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HomeMy WebLinkAbout06-4633STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, VS. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. U J't?P33 C?L 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 for relief requested in these papers by the Plaintiff. You may loose money or property or other rights important to you. 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 at the Cumberland County Court House, 1 Court House 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. LAWYER REFERRAL SERVICE 0 floor, Cumberland County Courthouse Carlisle, PA 17013 (717)-240-6200 Michael Acosta, Esquire Attorney for Plaintiff I.D. 90658 FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE 4'' floor, Cumberland County Courthouse Carlisle, PA 17013 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. YOU MUST ATTEND THE SCHEDULED CONFERENCE OR HEARING. BY THE COURT: DATE: J. STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, VS. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) or 3301 (d) OF THE DIVORCE CODE The Plaintiff is Stephanie Lyn Portanova, currently of 4822 East Trindle Rd. City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania 17050. 2. The Defendant is Dennis Nicholas Loxas, Currently of 730 Middle Lane. City of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on the 6s' day of May, 2002 in Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment of this marriage between parties. 6. For Purposes of § 3301 (d) of the Divorce Code, the parties have been living separate and apart since on or about May 23, 2006. The Marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff avers that this action is not collusive. COUNT I-MARRIAGE IRRETRIEVABLY BROKEN 10. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 11. The marriage of the parties is irretrievably broken. WHEREFORE. The Plaintiff respectfully requests the Court to enter and absolute decree of divorce pursuant to § 3301 (c) of the Divorce Code. r '?` Michael J I.D. 90658 Attorney for Plaintiff 208 Kings Highway South Cherry Hill, NJ 08034 Date: ?- w - a to VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. and su cubed before me day of ?? rK?Q1S? 20LU, r7,H WE TH OF PE OTARIAL S7AL M. DEDER, il Born, Cission Expires c 177fr V? P G7 AM SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04633 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PORTANOVA STEPHANIE VS LOXAS DENNIS the within named DEFENDANT LOXAS DENNIS 730 MIDDLE LANE NOT FOUND , as to CAMP HILL, PA 17011 PER BROTHER, DENNIS IS CURRENTLY LIVING IN AUSTRALIA. Sheriff ' s Costs: So answers- Docketing =? 18.00 r Service 13.20 Not Found 5.00 R. Thom ine Surcharge 10.00 Sheriff of Cumberland County Postage .39 46.59 STEPHANIE PORTANOVA (111;1-, `©` 08/17/2006 Sworn and. Subscribed to before me this _ day of , R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT LOXAS DENNIS but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - DIVORCE , A. D. STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW No. 1?xs- `{ 3 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 for relief requested in these papers by the Plaintiff. You may loose money or property or other rights important to you. 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 at the Cumberland County Court House, I Court House 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. LAWYER REFERRAL SERVICE 4"' floor, Cumberland County Courthouse Carlisle, PA 17013 (717)-240-6200 FAuE COPY FROM RECORD Tes* 1 W WW W, I hats IMt 9d Illy haltta -Ad on ad a SW Cowl Michael Acosta, Esquire Attorney for Plaintiff I.D. 90658 FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE 41h floor, Cumberland County Courthouse Carlisle, PA 17013 AMERICANS WITH DISABILITIES ACT OF 1990 "The Court of Common Pleas of Cumberland County is required by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. YOU MUST ATTEND THE SCHEDULED CONFERENCE OR HEARING. BY THE COURT: DATE: J. STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) or 3301 (d) OF THE DIVORCE CODE 1. The Plaintiff is Stephanie Lyn Portanova, currently of 4822 East Trindle Rd. City of Mechanicsburg, County of Cumberland, Commonwealth of Pennsylvania 17050. 2. The Defendant is Dennis Nicholas Loxas, Currently of 730 Middle Lane. City of Camp Hill, County of Cumberland, Commonwealth of Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on the 6th day of May, 2002 in Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or annulment of this marriage between parties. 6. For Purposes of § 3301 (d) of the Divorce Code, the parties have been living separate and apart since on or about May 23, 2006. 7. The Marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff avers that this action is not collusive. COUNT I-MARRIAGE IRRETRIEVABLY BROKEN 10. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 11. The marriage of the parties is irretrievably broken. WHEREFORE. The Plaintiff respectfully requests the Court to enter and absolute decree of divorce pursuant to § 3301 (c) of the Divorce Code. Michael J costa, I.D. 90658 Attorney for Plaintiff 208 Kings Highway South Cherry Hill, NJ 08034 -- w - U f-P Date: VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.'S. § 4904, relating to unsworn falsification to authorities. Sworn to and su cribed before me this ay of , 20C:Q. N COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumberland County My Commission Expires AuR. 20, 2009 r _:?= ,A?", ,f, ,- ?_ i? f 't.. ?_ _? ? , . 1 , ? Ali v I Curtis R. Long Prothonotary Office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Ol - 141 3 3 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573