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HomeMy WebLinkAbout06-2720 -rxVL UarfaS Plaintiff v. ?j eir?a lda Uar a5 Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 06-RV6 CIVIL TERM 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 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, 1 Courthouse Square, 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 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 0 1% ?X/S4 z Aq/ QS Plaintiff V. ge la / QS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 06-A?'ZkIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 2. 3 1. Plaintiff is ( (/Q/''igdj , who currently resides at l/ Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on y p y /0 6,Z at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. v AV99av Cumberland County, Pennsylvania. h 4/ Defendant is who currently resides at 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 1?21/ -Y Date Plainti , Pro 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 for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: Plain iff NaSe Assisted by: Marylou Matas, Esquire Saidis, Flower & Lindsay 26 W. High Street Carlisle, Pennsylvania 17013 (717) 243-6222 C1 c? o n C? cr _- rP'.T:?' i T -tJ -r t . ",??` N rl 1 _ -, =z ;; -,? y- ?m f'_ ? :' o `p c x Plaintiff V. g l r1 a?Gw ?? D66ndant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06- 07a6 CIVIL TERM DIVORCE Kindly allow, Marisol Vargas , Plaintiff, to proceed in forma au eris. I, Marylou Matas, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Q --- maryto-d tas Attorney Plaintiff 26 W. High Street Carlisle, PA 17013 (717) 243-6222 G W ?G Z 4!.;; Gb C'ry '' ..{7 .?Cj i _ C:l 11 MARISOL VARGAS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-2720 REINALDO VARGAS, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, MARYLOU MATAS, Esquire, being duly sworn according to law, hereby deposes and says that on May 16, 2006 she served a true and correct copy of the Divorce Complaint upon Reinaldo Vargas (David Ramos), by mailing those documents to his address at DN 9900, 660 State Route 11, Hunlock Creek, PA 18621 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, May 18, 2006. Respectfully submitted, SAIDIS, SHUFF, FLOWER & LINDSAY SAMIS, FLOVVIM & LINDSAY 26 West High Strew Culisle, PA Mar ates, squire Attorn 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: 5/2-4/6(0 Counsel for Plaintiff ¦ 0a1FOft ? @=1.2, mid 3. Also carnpbM IM 4 t Re*lctad DelNmy Is dedred. ¦ FM your name and address on the revers so that we can roh n the card to you. ¦ 0 11a 1 tds Cmd to the beck d the mailplece, or an the fmrft If space parmlts. 1. AAde Addmeaed to: 10 j)Ou g9oo 6?G/a s1 f //csn lea,. 0 Agm t D.fsd**WY eddiam dito Lomaem17 ?Ym \ If YES. MW delivery aft m below: 0 No ? ?° 1Yve GNAsd Mall 0 hem MW 0 Bend 0 Rd= R90W for Mwdmaam 0 hvaed Mat 0 C.O.D. 4. Ra*Mad Deevery4 Mft Fes) 2. Ago%NwOer 7001 1140 0003 2512 0379 plaaalbamemnAwbw PS Fmm 3011. Fabn+my 2W4 Dammed R,aan PAW" =? c ? ? . __ -? ::; - ._.; ?- ? r r _; 9 r:? ? - . Marisol Vargas : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 06-2720 Reinaldo Vargas : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that Plaintiff in the above matter filed a Complaint in Divorce filed on May 12, 2006 , hereby intends to resume and hereafter use her previous name of Marisol Vazquez , and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. M isol rgas Mari of Va uez COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS On this, the- ], day of 20017 before me, the undersigned officer personally appeared Marisol Vargas, also known as Marisol Vazquez known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Title NOTARIAL SEAL MERLENE J. MARHEVKA, NOTARY PUBLIC CARLISLE, CUMBERLAND COUNTY, PA MY COMMISSION EXPIRES JUNE 8, 2010 _{,, r •(?`( ? ?,?? x, "'? -t-' A?r W -' ? 1 ?? ? f. 1 v ? ? w ?? -? -v ? f ---. MARISOL VARGAS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-2720 REINALDO VARGAS, Defendant IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on February 22, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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. §4904 relating to unsworn falsification to authorities. Dated:3 2 riso ar /J SAIDIS, FLOWER & LINDSAY 1AW 26 West High Street Carlisle, PA C7 ?, Q rr?r; 32. m-n s=_ n . r-j ( { ri _ m c.n hl Plaintiff v. X 19, A /,,/ 6'1', S Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA No. 06- 27 Zo CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on Gl / Z boo ( 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 divorce. 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: 911/ 07 Signature: Plaintiff N C=p N Jr lIPlaintiff V. DefegIt IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : No. 06- 77ZO CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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. 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 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. Date: Signature: Plaintiff C3 r-11 O S CP MARISOL VARGAS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-2720 REINALDO VARGAS, ALSO KNOWN AS DAVID RAMOS : Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed May 12, 2006. 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. 1 consent to the entry of a final Decree in 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 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. 4904 relating to unsworn falsification to authorities. Date: o Reinaldo Vargas, AKA id Ramos DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER-4 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAMIS, LENDS AY 26 West High Street Carlisle, PA 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 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. 4904 relating to unsworn falsification to authorities. Date: 6--?y Reinaldo Vargas, AKA id Ramos C.rc?.e?1efl C,G1c.i T%tt ?C??/?`?b?>Sh yam[-i ?! 9?O,,C7lrt-pelf C? ? d (P ? t ? Ty c n r ? "C MARISOL VARGAS, Plaintiff V. REINALDO VARGAS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2720 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on May 18, 2006, via certified mail. Proof of service was filed with the Court on May 25, 2006. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: By Plaintiff: August 7, 2007 and filed with the Prothonotary on August 7, 2007. By Defendant: August 1, 1007 and filed with the Prothonotary on August 7, 2007. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed: By Plaintiff: August 7, 2007 and filed with the Prothonotary on August 7, 2007. By Defendant: August 1, 2007 and filed with the Prothonotary on August 7, 2007. F NVFR & LINDSAY M 1 .11?UW 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY ii MaryloV' atas, Esq?ke Suprerhe ourt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 C'? ey C' ? ? ?? ? ? i ? ' ` , `l ? i ?_?)?71 hh .? :V a, "+? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MARISOL VARGAS PLAINTIFF VERSUS REINALDO VARGAS, ALSO KNOWN AS DAVID RAMOS, DEFENDANT No. 06-2720 DECREE IN DIVORCE AND NOW, /?`? ?yZ4?1IT IS ORDERED AND MART.qnT. VAR(SnC DECREED THAT AN D REINALDO VARGAS, ALSO KNOWN AS DAVID RAMOS ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; 1144 ROTHONOTARY ,ow t, ?Q ? LI ?