !Ii !Ii !Ii !liff.!liif.!Ii!li!liif.ff.!Ii!li!liff.!Ii!liff.!liff.!Ii!li!liff.!Ii!liif.!Ii IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. IVAN SOLA No. 2006-1864-CIVll. VERSUS CHERYL SOLA !Ii !Ii !Ii DECREE IN DIVORCE AND NOW, 1~~~~\\.", IVAN SOLA , PLAI NTI FF, \'6 , 'l.{}()7 , IT IS ORDERED AND DECREED THAT CHERYL SOLA , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; NONE ATTEST: !liif.!li !li!liif.!Ii !Ii !Ii ;F. ;Ii !li!li!li ;F.;F.;F. !Ii J. _ r:fip ft ~ ~Jt, ,-0' ~I -, ~ jp ,.~.~ IV oJ-""/ ~ . .\ . . ~ .