HomeMy WebLinkAbout94-02341
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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.
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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
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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
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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
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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.
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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.
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