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HomeMy WebLinkAbout06-5996ALICIA A. LOPEZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2006- J_q q6 CIVIL TERM RYAN A. LOPEZ, CIVIL ACTION-LAW 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 the 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 ALICIA A. LOPEZ, Plaintiff V. RYAN A. LOPEZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006- ?9 g4 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Alicia A. Lopez, an adult individual who currently resides at 308 Tichy Drive, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. Defendant is Ryan A. Lopez, an adult individual who currently resides at 2 Fetrow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and the Defendant have been bonafide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 2, 2000, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 6. Plaintiff and Defendant are not in the Armed Forces of the United States. 7. Plaintiff avers that the marriage between the parties is irretrievably broken. 8. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. Respectfully submitted, O'BRIEN, BARIC & SCHERER OkRk Michael A. Scherer, Esquire I. D. # 69174 19 West South Street Date: /° "1 t' ?lO Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/lopez/divorce.pid VERIFICATION I verify that the statements made in the foregoing Complaint 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. AAlic?iak Lopez Date: 0 c2M (1 cn CX) ALICIA A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006- CIVIL TERM RYAN A. LOPEZ, CIVIL ACTION-LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE s? AND NOW, on this the 3l S day of October, 2006, I, Ryan A. Lopez, Defendant, hereby accept service of the Divorce Complaint in the above-captioned action and acknowledge receipt of a true and attested copy of said Complaint. Ryan A. Lopez -- T L I n - Fil ALICIA A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-5996 CIVIL TERM RYAN A. LOPEZ, CIVIL ACTION-LAW Defendant IN DIVORCE 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 October 13, 2006. 2. Defendant signed an acceptance of service form on October 31, 2006. 3. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 4. 1 consent to the entry of a final decree in divorce without notice. 5. 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. 6. 1 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. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. 1 do not request that the Court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: February 2007 '%R ca A. Lopez rv ? 73 -*a ta r- M4 -C C.?1 ALICIA A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-5996 CIVIL TERM RYAN A. LOPEZ, CIVIL ACTION-LAW Defendant IN DIVORCE DEFENDANT'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 October 13, 2006. 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 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. 5. 1 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. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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.A. Section 4904 relating to unsworn falsification to authorities. ! r l Date. 1 1 0 ?L I Ryan A. Lopez r ? 1 CIA ?U t- t r ALICIA A. LOPEZ, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006-5996 CIVIL TERM RYAN A. LOPEZ, CIVIL ACTION-LAW 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 divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the divorce code. 2. Date and manner of service of the complaint: Defendant signed an Acceptance Of Service form on October 31, 2006. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 3301(c) of the divorce code: by the plaintiff: February 12, 2007 the defendant October 15, 2007 (b) (1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the divorce code n/a (2) Date of service of the plaintiffs affidavit upon the defendant n/a 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 plaintiff's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: February 23, 2007 Date defendant's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: October 22, 2007 4,;? A ' Mi h e A. Scherer, Esquire Attorney For Plaintiff r-? ?} ?;? ? ? ? W -?; C,' ,,. --I t ? = ?? ? .,. -r 6, 7 - . .?C? ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ALICIA A. LOPEZ, Plaintiff VERSUS RYAN A. LOPEZ, Defendant N O. 2006-5996 CIVIL DECREE IN DIVORCE ?' / n : S'a?4 •M AND NOW, IT IS ORDERED AND DECREED THAT AND RYAN A. LOPEZ 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; NONE. ALICIA A. LOPEZ 7C L 0