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Home My WebLink About02-3856 LAW OFFICES MARLIN R M¢CALEB GABRIELA URENA, Plaintiff VS. JONAS RAMOS TAPIA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 5 56, civil : CIVIL ACTION - 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. If the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ~,~~~~ Marlin R. McCaleb Attorney for Plaintiff LAW OFFICES MARLIN R McC~,LEB GABRIELA URENA, Plaintiff VS. JONAS RAMOS TAPIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is GABRIELA URENA, who currently resides at 155 Salem Church Road, Lot 1, Mechanicsburg (Hampden Township), Cumberland County, Pennsylvania 17050, since August 5, 2002. 2. Defendant is JONAS RAMOS TAPIA, who currently resides at 6280 Carlisle Pike, Lot 410, Mechanicsburg (Hampden Township), Cumberland County, Pennsylvania 17050, since August 5, 2002. 3. 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. Plaintiff and Defendant were married on July 10, 2000, in Hummelstown, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have -2- the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests your Honorable Court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4904, relating to unsworn falsification to authorities. Date: August t2 ,2002 Gabriela Urena, Plaintiff Marlin R. McCaleb Attorney I.D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Plaintiff -3- I AW OFFICE~ MARLIN R McCALEB GABRIELA URENA, Plaintiff VS. JONAS RAMOS TAPIA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELiNG Gabriela Urena, being duly sworn according to law, deposes and says: 1. 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. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S., Section 4904, relating to unswom falsification to authorities. Date: August Ic~., 2002 Gabriela Urena, Plaintiff LAW OFFICES MARLIN R. McCALEB GABRIELA URENA, Plaintiff vs. JONAS RAMOS TAPIA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02-3856 CIVIL TERM : : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF SERVICE MARLIN R. McCALEB, Esquire, certifies and says: that he is the attorney for Gabriela Urena, the Plaintiff in the above-captioned action; that on behalf of said Plaintiff, he did file Plaintiff's Complaint in Divorce in the Office of the Prothonotary of Cumberland County, Pennsylvania, on August 13, 2002; that pursuant to Rule No. 1930.4(c) of the Pennsylvania Rules of Civil Procedure, he did serve said Complaint upon Jonas Ramos Tapia, the Defendant herein, by depositing a true and attested copy of said Complaint, properly endorsed with Notice to Defend and Claim Rights, in the mail in the post office at Mechanicsburg, Cumberland County, Pennsylvania, on August 13, 2002, properly addressed to the said Defendant at his place of residence at 6280 Carlisle Pike, Lot 410, Mechanicsburg, PA 17050, with proper postage attached, certified United States mail (Receipt No. 7099 3400 0017 1940 0822, return receipt requested, restricted delivery); that thereafter he did receive said return receipt card bearing the signature of Jonas Ramos Tapia, Defendant herein, and indicating receipt of said copy of the Complaint on August 29, 2002; that the said certified mail receipt and return receipt LAW OFFICES MAF~LIN F~. McCALEB card are attached hereto and made a part hereof, marked Exhibit 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., Section 4904, relating to unsworn falsification. Date: ~~3., 2002 ~~ Marlin R. McCaleb LAW OFFICES MARLIN R. McCALEB Postage Certified Fee Return Receipt Fee (Endorsement Requital) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees 1.75! 3.50 · oomplm munro 1, Z md O. Aio oo~N~ · M~ 4 If F#llfkJeld Ddl~me~ im dldmd. Jonas Ramos Tapia 6280 Carlisle Pike, Lot 410 Mechanicsburg, PA 17050 I~ml? r'ly# C.O.D. 7099 3400 0017 1940 o~,22 PS '-'~""~ 3811, July 199e EXHIBIT "A" LAW OFFICES MARLIN R. McCALEB GABRIELAURENA, Plaintiff vs. JONAS RAMOS TAPIA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : : CIVIL ACTION - LAW : : NO. 02-3856 CIVIL TERM : : CIVIL ACTION - IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: service by certified United States mail, return receipt requested, restricted delivery, on August 24, 2002, as set forth in Affidavit of Service filed herein. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff: April 11, 2003; by Defendant: April 11, 2003. 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 a copy of which is attached: (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: April /~J 2003 (c) Date Defendant's Waiver of Notice was filed with the LAW OFFICES MARLIN R. McCALEB Prothonotary: Date: April April /~" , /~, 2003 2003. -2- Marlin R. McCaleb, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS GABRIELA URENA, Plaintiff Of CUMBERLAND COUNTY STATE Of PENNA. VERSUS JONAS RAMOS TAPIA~ Defendant NO. 02 - 3856 CIVIL TERM DECREE IN DIVORCE AND NOW, F, ~- , DECREED THAT AND GABRIELA URENA JONAS RAMOS TAPIA , IT IS ORDERED AND , PLAINTIFF, , 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; NONE BY THE COURT: J. PROTHONOTARY