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Home My WebLink About95-01200 ~ Oy The CO~ ; A~~;f;" ~ ~.A~'~"k~ ~ ' ,~" ~, ."., ~ 1 ,olhonolBry ~'---- -- ..._---~~. --.-,... -.. ...... ....._-_......._-..,. ,,-, .' -.... _.~..... ..........' ,. . , , . ,~ ~~*~~~*~~**~*~~~-*~~-~****~~*~. ? ~ M ,'~ 8 ~ ~ ',' ~ i ',' 8 v ~.' ~', Pi " , , -~~~.~~~.~._--~~~~~~'~~~-~:~~~~~~._.:~~~ ~" -- - ~ w ',' w ... IN THE COURT OF COMMON PLEAS . . . ~ ~ OF CUMBERLAND COUNTY STATE OF _ PENNA. ~', * ~ ~ . $ 8 ~ ~ ~ - ~ i ~ ~ ~ ~ ~ $ '"' " ~ ~ ~ .'. ~ ~ " ,'~ * V ... ~ ',' V " ~ ',' w ',' ~ ',' ~ " J. t* ~~ l'" JlC! I; I w ',' w ',' i ',' V ',' 8 ."- ~ ,I<ARE:~..J,!.,().PD, , .... ...."............ II II N (), ..9.,~,::',~,~,Q,Q.., GJ;.Y.J.~.... 1<)95 M '. Plaintiff i .................... !I ~ Vel"Sl1S Ii d ...................... !I .'. ~ i ',' nDEL..A,.OLlD...JR., ' Defendant .:. ~ :; ~ i ',' DECREE IN DIVORCE i ',' ~ ',' ~ ,; w ':> AND NOW, ' , , , , " , , ,,~u.. :-, , , , ,'(~" " 1995,.", It is ordered and decreed that,.""" ..Kar,en, J,...Olid, ",.., ,'" " "..""", plaintiff, and,..........,..,.... J.':i,c;I!!~,l~" P,~i,c;I/..J:J;',................, 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; ""..""",.""""". ,I).~, ,C:~I!-~Jll,s, ,P!!nqi,~g",..,..""",..,..,.."",. ............. ........ ... .0.. " ...... .... ...... ........, . ^ ('.9'~'5- ud, (&f1 M,'Jdtv.4 tJ~ "t,9~r 71Aut. /U;>>-I.t> dfI' i I' , I I I " ~ KAREN J, OLID, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 95 - 1200 CIVIL TERM FIDEL A, OLID, JR., Defendant COMPLAINT IN DIVORCE PRABCIPB TO TRANSMIT RBCORD 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 S3301(d) (1) of the Divorce Code, 2. Date and manner of service of the Complaint: Certified Mail, Return Receipt Requested, March 22, 1995. 3, Date of execution of the Plaintiff's Aff1davi t required by 3301(d) of the Divorce Code: June 29, 1995; Date of service of the plaintiff's Affidavit upon the Plaintiff: June 29, 1995 4, Related claims pending: None 5. On June 29, 1995, the Defendant was served by first-class mail with a Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached. No response was received from the June 29, 1995 mailing. The counter-affidavit which was included in the mailing of March 22, 1995 was never signed d returned. MURREL R. WALTERS, III, ESQUIRE Attorney for Plaintiff 54 East Main Street Mechanicsburg, PA 17055 (717) 697-4650 1.0, No. 24849 "'- c.:: .., .c.. I ~_, c " I-' ,- ,"" .':J ,., ~ '0 - -< - c.o -, <..r1 , ,. KAREN J. OLID, , IN THE COURT OF COMMON PLEAS OF . plaintiff , CUMBERLAND COUNTY, PENNSYLVANIA . . . 95 - 1.;>,,00 CIVIL TERM vs, . , , . FIDEL A. OLID, JR., . COMPLAINT IN DIVORCE . Defendant . , 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 at the Cumberland County Courthouse, First Floor, CarliSle, Pennsylvania 17013, Telephone: (717)-240- 6195. 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. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, Pennsylvania 17013 Telephone (717)-240-6200 KAREN J. OLID, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, 95 - CIVIL TERM FIDEL A. OLID, JR., Defendant COMPLAINT IN DIVORCE COMPLAINT COUNT I - SECTION 3301 (0) The plaintiff by her attorney, MURREL R. WALTERS, III, ESQUIRE, brings this action in divorce for a Decree of Divorce from the bonds of matrimony and respectfully represents: 1. The plaintiff is KAREN J. OLID, an adult individual who currently resides at 338 McAllister Church Road, Carlisle, Cumberland county, Pennsylvania, 2. The defendant is FIDEL A. OLID, JR., an adult individual who currently resides at 121 Rosario village, st. Lucia Pasig, Rizal, Metro Manila, Philippines. 3. Plaintiff has been a both bona fide resident of 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 September 30, 1989 in Dillsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The plaintiff avers that the marriage is irretrievably broken. 7. The plaintiff requests the Court to enter a Decree of Divorce, 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the court to require the parties to participate in such counseling. Being so advised, plaintiff does not request that the court require the parties to participate in counseling prior to a Divorce Decree being handed down by the court. WHEREFORE, the Plaintiff prays that a Decree in Divorce be entered divorcing Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant. COUNT II - SECTION 3301 (4) 9. Paragraphs 1 through 8 are incorporated herein as if set forth at length, 10, The plaintiff and defendant have lived separate and apart since February 29, 1992 which is greater than 2 years. WHEREFORE, the defendant prays that this Honorable Court will grant her a divorce under section 3301(d) of the Divorce Code, Res?lil"1id' "- Esquire Murrel R. Walters, III, Attorney for Plaintiff 54 E. Main street Mechanicsburg, PA 17055 (717) 697-4650 '. . , ::0: ",g - ... .lz) ~ 'i... - ~ "T'ItuX ~ ~ ~ ~ ~ t"'1r"l~r ~ ~ ,IJ) ~;L'~I#' @) :;.r" ,. '"',d.- 0 4n....;.:... : '" '" ~ 0 ~ ~ ~:.:;.::.C N C '...:::.ox::;: ~~c_ N ~ ~ .:; ~....;rn -a C ~1.. -"-..:~", ::IC -7 ' ~ ~ -<'"" - of. ....;0; CoD , ..... -.. ~ ~ 1 . ~ ~ , L- .' KAREN J. OLID, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNT~, PENNSYLVANIA . . . vs. . 95 - I~OO CIVIL TERM . . . FIDEL A. OLID, JR., . COMPLAINT IN DIVORCE , Defendant . . NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: FIDEL A. OLID, JR. YOU HAVE BEEN SUED IN AN ACTION FOR DIVORCE. You have failed to answer the Complaint or filed a counter-affidavit to the Plaintiff's affidavit. Therefore, on or after July 19, 1995 the Defendant 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 signatul."e notarized or verified or a counter- af.fidavit 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 economic 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 Courthouse Fourth Floor Carlisle, Pennsylvania 17013 , , . KAREN J. OLID, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95 - IQOO CIVIL TERM vs, FIDEL A. OLIO, JR., Defendant COMPLAINT IN DIVORCE NOTICB OF INTENTION TO REQUEST ENTRY OF DIVORCB DBCREB TO: FIDEL A, OLID, JR. KAREN J, OLID intends to file with the court the attached Praecipe to Transmit Record on or after July 19, 1995 requesting that a final decree in MURREL R, WALTERS, III, QUIRE Attorney for Plaintiff 54 East Main street Mechanicsburq, PA 17055 (717) 697-4650 10 No. 24849 . ..: ""'" c: '" .!:,. ,",'" .:':..4, :f1 "^-, lJ'l l.D -~ ::J" )- .' "J:" c..o -'..' '"'"' , KAREN J. OLID, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. 95 - 1200 CIVIL TERM FIDEL A. OLID, JR., Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICB I, MURREL R. WALTERS, III, ESQUIRE, hereby certify that the Notice of Intention to Request Entry of Divorce Decree along with a copy of the Plaintiff's Affidavit Under section 3301(d) and a / copy of the Decree was served by first-class mail, postage p e- paid, on: June 29, 1995 MURREL R. WALTERS, III, ESQUIRE Attorney for Plaintiff 54 East Main street Mechanicsburg, PA 17055 (717) 697-4650 10 No. 24849 KAREN J. OLID, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . 95 - I:;)()Q CIVIL TERM . FIDEL A, OLID, JR., , COMPLAINT IN DIVORCE , Defendant . . NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. . KAREN J, OLIO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95 - I QOO CIVIL TERM COMPLAINT IN DIVORCE vs. FIDEL A. OLID, JR., Defendant COUNTER-AFFIDAVIT UNDER SECTION 3301(d) 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 18 Pa, C.S. S 4904 relating to unsworn falsification to authorities. Date: FIDEL A. OLIO, JR., Defendant NOTICE a 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. KAREN J. OLIO, IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . 95 - 1.)00 CIVIL TERM . . . FIDEL A. OLIO, JR., . COMPLAINT IN DIVORCE . Defendant : APPJ:DAVJ:T i II I , I I t I 1. The parties to this action separated on February 29, 1992 and have lived separate and apart for a period of at least two (2) VERJ:PICATION years. 2. The marriage is irretrievably broken. 3. 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. 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. S 4904 relating to unsworn falsification to authorities. :JZd ,,", I q. I q tf..j- Date 0 YaIuJO (9.J![d, ~ J. OL:u1 ~ "" .., - .c- c:. .... r-) /;., .::....: ,- " ....... u:> c.n