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HomeMy WebLinkAbout06-4128 .i' o ALPESH PATEL, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, : PENNSYLVANIA -v- : No. 2006 - LfI2.-f( ~ Defendant : CIVIL ACTION---LA W : IN DIVORCE NEHAL PATEL, 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Dauphin County Courthouse, Front & Market Streets, Harrisburg, Pennsylvania 17101. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS' 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 ds...be,..f-.:( ];I! lpJl.in County Lawyer Referral Service Cue 213 Hurch l'l'ElM gWlll;lt S:z. S. '.w..6~ ~ ' ( -UItI'l'iMJl.trg, Penn5yl.<u,;.. 11101 717232 7536 &rDs{e, Pit 170']. I C!.!.7) y'f r - ?, I t,~ 10 ALPESH PATEL, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, : PENNSYLVANIA -v- . ; No. 2006 - "I1.n t.:u.l Ti--. Defendant : CIVIL ACTION--LA W : IN DIVORCE NEHAL PATEL, COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I The plaintiff is Alpesh Patel, an adult individual who currently resides at 14 Fortuna Lane, Enola, Cumberland County, Pennsylvania 17025. I. The defendant is Nehal Patel, an adult individual, who currently resides at 14 Fortuna Lane, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The parties were married on October 17,2001, in India. 5. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 6. Neither plaintiff nor defendant is a member of the United States Anned Services or any of its allies. 7. There were no children born of the marriage. .. 8. The grounds upon which the plaintiff requests a divorce are as follows:- (a) Defendant has offered such indignities to the plaintiff, the injured and innocent spouse, as to render plaintiffs condition intolerable and her life burdensome. (b) The marriage of the parties is irretrievably broken. 9. This action is not collusive as defmed by Section 3303 of the Divorce Code. 10. The plaintiff has been advised of the availability of counseling and understands that she may have the right to request that the court require the plaintiff and defendant to participate in counseling. WHEREFORE, plaintiff respectfully prays your Honorable Court to enter a decree in divorce. Respectfully submitted Date: July 21,2006 Melville Wal P.O. Box 108 Harrisburg, Pennsylvania 17108 (717) 232-0577 Attorney for plaintiff . ALPESH PATEL, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, : PENNSYLVANIA -v- : No. 2006 Defendant : CIVIL ACTION-LAW : IN DIVORCE NEHAL PATEL, VERIFICATION I, Alpesh Patel, hereby verify that the statements made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, I understand the false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~ 4904 relating to unsworn falsification to authorities. ~~^\1\ ~~~ i) l :i}. --.... ~ c ~ . , ,;;," f.". :? (,'17] 0) --, - - (:~, .' -, C.) ALPESB PATEL, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA . . -v- : No. 2006 - 04128 . . NEBAL PATEL, : CIVIL ACTION-LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Melville GM. Walwyn, hereby certify that a true and correct copy of the Complaint in Divorce in this matter was served upon the defendant Nehal Patel on July 24,2006, as is attested to by her Acceptance thereof on the said date. That Acceptance of Service is attached hereto. ~ Melville G.M. r--..:> (",~ <::~::J 0-" c) " :.:;l n', :JJ r- rr: \..1 ('-j .'j, ~ -"['1 ~~S{ :-l .J'> :-.0 -< It_J -~>... 0.) -~ -v- : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, : PENNSYL VANIA D(P-Lf/~8 : No. 2006 CV DV ALPESH PATEL, Plaintiff NEHAL PATEL, Defendant : CIVIL ACTION---LA W : IN DIVORCE ACCEPTANCE OF SERVICE I, Nehal Patel, hereby certify that on the ? 4- tL day of July, 2006, at approximately /,1. o"o'clock fl 1M, at 14 Fortuna Lane, Enola, Pennsylvania 17025, I received and accepted a copy of the Complaint in Divorce Witness my hand and seal this ~f~ay of July, 2006. N .~. Pck~ Nehal Patel o C ~':~ ,'f r--' C""':' = 0' -? ~ -0 ---:'"" ~ o -n --I -r ---. fl1r"': -nC:;-<1 ~;l~; ~ ...,.~ ~~ -.. '-:? ..S:- --l ~ ALPESH PATEL, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, : PENNSYLVANIA -v- : No. 2006-"I/~8 Defendant : CIVIL ACTION---LA W : IN DIVORCE NEHAL PATEL, PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on July 21,2006. 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 entry of a final Decree in Divorce without further notice. 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 decree is granted. 5. I understand that I will not be divorced until a Decree in Divorce 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: October 31, 2006 ~~ Alpesh Patel r--> Cd C:;O:> CJ'"' o .1 ::;:! nl :r.: ~O l:r4 ~~ ::J l.....',J .~:: (':1 .~.~ ~'!", -t- -r.~ ~~ f~:~ -~I """. ::0 -< oF.:,,~_ C' ..--..z::: -0 -.. ~-.:... r...^: -<- -.. ALPESH PATEL, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, : PENNSYLVANIA -v- : No. 2006-~'~8 Defendant : CIVIL ACTION---LA W : IN DIVORCE NEHAL PATEL, DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301 (e) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on July 21,2006. 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 entry of a final Decree in Divorce without further notice. 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 decree is granted. 5. I understand that I will not be divorced until a Decree in Divorce 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. Date: October 31, 2006 NJl FbJ~ N ehal Patel o ~;. I'..) C_~:l (:;:::) c:;r. -0 (..) .;:- -J o II ~ -'-- "'T1 01 r= ;T; ~j ("l -T; -;'1 ?'~. i::'fl ALPESH PATEl.. Plaiatiff : IN THE CUDRT OIT COMMON PLEAS :CUMBERLAND COUNTY., PENNSYLVANIA . . -v- : No.. 1006-04128 . . NEBALPATEL, :CIVlLACfION-LAW Defeadant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Protbonomry: Transmit the reco:rd, together with the following infonnation.. to the court for entry of a divorce decree:- 1. Grounds for divorce:- Irretrievable breakdown under Section (X) 3301 (c) () 3301 @ of the Divorce Code. (Check applicable section). 2. Date and manner of service of the Complaint:- 24* day of July, 2006 by Acceptance of Service by Defendant. 3. (Complete either paragraph (a) or (b). a) Date of execution of the plaintiffs affidavit of consent required by Section 3301 (c) of the Divorce Code: October 31,2006. b Xl) Date of execution of the plaint:ifPs affidavit required by section 330 1 (d) of the Divorce Code upon the defendant:- 4. Related claims pending:- None. 5, Date and manner of service of the Notice of Intention to file a Praecipe to Transmit Record, a copy of which is attached:- None. See attached Waiven dated October 31, 2006. Date:- October 31. 2006 ~~ Melville G. . Walwyn, # 18060 P.O. Box 1083 Harrisburg,PA 17108 (711) 232..0577 Attorney for Plaintiff o ~; ~ c;:;.:> cf" ~ ",~', ,,, L::~ ...:............ \ r'" o -n .-1 --(" ~, 1';"1..0 : C -n ~~_". <-J'~~i' .~) t-, ~_.:.: '":::::: I ;~,. -,': }~~ ~\ i~1 ::::: -:;:: -- ~ r:-? o -l '+' ,. '+' ,. '+' '+' + ,. +. Of. Of. Of. Of. Of. Of.Of.0f.0f.0f.0f.0f.0f. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. Of. 0f.0f.0f.0f. Of. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. No. 04128 2006 ALPESH PATEL VERSUS NEHAL PATEL DECREE IN DIVORCE AND NOW, November , , IT IS ORDERED AND 2006 DECREED THAT ALPESH PATEL , PLAINTIFF, AND NEHAL PATEL , 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; ATTES PROTHONOTARY Of. J. . h f. /'I""" ~ ?rJ. .$I . II ~(r r:?-PT""': ~./W 1)' ?/.)/ . ~. ~ ..