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Home My WebLink About06-3180 -~ ... r \F1LES\DATAFlLE\G~n<'rJI\CllJwl1t\116oJ:dcom C"~J.(eJ ~ :30~ j: -,:AM RevIsed' :3.,)t, 3 :4PM Jennifer 1. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO l.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff v. IN THE COURT 0 COMMON PLEAS OF CUMBERLAND C UNTY, PENNSYLVANIA NO. 06- .)IPO r:~uL ~E.n-~ CNIL ACTION - L W FERNANDO SANCHEZ, Plaintiff ROXANNA SANCHEZ, Defendant IN DNORCE NOTICE TO DEFEND AND CLAIM RIG Y ouhave been sued in court. If you wish to defend against the cl ims set forth in the following pages, you must take prompt action. You are warned that if you fail t do so, the case may proceed without you and a decree of divorce or annulment may be entered against ou by the Court. A judgment may also be entered against you for any other claim orrelief requested in the e 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 break own of the marriage, you may request marriage counseling. Upon your request, the Court may require yo and your spouse to attend up to three sessions. A request for counseling must be made in writing and fiI with the Prothonotarywithin twenty (20) days of receipt of this Notice. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DI ISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AN ULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYERA ONCE. IFYOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TE EPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LE AL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. CE MAY BE ABLE TO T MAY OFFER LEGAL NO FEE. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS 0 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TH SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE 0 Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 -" ... FERNANDO SANCHEZ, Plaintiff IN THE COURT 0 COMMON PLEAS OF CUMBERLAND C UNTY, PENNSYLVANIA v. NO. 06- 3/RD CIVIL ACTION - L C;G.>~L ~f/L.~ W ROXANNA SANCHEZ, Defendant IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3 01 C or 3301 (D) OF THE DIVORCE CODE 1. Plaintiff is Fernando Sanchez, who currently resides at 118 Lincoln Way West, Chambersburg, Pennsylvania 17201. 2. Defendant is Roxanna Sanchez, who currently reside at 202 South 2nd Street, #B, Chambersburg, Pennsylvania 17201. 3. Plaintiff and Defendant have been bona fide residents in the ommonwealth ofPennsylvania for at least six months immediately previous to the filing of this Com lain!. 4. The Plaintiff and Defendant were married on Septem er 3, 1999, in Hagerstown, Maryland. 5. There have been no prior actions of divorce or for ann Iment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and at Plaintiff may have the right to request that the court require the parties to participate in counseling 8. Plaintiff requests the Court to enter a decree of divorce WHEREFORE, Plaintiff requests the Court to enter a Decree dis lving the marriage between Plaintiff and Defendant. MARTSON DEARDO F WILLIAMS & OTTO Date:w(~ (~ By Je ifi 10 East igh Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff . , . VERIFICA nON The foregoing Divorce Complaint is based upon information w ich has been gathered by my counsel in the preparation of the lawsuit. The language of the docwnentis t of counsel and not my own, I have read the Divorce Complaint and to the extent that the docwnent is b ed upon information which I have given to my counsel, it is true and correct to the best of my knowled e, information and belief To the extent that the content ofthe docwnent is that of counsel, I have relie upon counsel in making this verification, This statement and verification are made subject to the penaltie of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that ifImak knowingly false averments, I may be subject to criminal penalties. Fernando Sanchez F: \FILES\DA T AFILElGeneraJ\Current\ 1 ] 664.2.dcom . () "" 0 ~ = (J F co> -oJ =' - .-1 ~ ~ ~ -or!' ,- ::L-n '-",-' s:; rll- ~ ...... .- ~t:im ~ t :c'y B U1 1:._~C\ ..... p,"", -r, ~ r-- ~ :;2~ ~ - Om 111 <3 ~ -0 ~ ---I ~ C> - ~ - N ,< -~ 1- RECEIVEL HAY262806 MDW0 t.. F:\FI~S\DATAFILE\Gene,al\Current\11664.2.aos Created: 5123106 11:42AM Revised: 6/12106 3:03PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff FERNANDO SANCHEZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3180 CIVIL ACTION - LAW ROXANNA SANCHEZ, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Roxanna Sancehz at 202 South 2nd Street, #B, Chambersburg, PA 17201, on June 7, 2006, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Roxanna Sanchez" and dated June 9, 2006. Sworn to and subscribed before me this I tBay of -July; 2006. -::run e.. ~akh~ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Melissa A. SchoIIy, Notary Public CarIl8le Bolo, Cumberland County My CommiI8ion Expiree Jan. 19, 2010 Member, Pennlylvanla AalOOlatlon of Notan.. ... ., · Complete 1terr1it'., 2, and 3. Also complete Item 4if RestriCted Delivery is desired. · Print yc& riame and addl'8SS on the reverse so that we can return the card to you. · Attach this card to the back of the mailplece, or on the front if space permits. 1. ArtIcle AddI'8ll8ed to: l'\a RMwlJ. ~~ dDJ. Sili-+h 2.n S1wf.11'13 e1aJY)bs.w~ ~ Il1.DJ 3. Servtce 1ype liB CertIlled Mall [] Express Mall [] RegIster8cl [] Retum Receipt for Merchandise [] Insured Mall [] C.O.D. 4. AeI1rtcted DelIvery? (&fnI Fee) II"\w 2. ArtIcle Number (Tiansfer ftt>{n S8fVice 1BbeI) PS Form 3811, February 2004 7005 2570 0000 3&02 8566 ----------_.~_.--..~ DomeIlIc ReUn RIoeIPt ""102595-02-M-1540 _._--,_.__.-~_..~-._,-_.._ t. ..D ..D U1 co ru CJ co fT1 U.S. Postal Service. CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Prr',-,dpr!1 . ., aGrfiuIFpJ 61' A L USE CJ CJ Certified Fee CJ z:J Retum Rl!'C8iPl Fee (Endorsement Required) CJ ReslJ1Cl1ld Delivery Fee [;; (Endorsement Required) ru Postage $ Total Postage & Fees $l.SS $3.70 $8.34 U1 CJ CJ ~ iI 0 r--,) ~ C) 'n --1 N I"J .- :,.) 04 a :D \..0 .< Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff FERNANDO SANCHEZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3180 CIVIL ACTION - LAW -, ':"i"," (/~j :::;~ rtj ROXANNA SANCHEZ, Defendant f ....1 '-' . IN DIVORCE AFFIDAVIT OF CONSENT CJ r"',) u 1. A Complaint in Divorce under 9 3301(c) oftheDivorceCodewas filed on June 5, 2006. 2. The marriage ofPlaintiff 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 subjectto the penalties of18 Pa. c.s. 94904 relating to unsworn falsification to authorities. Date: Cf I/o lOb I I :>L C- ~~___ - Fernando Sanchez, Plaintiff !"...._..."l c"") :.:;-J ;1:1 L;. r.. ~ Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff FERNANDO SANCHEZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3180 CIVIL ACTION - LAW ROXANNA SANCHEZ, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) AND ~ 3301 (d) 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. Date: q 1;0 /06 * s:-- ~~ · ~ <-..> - Fernando Sanchez, Plaintiff F IFlLES\DA T AFlLEIGenerallCurrentl 11664 2.consent Revised 10117106 1:38PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO J.D. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff FERNANDO SANCHEZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3180 CIVIL ACTION - LAW ROXANNA SANCHEZ, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301 (c) ofthe Divorce Code was filed on June 5, 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. I consent to the entryofa 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 of18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: 1/) - tg- - 0 h f{~~1 Roxanna Sanchez, Defendant (') f"'..) ~ c:=J C. c=:> ~ c:T' -0 lX' 0 ~:n mp: ("") 2::'1"',; -t mlTi ~r,:,' \D a~ --'4 . ~f~ -0 ~:rl :x ?:=~ PC: .:::- 0 Z ~ =2 0 a> -< Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff FERNANDO SANCHEZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3180 CIVIL ACTION - LA W ROXANNA SANCHEZ, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330Hc) AND ~ 330Hd) 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 waiver 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: \0 r~11 ()(p ~~4..,4" 4- ~ ~ q~ Ro a S chez, Def~dant y ,...., c:::;) c::;;;;:l c::r- :z: o <:: I -0 :x N .. C> -.i ~ -4 :r:-n rn- Hi =89 ;~~ S 55 ~ F.IFILESIDA T AFlLEIGenerallCulTcnt\11 oo4.2.pral Revised: J 111:00 1.31 PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO 1.0. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff FERNANDO SANCHEZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3180 CIVIL ACTION - LAW ROXANNA SANCHEZ, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a di vorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: via certified mail, restricted delivery on June 7, 2006. 3. Date of execution ofthe Plaintiff s affidavit of consent required by Section 3301 (c) of the Divorce Code; September 10, 2006; by the Defendant; October 18, 2006. 4. Related claims pending: All claims have been resolved. 5. Date Plaintiffs Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: September 15,2006. Date Defendant's Waiver ofNotice in 93301 ( c) Divorce was filed with the Prothonotary: November 1, 2006. MARTSON DEARDORFF WILLIAMS & OTTO !~ By Je b L. Spears, Esquire Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Date: November 1, 2006 8 :;~c,; ~ = c:::;, C-' a "Cli,~ (:) -n ~ n,"Ti r- -om :)0 C'> j ~..:!C) ~~ :::0 -< ::r:: ~ r-.:., iliiliiliili iliili IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. FERNANDO SANCHEZ Plaintiff VERSUS ROXANNA SANCHEZ No. 06-3180 Defendant DECREE IN DIVORCE AND NOW, ~ D'I t..W\~t'f 'i , 'lcL)(o , I TIS 0 ROE RED AND DECREED THAT FERNANDO SANCHEZ , PLAI NTI FF, AND ROXANNA SANCHEZ , DEFENDANT, 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. BYTHE~RZ W PROTHONOTARY if.ili if. if.if.ili J. . # ,J- nf""'" ':!Yvt. 'Ill. 5' . !! ~ Y 1- /fF"'" t-Utl . pi{) "11. ),1 . I' ~ I'- . " " .,.... ,,'