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DECREE IN
DIVORCE
AND NOW"...V9:-:~,. ,!.~...., 19.~?-::', it is ordered and
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decreed that.. ... .JAi.me. ,Guad.a.l.up-e, ... ,... . .... .......... ... ..., plaintiff,
and...,. ,l-f1Ill\.~..~"'l\dl\l...PI'.,...........".,......,.........., 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;
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY . PENNSYLVANIA
NO. 1109 Civil 1994
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following infonnation, to the Court for entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301 (d) (1) of the
Divorce Code.
2. Date and manner of service of the Complaint: The Complaint was served by
personal service on March 30, 1995.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301 (c)of the
Divorce Code: by Plaintiff
; by Defendant
(b) (1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of
the Divorce Code: February 23, 1994; (2) date of service of the Plaintiffs affidavit upon the
Defendant: April 7, 1995, Defendant's Counter-Affidavit was executed on April 7, 1995 and served
upon Plaintiff on April 10, 1995,
4. Related claim pending: None
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Attorney for Plaintiff
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMB~D COUNTY, PENNSYLVANIA
NO. /lOq"", 1994
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, Cumberland County Courthouse, 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 lHIS 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.
Court Administrator
Cumberland County Court House
4th Floor
I Court House Square
Carlisle, PA 17013
717 240-6200
..
JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PBNNSYLV ANIA
NO. S 1994
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTIDN not/d) OF THE DIVORCE CODE
1. The Plaintiff is Jaime Guadalupe, who currently resides at P.O. Box 72.
Mechanicsburg, Cumberland County, PA 17055, since February of 1993.
2. The Defendant is Inna L. Guadalupe, who currently resides at 16 John Street,
Apartment 4, Amsterdam, New York, since at least June of 1993.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4, The Plaintiff and Defendant were married on December 28, 1982, at Caguas,
Puerto Rico.
5. The Plaintiff avers as the grounds on which the action is based that the
marriage is irretrievably broken and that the parties have lived separntely from each other for
a period of at least two years as provided under Section 3301(d) of the Divorce Code, having
separated on December 21, 1986,
6. There has been one prior action of divorce or for annulment between the
parties filed to No. 4921 S 1987 in Dauphin County, Pennsylvania, which action was tenninated
for inactivity.
7. The 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.
8. The Plaintiff requests the court to enter a decree of divorce.
9. The Defendant is not a member of the anned forces of the United States or
any of its allies,
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WHEREFORE. Plaintiff demands judgment:
A. Dissolving the marriage between the !WO parties:}
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Ro rt G. Ra e ac
Attorney for Plaintiff
105 North Front Street
Harrisburg, PA 17101
(717) 234-5600
.
JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. S 1994
IN DIVORCE
DEFENDANT'S COUNTER-AFFIDAVIT
UNDER SECTION 33011d) OF TIlE DIVORCE CODE
1.
Check either (a) or (b):
(a) I do not oppose the entry of a divorce decrce.
(b) I oppose the entry of a divorce decree because.
(Check (i), (ii) or both):
(i) The parties 10 this action have not lived separate and apart
for a period of at least three years,
The marriage is not irretrievably broken,
(ii)
Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. I understand that
I may lose rights concernmg alimony, division of property, lawyer's fees
or expenses if I do not claim them before a divorce IS granted.
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
2.
I verify that the statements made in this counter-affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 19 Pa.C.S, ~ 4904
relating to unsworn falsifications to authorities.
Date:
Inna L. Guadalupe
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you need not file this counter-affidavit.
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMB~ COUNTY, PENNSYLVANIA
NO. 1/t>7f1J4I994
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file
a Counteraffidavlt within 20 days after the Affidavit has been served on you or the statements
will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 330Hd)
OF THE DIVORCE CODE
1. The parties to this action separated on December 21, 1986, and have continued
to live separate and apart for a period of at least two years,
2. The marriage is irretrievably broken,
3. I understand that I may lose rights concerning alimony, division of property,
lawyers fees or expenses if I do not claim before a divorce is granted.
I verify that the statements made in this Affidavit are tme and correct. I
understand that false statements herein a~,ntiiOe's).lbject to the penalties of 18 Pa.C.S. fi4904
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relating to unsworn falsification to Aut orities. .
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JAIME GUADALUPE,
Plaintiff
VS,
IRMA L. GUADALUPE,
Defendant
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
NO. 1109 Civil 1994
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 11th day of March, 1994, I, ROBERT G. RADEBACH,
ESQUIRE, of the Law Finn of ETZWEILER & RADEBACH, Attorneys for Jaime Guadalupe,
Plaintiff, hereby certify that I selVed a copy of the Complaint in Divorce, Defendant's Counter-
Affidavit and Plaintiff's Affidavit in the above-captioned matter upon Inna L. Guadalupe, of
16 John Street, Apartment 4, Amsterdam, NY, this 11th day of
same in the United States Mail, postage prepaid, via Certi
in the post office at Harrisburg, Pennsylvania,
By:
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Earl Richard EtzWeller
Roben G. Radebach
Roben J. Kreidler
ETZWEILER AND RADEBACH
ATIORNEYS-AT-LAW
105 N, FRONT STREET
HARRISBURG, PENNSYLVANIA 17101
(717) 234-5600
HAUFAX UNE
(717) 896.3737
FAX UNE: (717) 234-5610
2 Wcst Main 51=1
Elizabethville, P A \7023
(717) 362.8395
225 Markel 51reel
Mlllersburg, PA \7061
(7\7) 692-2519
March 11, 1994
Mrs, Irma L. Guadalupe
16 John Street
Apartment 4
Amsterdam, NY 12010
RE: Guadalupe v. Guadalupe Divorce
Dear Mrs. Guadalupe:
Please find enclosed the Complaint in Divorce, Defendant's Counter-Affidavit
and Plaintiffs Affidavit regarding the above-captioned matter,
Very truly yours,
Robert G. Radebach
RGR:db
Enc,
Via Certified Mail
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1109 Civil 1994
IN DIVORCE
PRAECIPE TO REINSTATE
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L, GUADALUPE,
Defendant
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLANDCOUNTY,PENNSYLVANIA
: NO. 1109 Civil 1994
IN DIVORCE
PRAECIPE TO REINSTATE
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in Divorce in the action above-captioned.
Dated: ~J~ Ifq Y
Ro It G. e ac
Attorney for Plaintiff
105 North Front Street
Harrisburg, PA 17101
(717) 234-5600
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1109 Civil 1994
IN DIVORCE
PRAECIPE TO REINSTATE
TO TIlE PROTHONOTARY:
Kindly reinstate the Complaint in Divorce in tl
Dated: (0 - d(j- (0
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
: IN TIlE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1109 Civil 1994
IN DIVORCE
AFFIDAVIT OF NON.MILITARY SERVICE
JAIME GUADALUPE, being duly sworn according to law, deposes and says
that:
1. He is the Plaintiff in the above captioned divorce action;
2. That the Defendant is 38 years of age;
3. That she lives at Holland Gardens, Apartment #R-8, Amsterdam, New York
12010;
4. Defendant's employment is unknown;
S. That Defendant is not in the military or naval services of the United States
or its allies, or is otherwise within the provisio of the Soldiers and Sailors Civil Relief Act
of Congress of 1940 and its amendments.
Sworn and subscribed
before meJ.his .k;t
day of e?u.ut.7' 1995.
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1109 Civil 1994
IN DIVORCE
.
.
PRAECIPE TO REINSTATE
TO TIlE PROTHONOTARY:
Kindly reinstate the Complaint in Divorce in the action above-captioned.
Dated: March 21, 1995
Raben G. Radebac
Attorney for Plaintiff
105 North Front Street
Harrisburg, PA 17101
(717) 234-5600
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JAIME GUADALUPE,
Plaintiff
VSo
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V AJ.'ITA
NO. S 1994 ~ (,(67' - (l e 'v~
IN DIVORCE
pEm'1DA..~"'s COUN'I'ER-AFFIDA VIT
JJNDEIfsEcno'N 3301Cdl OF TR"F, DIVORCE CODE
Ch)(' either (a) or (b):
(a) I do not oppose the entry of a divorce decree,
(b) I oppose the entry of a divorce decree because,
(Check (i), (ll) or both):
(i) The parties to this a.don have not lived separate and apart
fer ;0, oeriod ,)f at least three '/ea."S.
(ll) The marriage is not irretrievably broken.
ChXk either (a) or (b):
(a) I do not wish to make any claims for economic relief, I understand that
I may lose rights concenuog alimony, division of property, lawyer's fees
or expenses if I do not claim them before a divorce IS grantedo
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other imponaot rights.
I verify that the statements made in this counter-affidavit are trUe and correcto I
understand that false statements herein are made subject to the penalties of 19 Pa.CoS. ~ 4904
relating to unsworn falsifications to authorities.
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NOTICE:, If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any,'claim for economic relief, you need not file this counter-affidavit.
1.
2.
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JAIME GUADALUPE,
Plaintiff
VS.
IRMA L. GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 1109 Civil 1994
IN DIVORCE
CERTIFICATE OF SERVICE
I, KEVIN S, BLANTON, of the Law Finn of ETZWBILER & RADEBACH,
Attorneys for Jaime Guadalupe, Plaintiff, hereby certify that I forwarded a true and correct
copy of the Complaint in Divorce and the Plaintiffs Section 3301 (d) Affidavit to the Sheriff
of Montgomery County, New York, for personal service upon the Defendant, Irma L,
Guadalupe. A copy of the Sheriffs Return is annexed hereto indicating service was completed
March 30, 1995, and April 7, 1995 respectfully,
Dated: April 12, 1995
Respectfully submiued,
BTZWBILER & RADEBACH
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\ Kevin S, Blanton
105 North Front Street
Harrisburg, PA 17101
(717) 234-5600
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STATE OF PE~NsvlVANIA
COURT
COURT OF COMMON ClAIMS
COUNTY OF CUMBERLAND
JAIME GUADALUPE
AFFIDAVIT OF
SERVICE
VS
IRMA Lo GUAOALUPE
Action For A Divorce
STATE OF HEN YORK )
COUN'l'Y OF MONTGOMERY)
55. :
Chief Deoutv Cvnthia Cline Smith , being duly sworn deposes and says:
that deponent is over the age of 18 years and is not a party to this
proceeding. Deponent served the within notice to defend & complaint
in the above-entitled proceeding, such service having been made in the
following manner, stated herein, and said person being the proper and
authorized person to be served in this proceeding.
Name.
Address.
Date:
Time:
Place.
Irma L. Guadalupe
Holland Gardens R-B Amsterdam, NY 12010
March 30, 1995
3:30 PM
MontQomerv County Sheriff's Office, Park Sto Fonda. NY 12068
10 by delivering to and leaving with personally,Jrma L Guadalupe(now using Vas,quez)
known to the deponent to be the same person mentioned and described in
the above proceeding as the person to be served.
2. by delivering to and leaving with personally
at the premises mentioned above, such person knowing the person to be
served and associated with him, and after conversing with him, deponent
believes him to be a person of suitable age and discretion, and by mailing
a copy of the proceeding herein to the person named above, to the address
and at the time stated above which is his last known address, enclosed in a
post paid sealed wrapper in an official depository of the United States
Postal Service.
30 by delivering to and leaving with
agent for service on the person in this proceeding as designated
31B CPLRo Service having been made to such person at the place,
date stated above.
, the
under Rule
time and
4. by affixing a true copy of the same to the door of the actual place of
business, dwelling place or usual place of abode stated above and by
mailing a copy of the proeeeding herein to said person to the address and
on the date and time stated above.
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Service was made in the manner stated in this paragraph (4) because
deponent was unable, with due diligence to find the proper or authorized
person to be served or a person of suitable age and description at actual
place of business, dwelling place or usual place of abode stated above,
having called there at the following times and datesl
50 by delivering to and leaving with the person named above at said
address, upon information and belief the person served is an officer of the
corporation, , named in this proceeding
authorized to be served hereino
Deponent further states upon information and belief that said person so
served is not in the Military service of the State of New York Or the
united States as the term iA defined in either the State or Federal Statuteso
Deponent further states that he described the person actually served as
followsl
SEX
Hale
..1. Female
SKIN COLOR
Black
X White
IIAIR COLOR
Light
Hedium
X Dark
AGE(approx)
37
HEIGHT
DEIGRT
5'
110
OTHER IDENTIFYING FEATURES:
. , .
Sworn to before me, this 31st
day of March . 1995
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
JAIME GUADALUPE,
Plaintiff,
APFI:DAVI:T OF
SERVI:CE
VS
IRMA Lo GUADALUPE,
Defendant.
ACTION FOR A DIVORCE
STATE OF NEW YORK )
COUNTY OF MONTGOMERY) 55.:
Deputy Gordon Faltermeier
, being duly sworn deposes and says:
that deponent is over the age of 18 J'ol~g: t~nft,eilfleP.?n'aa~t'pp~~r~tlll?,,~haWidavit
proceeding. Deponent served the within and defendant's counter affidavit
in the above-entitled proceeding, such service navlng ~een maae In tne
following manner, stated herein, and said person being the proper and
authorized person to be served in this proceeding:
Name:
Address:
Date:
Time:
Place:
Irma L 0 Guada I.upe
Holland Gardens. R-8 Amsteraam, NY12010
Apri 1 7 100<;
10:3n AM
Hol1~nd Gardens R-8 Amsterdam. NY
1. by delivering to and leaving with personally, Irma oL. Guadalupe/now Vasquez,
known to the deponent to be the same person mentioned and described in
the above proceeding as the person to be served.
2. by delivering to and leaving with personally
at the premises mentioned above, such person knowing the person to be
served and associated with him, and after conversing with him, deponent
believes him to be a person of suitable age and discretion, and by mailing
a copy of the proceeding herein to the person named above, to the address
and at the time stated above which is his last known address, enclosed in a
post paid sealed wrapper in an official depository of the United States
Postal Service.
30 by delivering to and leaving with
agent for service on the person in this proceeding as designated
318 CPLR. Service having been made to such person at the place,
date stated above.
, the
under Rule
time and
40 by affixing a true copy of the same to the door of the actual place of
business, dwelling place or usual place of abode stated above and by
mailing a copy of the proceeding herein to said person to the address and
on the date and time stated aboveo
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Service was made in the manner stated in this paragraph (4) because
deponent was unable, with due diligence to find the proper or authorized
person to be served or a person of suitable age and description at actual
place of business, dwelling place or usual place of abode stated above,
having called there at the following times and dates:
50 by delivering to and leaving with the person named above at said
address, upon information and belief the person served is an officer of the
corporation, ' named 'in this proceeding
authorized to be served hereino
Deponent further states upon information and belief that said person so
served is not in the Military service of the State of New York or the
united States as the term is defined in either the State or Federal Statutes.
Deponent further states that he described the person.actuallY served as
follows:
SEX SKIN COLOR IIAIR COLOR AGE(approx) BEIGIIT HEIGIIT
Hale Black _ Lj.ght
X Female X White HediUII 4R C;, 11 Ii
Dark
X Red
OTHER IDENTIFYING FEATURES:
,
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Sworn to before me, this 7th
day of April , 1995
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CVNTHIA CUN5 SIoIITI4
Notary Pubnc lor Naw York ~
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(print name beneath Signature)
Gordon Faltermeier -
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JAIME GUADALUPE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: NO. 1109 Civil 1994
IN DIVORCE
VS.
IRMA L. GUADALUPE,
Defendant
.
.
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
TO: Irma L. Guadalupe
(DEFENDANT)
YOU HAVE BEEN SUED IN AN ACTION FOR DIVORCE, You have failed to
answer the complaint, but have filed a counteraffidavit to the plaintiffs affidavit.
Therefore, on or after oc:r,.L. ,1925, the plaintiff can request the court to enter a final
decree in divorce,
If you do not file with the prothonotary, of the court an answer with your signature
notarized or verified, or a counteraffidavit by the above date, the court can enter a final
decree in divorce, Unless you have already filed with the court a written claim for
econornic relief, you must do so by the above date or the court may grant the divorce and
you will lose forever the right to ask for economic relief, A COUNTER-AFFIDAVIT
WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS
ATTACHED TO THIS NOTICE,
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,
Court Administrator
Cumberland County Court House
Fourth Floor
1 Court House Square
Carlisle, PA 17013
(717) 240-6200
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JAIME GUADALUPE,
Plaintiff
VS,
IRMA L, GUADALUPE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
NO, S 1994
IN DIVORCE
DEFENDANT'S COlJNTER.AFFIDA VIT
UNDER SECTION 330Hd\ OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because,
(Check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart
for a period of at least three years,
(ii) The marriage is not irretrievably broken,
2, Check either (a) or (b):
(a) I do not wish to make any claims for economic relief, 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,
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights,
I verify that the statements made in this counter-affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 19 Pa,C,S, ~ 4904 relating to
unsworn falsifications to authorities,
Date:
Irma L, Guadalupe
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to
make any claim for economic relief, you need not file this counter-affidavit,
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