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HomeMy WebLinkAbout06-7110I,/ STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, VS. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :No. 0(0 _ 2 11 : 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`h floor, Cumberland County Courthouse Carlisle, PA 17013 (717)-240-6200 FIND OUT WHERE YOU CAN GET LEGAL HELP LAWYER REFERRAL SERVICE 4`h 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. 0 6 - 7110 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 6t' 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 Acosta, LD 90658 Attorney or Plainti 208 Kings South Cherry Hill, NJ 08034 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 author' .iek. r" Plailfti Sworn to and subscribed before me this, day of/???'?? 200 otary ublr UOMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JAMES E. GREEN, Notary Public Camp Hill Boro, Cumberland County My rommission Expires June 6, 2009 `- a., ? z ?y co, n r i 3't ono b ? ?, ?, /w E5 ?i s s, ms Demetrios H. Tsarouhis, Esquire Attorney for Plaintiffs/Petitioners 347 New Street-Suite 115 Quakertown, Pa 18951 Attorney ID#88513 (610) 538-9600 Stephanie Lyn Portanova, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Dennis Loxas, Defendant : No. 06-7110 DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE CLERK OF SAID COURT: Enter our appearance on behalf of Dennis Loxas. Papers may be served at the addresses set forth above. DEMETRIOS H. TSAROUHIS Attorney for Defendant 347 New Street-Suite 115 Quakertown, Pa 18951 Attorney ID #88513 (610) 538-9600 0 ??, ? ?=F,= ? .?-?. -f;? ?? ? ?? 3 ? ? ?? ? ? V Demetrios H. Tsarouhis, Esquire Attorney for Plaintiffs/Petitioners 347 New Street-Suite 115 Quakertown, Pa 18951 Attorney ID#88513 (610) 538-9600 Stephanie Lyn Portanova, Plaintiff V. Dennis Loxas, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW No. 06-7110 DIVORCE ANSWER TO COMPLAINT IN DIVORCE 1. Paragraphs 1-11 of this Complaint are Admitted. WHEREFORE, Defendant respectfully requests that this Honorable Court enter an absolute decree of divorce pursuant to Sec. 3301(c) of the Divorce Code. Date: Demetrios H. Tsarouhis Attorney for Defendant VERIFICATION I, Dennis Loxas, hereby verify that the statements contained in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904 relating to unworn falsification to authorities. I ?iyt?M ` Dennis Loxas Date: ) - g C) rt r_l rn Fn ` W 45 C SHERIFF'S RETURN - REGULAR CASE NO: 2006-07110 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTANOVA STEPHANIE VS LOXAS DENNIS DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon LOXAS DENNIS DEFENDANT the , at 1216:00 HOURS, on the 2nd day of January , 2007 at 730 MIDDLE LANE CAMP HILL, PA 17011 DENNIS LOXAS by handing to a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Postage Surcharge ill f[6 -7 So Answers: 18.00 13.20 .39 10.00 R. Thomas Kline .00 ? 41.59 01/03/2007 STEPHANIE PORTANOVA Sworn and Subscibed to before me this of By: day Deputy Sheriff A.D. STEPHANIE PORTANOVA, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. Or t{ -7110 DENNIS LOXAS, Defendant : DIVORCE AFFADAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on December 14, 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 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 of 18 Pa.C.S § 4904 relating to unsworn falsification to authorities. Date: !.k1 tv Date: ©? ? ? ? . .?____ ? t^.- Vi"a"-` G t -? ?' ,? ...- ,,,,.. ".?. f ., _ ?, ? ' - ? ; ` ? ?"" ?? STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW No. 06-7110 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) AND § (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 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 unswom falsification to authorities. Date: ? a ot r Date: ? a efendant " ? C 'k ? C --' ?? r ,?_ r ..-- ; ?? t Jt , s ? ::` t 1;?; , ?. . r '...-d --r STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, VS. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : No. 06-7110 : 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 § 3301 (c) of the Divorce Code. 2. The Complaint was served by the Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania on January 2°d° 2007. 3. The date of execution of the affidavit of consent required by § 3301(c) of the Divorce code by plaintiff was on May 21, 2007; by defendant on June 6, 2007. 4. There are no claims pending. 5. Date and manner of service of the notice of intention to file praecipe, a copy of which is attached, was on served on May 240', 2007 through certified mail and signed by plaintiff on May 21St, 2007; defendant on June 4d', 2007. Michael J. sta ?j Attorney for Plaintiff d _'' ?' -a jr+ r; ?... --y ' : xx '- C r - '` t: °?'jc°r't `?, • • G `1 ^! STEPHANIE PORTANOVA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DENNIS LOXAS : NO. 2006 - 7110 CIVIL TERM ORDER OF COURT AND NOW, this 18TH day of JULY, 2007, it appearing that the Affidavits of Consent were not filed within 30 days of being executed as required by Pa. R.C.P. 1920.42 (b) (2), the request for the entry of a final divorce decree is DENIED without prejudice. Edward E. Guido, J. (cichael J. Acosta, Esquire " 0 208 Kings Highway South Cherry Hill, N.J. 08034 e' a os H. Tsarouhis, Esquire 347 New Street - Suite 115 Quakertown, Pa. 18951 /ephanie Portanova ,.Dennis Loxas sld MVi w . '' 3Hi ECG STEPHANIE PORTANOVA, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. No. 06-7110 DENNIS LOXAS, Defendant : DIVORCE AFFADAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on December 14, 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 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 of 18 Pa.C.S § 4904 relating to unsworn falsification to authorities. Date: or-) laintiff Date: 9-A 1 - 02 Defendant Z7 -•r.t STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, VS. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : No. 06-7110 : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) AND § (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 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: - a Date: S. a 1 - b 7 CNc-. De en ant c_' G". PO N L C"x STEPHANIE PORTANOVA, Plaintiff DENNIS LOXAS, VS. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : No. 06-7110 DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: decree: I. 2. 3. 4. Transmit the record, together with the following information, to the court for entry of a divorce Ground for divorce: irretrievable breakdown under § 3301 (c) of the Divorce Code. The Complaint was served by the Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania on January 2°d° 2007. The date of execution of the affidavit of consent required by § 3301(c) of the Divorce code by plaintiff was on May 21, 2007; by defendant on June 6, 2007. There are no claims pending. Date and manner of service of the notice of intention to file praecipe, a copy of which is attached, was on served on May 24 h, 2007 through certified mail and signed by plaintiff on May 21St, 2007; defendant^ June 4", 2007. T.;: , < c; ? ? . F ?;,? i`:' . . :Y??p ? t` 1:? '"`" yl ? t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Sch Pb?xx?nw VERSUS lkkazn?- =6 N O. _ \\fl DECREE IN DIVORCE ,:r/2opoA,l AND NOW, IT IS ORDERED AND DECREED THAT PLAINTIFF, AND lC\?? ??1LAC ? 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; ATTEST: J PROTHONOTARY V ;, r4 Y } v# S ? x ? i KA