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HomeMy WebLinkAbout94-02341 . . : . ~ . . . . . .. .. . . . I . ~ . . I . . . i . . 8 , '. I!I . . J. 8 * , .... -.. - .. -- .. .. . .. ,...'.;,... ... c. '... . ... ..~ ~-~~-~~~-~~-~-----~~~~~-~---~ . ~ . c. . . . . . . . .. .,.... ,.... . . . . I . . I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '*' PENNA. ROMAN SALAMACA, Plaintiff " II 94-2341 civil Term 'I No.......,......", ............,.." 19 II II II VerSIIS Susan Salamaca, "... .... Defendant DECREE IN DIVORCE A r. J. f 'f AND NOW, .. .. .. ../....~ .~.. .. .. .. ... 19....... It I. ordered and decreed that ......... ~9W\~ . !3^~~.~l}. . . . . . . . . . . . . . . . . . . . . . " plaintiff, SUSAN SALAMACA and . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. defendant, are divorced from the bond. of matrimony. The court retain. jurl.dlctlon of the following claim. which have been ral.ed of record In thl. action for which a final order ha. not yet been enteredi NO RELATED CLAIMS PENDING. .. .............. ,.,. " ............ ........ ,.,. ..... ..... .... ........ ""'" ............ II.. .0'.'. ".,.. .......... .... I", .... ...... .... ..... '" ....... ::'i~:~~ ~L<s'>'_4+ '. /'~./- ,c L/ : ./~ ~. .':f'h.i l fj~;:;~ "Prolh~nol.ry ROMAN SALAMACA, ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA ) v. ) NO. 94 - 2341 CIVIL TERM ) SUSAN SALAMACA, ) 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 IXI section 33011cl I I section 33011dl of the Divorce Code. (Check applicable section). 2. Date and manner of service of the complaint: Bv service ucon counsel for Defendant. James A. Miller. ESQuire. as evidenoed bv that certain Accectance of service filed of record herein. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit required by Section 3301(c) of the Divorce Code: AUQust 15. 1994 I by defendant, AUQust 5. 1994. (b) (1) Date of execution of plaintiff'S required by Section 3301(d) of the Divorce Code: (2) date of service of plaintiff's affidavit upon of consent by plaintiff, affidavit I defendant: Datel q!~)A 'I pending: NO CLAIMS PENDING. J[i @l J. C (C...~ .tOh . Howett, Jr.. quire HOWETT, KISSINGER & MILES, P.C. 130 Walnut Street P. o. Box 810 Harrisburg, PA 17108 Telephone: 717/234-2616 Counsel for Plaintiff 4. Related claims '" ." p; ,. .. .r.; :n ., ~ , ., n_ " , , g ,. N ...... , "., .... .. .. ,. i:C . I' \ i~I":'l 'I -l 'I '0 1'\, ........ ....... .~, .~ J;; ~ _~A \0 ." -p-r; -' ~ ~-j,... ~\ ) ~,---' i i i i ~~ ~ .) ~f!~ J ~ . I l> I I ! ! ~.--~-- -" ._-- t', '-.l l...--J -.. t'-... "I v>.$ '"1< It- o '" 4- '~ ~ ~ ".~ \.() 1\, '\1 .... "- . VI . ". ... '.. 11111\'1-:1'1', 1\I!;HINIIIW /\, :\111.1';0;. I'.C'. ." ~ ~ !'J ~ .- ::il ~ t- Q r. \) Qjj ~ ;; ~ e~~2g 5~~i~ jl;~~ '~ J ~ o = ., ROMAN SALAMACA, ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND4COUNTY, PENNSYLVANIA ) q/I' .)3 d v. ) NO. IVIL I f'r III ) SUSAN SALAMACA, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE NOTICE TO DEFEND AND CLAIM RIG~ 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 counselling. A list of marriage counsellors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pa. 17013 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 Cumberland County Courthouse Court Administrator, 4th Floor 1 Courthouse Square Carlisle, PA 17013 Telephonel (717) 240-6200 4\ ROMAN SALAMACA, ) IN THE COURT OF COMMON PLEAS OF plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA ) v. ) NO. CIVIL 1994 ) SUSAN SALAMACA, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE COMPLAINT IN DIVORCE Plaintiff Roman salamaca, by and through his counsel, Howett, Kissinger, and Miles, P.c., hereby files this Complaint in Divorce and in support thereof avers the following: 1. plaintiff is Roman Salamaca, an adult individual who currently resides at 252 Deerfield Road, Camp Hill, cumberland county, Pennsylvania, 17011. 2. Defendant is Susan salamaca, an adult individual who currently resides at 1435 Hillcrest court, Apartment 103, caap Hill, Cumberland county, Pennsylvania, 17011. 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 April 21, 1979, in Cumberland County PennSYlvania. 5. There have been no prior actions for divorce or for annulment of the marriage between the parties instituted by either of them in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant i8 in the military or naval service of the united States or its allies within the VERIFICATION I, Roman Salamaca, hereby swear and affirm that the facts contained in the foregoing complaint in Divorce are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. 14904 relating to unsworn falsification to authorities. Date: /;'rA' 11 I ~ /J~-- R n Sal!amada -::r ~ ~,~~ -- -:',. ti: ;'.~ j _ I -,: In c.> ,..., :-: .' " . -' . ~ :0-,.. "~I ,. "..., - -, ::= u ~ ili ~ ., Q ~ ;;: i ~ .. ~ I ~~ ~ J . ~~~;~ . ~ i~~~j ~ ~I~~ f :; ~I!II i I g ~ ~ ~; I m ~ =: ", -. t-~ . , llllln:TL I\ISSI:\:W-:tl .\' ~III.I':S. 1'.1', , . ROMAN SALAHACA, ) IN THE COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA ) v. ) NO. 94 - 2341 CIVIL ) SUSAN SALAHACA, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE ACCIP'l'AIIOI or SIRVIOI I accept service of the complaint in Divorce on behalf of Susan salamaca, Defendant in the above styled and numbered cause, and certify that I am authorized Date I A. M ller, Esquire cust Street sburg, Pennsylvania 17101 Co sel for Defendant san Salamaca . ~ ROMAN SALAMACA, ) IN THE COURT OF COMMON PLEAS OF plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA ) v. ) NO. 94 - 2341 CIVIL TERM ) SUSAN 8ALAMACA, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 330l(c) of I~h" oi',,,)..:.. co':... \;.... tilt.d or. ::lir J, 19!:J4. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filinQ of the Complaint. 3. I consent to the entry of a Final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or couneel feee or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. OJ. 1: have be.9n o..l','.t",ed of the BvaUill'::'l i+:y of marriage couneeling, and understand that I may request that the court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage couneelors in the prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. .,. le '" ,. .~... .. , t .., '..J1 ..,,. ~.' "; ~. " '; N ..r ~.... J ROMAN SALAMACA, ) IN THE COURT OF COMMON PLEAS OF plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA ) v. ) NO. 94 - 2341 CIVIL TERM ) SUSAN SALAMACA, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under section 330l(c) of the Divorce Code was filed on May 3, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a Final Decree in Divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. ,.. ~ tH co '" ~f. r: "'~ . . J I. .~. .\ '-' :J'- ~- ;.t- \.~ c,C -t .;~ r .. - ~ " ;J'" 14 " '.' . .