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Home My WebLink About06-5465 .. VI ~1v14- k.. JAN o.o~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. ~ " No. 06- .s l{(p,) CIVIL TERM rP A R1-o S ~. /kN DO 1rlJt-; Defendant 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, PAl 70 13 (717) 249-3166 . V'I-/vfA-- fG.~NOov1rf-; Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA / No. 06- S,/t.,!:-IVIL TERM " v. (! A{ljJ).J. i<. -&w /)0 ~U Defendant IN DIVORCE COMPLAINT UNDER ~3301(c) or Cd) OF THE DIVORCE CODE 1. Plaintiff is 1If/-wz,a C. &f?dot./() I , who currently resides at 3 { Natfw ~ ()r ~/IU)Ca P4 ( /70:; 7 Cumberland County, Pennsylvania. 2. Defendant is fIE r {Q sR.. c~t( c6vzr L. who currently resides at 31 Alof!Ul/~ Dr. -!:-twCa ~.,4 17tJ~5 3. 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 r /~5" / 9 ~ at cil1 4t(jv.d; ~! h((/t?ti~;r/ ~{'~IraIIl/UUl"ar' 5. The marriage is irretrievably broken, and the parties separated on \T~~ ~3 I ~oll5: - ' 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. .. 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 Diva ceo (/ 10/ tJ " Date! ' I, tIt-;~ {::. \ 1pt-1Jt;tI(;( f , 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. g4904. 1(/ s) IJ f.- Date: Plain' f, Pro Se Assisted y: Hannah Herman-Snyder, Esquire Griffie & Associates 200 N. Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5551 5;::, ~ -:u c_;' , /1 \.0 , ;, :-::1 I ~1 ~ W~UA- k;.J4AJOoI/40 Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA (!AR/~J' i(~ &AI~IJ Defendant ./ : NO. 06- 5 '{t, ~ CIVIL TERM : DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Vilma E. Sandoval , Plaintiff, to proceed in forma pauperis. I, Hannah Herman-Snyder, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. ~ "- ~.}n.It\1l" - ~lY\l~ Hannah Herman-Snyder, Esqui Attorney for Plaintiff 200 N. Hanover Street Carlisle,PA 17013 (717) 243-5551 ~'"'~) '....~~) , ~ VILMA E. SANDOVAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-5465 CIVIL TERM CARLOS R. SANDOVAL, Defendant : CIVIL ACTION LA W : IN DIVORCE AFFIDA VIT OF SERVICE AND NOW, on the ~day of 5~ f"t...{>t<\. hl.\ r , 2006 comes Hannah Herman-Snyder, Esquire, and states that she mailed a certified and true copy of a Complaint in Divorce and Notice to Defend and Claim Rights to the Defendant, Carlos R. Sandoval, at his address of 31 Nathan Drive, Enola, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on September 27, 2006. ~ (\. 1'-1'-.1\. \-..... ~ j~ It\. r, f'\ -~f(\~ ~J If\ Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this !) CJ ih- day of Serkm.6.1f1 ,2006 /"'f?t:b~ ~ ~~ NOTARYP$LIC NOTARIAL SEAL ROB'" J. GOSHORN, NOTARY PUBlIC CARLISLE BORO., CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 17 '1007 C) r.~ --;:. r-.:> (:';::J ~':'::~ C:i...... ....0 -r;; -.:.~ _,0;.... (:? C) U1 ,J' '-. l"- I"- 3' CJ IT! CJ I:() IT! u.s. Postal Service". CERTIFIED MAILM RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) CJ CJ CJ Return Receipt Fee CJ (Endorsement Required) CJ Restricted Delivery Fee I"- (Endorsement Required) LI1 ru Total Postage & Fees Certified Fee $ LI1 ~ ;;:;'iii'N../p..Sjl,~d."f>~.L......._.......... ~;~:;~4"J~.~_._h~~_'---7i;J~'--"-"-"'-' .. ~~1;~8nd3.Nio__ ..:t-tf ...~~18 de8IMcl. . PJfnt~ ,...... on..,..... 10" < '.,"'." , ,'~C8Idtoyou. . ~"~tQ."baCf(oIlhe~. Ol"ClI'I!thefrORttf -.permft:s. to: /I, sttntltJ,,1l .3, .".,""',. 't/tA.1l ])rfVe. En'/~. IA /11J;#5' C Agent Add! II II C. D* of DeIIYery . ~.- C ecp.._ . Altum ~ for MeftlheIldIlIe C II'IIII.IlIClMlll C c.o.o. 4. ResIrieted DelIvery? /Blh Fee) "Yes j 7005 2570 0000 3803 0477 -, .. . '~" PS Fonn ','" 1, I ;'. " . ~ .C_".!.' "', . ~... .... t. . t....':1 ...if. iii~'iil.! !' 1: i j i \;: t ~ \ ~ t \ ~___ __.l 1025l15-02.M-1540 (") C.~ =< .'" r--' (':':::"') c~:::;, t,.-.J'"'\ Pl (, ~1 -! :L-n fn= f-rl \....-:J I q -,:' , \..0 0.) o (..; ~ vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - IA W VILMA E. SANDOVAL, Plaintiff CARLOS R. SANDOVAL, Defendant : NO. 06-5465 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on September 19,2006 and served on September 27, 2006, as indicated in Affidavit of Service. 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 REIATING TO UNSWORN FALSIFICATION TO AUTHORmES. DATE: / /.:3 /b7 I I ! ~ ~., ~;, --'0 V;: Oi~i) ~~". 0.';~; r::;C L~. %\~"") .'571::: ~ ~ ~ ~ ~~ ~ ~\:? \ ~q\ cP ~:l1 .-0 ~~ "'$ ~ ~ ~ c.;. VILMA E. SANDOVAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERlAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW CARWS R. SANDOVAL, Defendant : NO. 06-5465 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301W OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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: 1 /IJ3/p7 I I I <2, ~ ';;', ""(~w. D.; ',f-' :t:- \., ~~. <-!J..~~:, r:' \..., <e:.:. ,., -v"t./ <...,.. c.' ~c ~ ~ ~ ~~ ~ ii, CSJ 6"8 ~ 5f'O ..;p '::::.\ --::: ~ ~ VILMA E. SANDOVAL, Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERlAND COUNTY, PENNSYLVANIA : CMLACTION-LAW CARLOS R. SANDOVAL, Defendant : NO. 06-5465 CML TERM : IN DIVORCE AFFIDAVIT OF CONSENT 2. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on September 19, 2006 and served on September 27, 2006, as indicated in Affidavit of Service. 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: I Wot a c: ~ \'J. c.rj n-lrn :;~, _:.'~ ~~;. <:::~ )"';:ot r- *,,:j:.\. ' 5~~ z :;:l .... ,..." c::::l c::::l -..l <- :Po :z:: o -n :i! rn" -or~ :0 o .-l-} '-r -r ~ f;;':- :!J ')0 5m :-"-\ '55 -< "" -0 :::i!: N U'l c..;) VILMA E. SANDOVAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CNIL ACTION - LAW CARWS R. SANDOVAL, Defendant : NO. 06-5465 CNIL TERM : IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301~ OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 RE TING TO UNSWORN FALSIFICATION TO AUTIlORmESL \ \ ~ - --J V- 0 --. DATE: \ ~ \ ' CARW R.S () s; ..,.., ,:s;~; rrl f~'::' ...?;. !~; liS, ~ ~ - \.0 ""t:1 :::1:: f>? <:.n <v ~ <:::::> .-., k .:oe: ~ 5! rn;::o r= ,'31 D1 cc'_1l:;:i ~r::) ~.3]j. ":--C'\ air'! 5;! :::0 ""'" VILMA E. SANDOVAL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-5465 CIVIL TERM CARLOS R. SANDOVAL, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under ~3301(c) 3301(d)(I) oftne Di'/oree Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on September 27, 2006. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code: by Plaintiff: 01/03/07 by Defendant: 01/16/07 (b) (1) Date of execution ofthe affidavit required by ~3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: January 8, 2007 Date defendant's Waiver of Notice In ~3301 (c) Divorce was filed with the Prothonotary: January 19, 2007 G)\n.... "".. h. "\l_bh "'~ "'- - .r-Jl'l'\lf'T\ Hannah Herman-Snyder, Esquir GRIFFIE & ASSOCIATES Attorney for Plaintiff (') C -o~ rT.~ f"' ~~. ;~J 1 {lJ;' . . %~ j;. ,....:; = = --J c.... > :it!: ~ --l ::t:-n nip -l'.liIl -be... ~~6 ~~ :13 '::~..; C~) 0.'0 '--I 55 :< \.0 -0 :J.: 1);' U1 W ".;'" ~ <Ii <Ii <Ii ;t; ff. <Ii <Ii ~ ~~ "'01;", ;!i<li ;!i t+i <Ii IN THE COURT OF COMMON PLEAS ;f. ;f. ;f. <f. '" <f. OFCUMBERLANDCOUNTY PENNA. STATE OF Vilma E. Sandoval, No. 06-5465 Plaintiff VERSUS Carlos R. Sandoval, Defendant !Ii !Ii !Ii 'f. 'f. ;f. 'f. !Ii !Ii !Ii 'I' !Ii 'I' 'I' 'I' 'I' 'I' 'f. 'f. 'I' 'I' <f. !Ii <f. !Ii '" '" '" <Ii '" 'f. <Ii t+i 'f. 'f. <Ii DECREE IN DIVORCE _ \~ 21. ~ ,IT IS ORDERED AND AND NOW, Vilma E. Sandoval , PLAINTIFF, DECREED THAT Carlos R. Sandoval , DEFENDANT, AND 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; None. J. By TH / PROTHONOTARY <Ii 'f.~~ !Ii fI' ~ !Ii!li if.!Ii if.!Ii if. if. !Ii 'f.'I''f. '1''1' ~~~ ~if. if. 'f. !Ii 'f. Of. t+i 'f. 'f. 'I' 'I' 'I' 'I' 'f. 'I' 'I' 'f. Of. 'I' 'I' 'I' 'I' 'I' '" 'I' _ h ~ ~ r?7)<!"Jl, L-O ~t' - / ~_ ~ fr rt-/fJ"'-11I MJ? -Jf{J uJ' /It' . / . ' .