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Home My WebLink About00-01111 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ;f. Of.'fi "';t;;t;~;+:......... Of. . ... .........++++... +...+ ... +~ ++++++++ +++++++++ .. .. ;t':+ + 'to if'''':Ii IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DEBRA ANN GORDON, No. 2000-1111 Civil Term Plaintiff VERSUS GARY s. r..oRDON. Defendant DECREE IN DIVORCE AND NOW, '^^~ ~ ~ , IT IS QRDERED AND DECREED THAT DEBRA ANN GORDON , PLAINTIFF, AND GARY S. GORDON , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLI..OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE ~ / // // r f~ ATTEST: PROTHONOTARY ;t.;t +;+: + ,.-'1' '+' ...;t + "':t' + + ... '" +... + :+;to Of 'f. '" + '+ Of. 'f ... + +... 't'...;t '+':t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . DEBRA ANN GORDON, Plaintiff ",,------;=- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. No. 2000-1111 Civil Term GARY S. GORDON CIVIT- ACTION- IN DIVORCE Defendant 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 Section ( ) 3301 C ( J{) 3301 D ofthe Divorce Code. (Check applicable code) 2. Date and manner of service of the -complaint {;prr; r; prl_Rp.~t-,...; f"rp.n ~""T""'l:d rot:> ~ /1./nn 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) (I) Date of execution of the plaintiff's affidavit required by Section 3301 (D) ofthe Divorce Code: 2/25/00 (2) Date of filing and service ofthe plaintiff's affidavit upon the respondent ~ /~ /nn 4. Related claims pending: !lGNE 5. (Complete either (a) or (b).) (A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Certified-Restricted delivery 4/5/00 (B) Date plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: Date defendant's Wavier of Notice in ~ 3301 (c) Divorce was filed with the Prothonotary: Attorney for ( x ) Plaintiff ( ) Defendant Prothon.-49 I ~ ~-v..~. '_. . ~,"".~; :>.~ ...' .5fJ'CJCJ dwI- ~.M~ ~ 4 ~ y3.a; '7i~ ~~~. , < . (") a C a C) ? -" -o;::~ ,.,. rn;:~. "1J -~ 2:t.' :;0 'i~ :::: L;""" i'.;l c/5~, ~:,23 rsiG co ....--.....w' ~~6 ;,;; ~ ;z() -- - :t? $(~) ~ _:~:c5 C C ,71 2: =< ~ .r.:- 55 -< .~' , DEBRA ANN GORDON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. .;looo- /11/ Ciu~.( y~ GARY S. GORDON, Defendant IN DIVORCE : NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN the claims set forth action. SUED IN COURT. If you wish to defend against in the following pages, you must take prompt You are warned that if you fail to proceed without you and a decree of divorce entered against you by the Court. A judgment against you for any other claim or relief papers by the Plaintiff. You may lose money rights important to you, including custody children. do so, the case may or annulment may be may also be entered requested in these or property or other or visitation of your 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 Court Administrator's Office, Cumberland County Courthouse, Carlisle, PA. PROPERTY, GRANTED, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DO NOT OFFICE CUmberland County Bar Association 2 Liberty Avenue Carlisle, PA l70l3 (7l7) 249-3l66 , DEBRA ANN GORDON, Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. :t.l.Hro- JIll ~ ~ GARYS. GORDON, Defendant : : CIVIL ACTION-LAW DIVORCE ACTION NO FAULT DIVORCE COMPLAINT 3301(D) AND NOW COMES the above-named Plaintiff, DEBRA ANN GORDON, by Judith A. Calkin, Esquire and she seeks to obtain a Decree in Divorce from the above named Defendant upon the grounds hereinafter more fully set forth: ~. Plaintiff is DEBRA ANN GORDON, who resides at ~~45 Myerstown Road, Gardners, Cumberland County, Pennsylvania. Her social number is 205-44-0534. 2. Defendant is GARY S. GORDON, who resides at ~056 Rebecca Street, Carlisle, Cumberland County, Pennsylvania. His social security number is 206-52-~~00. 3 . Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing for this Complaint. 4. The Plaintiff and Defendant were married on November ~4, ~992 in Cumberland County, Pennsylvania. 5. There has been no previous action filed to the above- captioned number and term. " 6. The Defendant is not a member of the Armed Forces. 7. The marriage is irretrievably broken, and the parties have lived separate and apart for a period in excess of two (2) years. 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 handled down by the Court. WHEREFORE , Plaintiff requests the court to enter a decree of divorce under 330l(d) of the Pennsylvania Divorce Code. Respectfully submitted: ../J / /!-~ udith A. Calkin, Esquire Attorney for Plaintiff 220l North Second Street Harrisburg, PA l7ll0 (n7) 238-23l2 vs. IN- THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~_ JII)CU:JI_____ NO. DEBRA ANN GORDON, Plaintiff GARY S. GORDON, Defendant CIVIL ACTION-LAW DIVORCE ACTION NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this Affidavit, you must file a counterclaim within twenty (20) days after this affidavit has been served on you or the allegations will be admitted. AFFIDAVIT OF PLAINTIFF UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in January, 1998, and have continued to live separate and apart. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights, concerning alimony, division of marital property, attorney's fees or expenses if I do not claim them before a divorce is granted. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. 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: .:21.:25 It) 0 -/JJ;a d AdffJ Debra A. Gordon , , , . Commonwealth of Pennsylvania: ss. County of Dauphin I verify that the statements made in this 3301 (D) Divorce 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: Ueka d Ach/YL Debra A. Gordon 6f Subscribed ~ this 25 day , 2000. Sworn and before me f....>> . qMA;'^~ Notary ~AAjl.J A1AJ<- Public NOTARIAL SEAL ELLEN ROSENBLOOM, Notary Public . of Harrisburg, Dauphin CounlY mmlssion Ex ~es Ma 8, 2003 . . . . , . . ~ CERTIFICATE OF SERVICE I, Judith A. Calkin, do hereby certify that a true and correct copy of the within Divorce Complaint 3301 (d) was mailed at Harrisburg, PA., certified-restricted delivery, postage pre-paid to the following person: D~~1~ Gary S. Gordon 1056 Rebecca Street Carlisle, PA 17013 (7. .... ~ 'dith A. Calkin, Esq. / . . , . . . 0 0 0 c 0 -,., -, ." ,~ '.- -")r'-' n ~;~ ~ rhf?: = , 2-....." .,. N Zr- UJ.~_~ CO '-:~f~ -<.< r::.'.~ ~~- ::? -, ~r', ~- ~~~~ ,~ W > c: :=1 z => S ::<! ....J -< ~..... ~,,11~ a DEBRA ANN GORDON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 1111 Civil Term GARY S. GORDON, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE TO: GARY S. GORDON, DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter affidavit to the plaintiff's affidavit. Therefore, on or after April 13, 2000, 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 counter affidavit 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 econ9~jc relief. A COUNTER AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. UNLESS YOU RAVE 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. THE FILING OF THE FORM COUNTER-AFFIDAVIT ALONE DOES NOT PROTECT YOUR ECONOMIC CLAIMS. YOU SHOULD YOU DO NOT RAVE TELEPHONE THE OFFICE LEGAL HELP. TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF A LAWYER OR CANNOT AFFORD ONE, GO TO OR SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 '-~ . DEBRA ANN GORDON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - 1111 Civil Term GARY S. GORDON, Defendant IN DIVORCE DEFENDANT'S 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 two 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 understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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 ~8 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: Gary S. Gordon NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any c~aim for economic relief, you need not file this counter affidavit. .. w.__ '__~,,<. ~ . (J <::> C) ~ <:.::> -n ~ uF::!; -r, ~I~. ::u ~'7 .,., :;:::.:- "-., !~:t en ~:, CO :'~iO -<~... : ') ~:-) r-~, .~! ..-....~ :C? ~r.~ -H ~ -,~ () r::? "~', r1"1 ~c=: ,~ - ~ ""- ---; f'0 _0 -:: -< DEBRA ANN GORDON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-1111 Civil Term GARY S. GORDON, Defendant CIVIL ACTION-LAW IN DIVORCE M"fWA VIT OF SERVICE I, Judith A. Calkin, Esquire, deposes and says: 1. That she is an adult individual residing in Cumberland County, Pennsylvania. 2. That on March 23, 2000, she sent by certified- restricted mail, return receipt requesting from Harrisburg, Pennsylvania (No. 273 825 755) flieoNOf:ice of Intention to Reql.lest ~Eritry of a Divorce_Decee in the above captioned case to: Gary Gordon 1056 Rebecca Street Carlisle, PA 17033 3. That on April 5, 2000, Gary Gordon signed the receipt (No. 273 825 755) which is attached to this affidavit. Calkin, Esquire for Plaintiff 2201 North Second Street Harrisburg, PA (717) 238-2312 --",- ~ Z273U 825' 755 - ----, , US Postal Service Receipt for Certified Mail No -Insurance Coverage Provided. Do not use for International Mail See reverse Sent to POs1age Certified Fee Special DelivefY Fee Restricted DeUve:y Fee . '" ~ Return Receipt Showing to ..... Whom & Date Deli '!i Retum <. Dale, & c:i o TOTA CD CO) p E {L (I) 0.. tJ.A<.../ 5:+ (7013 $ 33 IYO 2...7'5 (.25 5.73 -- --~--:-:::':'-'------------ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Atdil.ch this card to the back of the mail piece, or on the front if space permits. 1. Arti~le Addressed to: 'f\t"l1 ( 0 S ~tv6..(..u'a- C 1"<,/,", I.e... G,. er-d fYV' PCL t 7013 D. Is deliv address different from item 1? [f YES. enter delivery address below: D Agent dressee - DYes ONo ~-{ 3. Service Type ~rtified Mail D Express Mail .0 R~gistered D Retum Receipt f r Merchandise D Insured Mail D C,O.D. 4. Restricted Delivery? (Extra Fee) Yes PS Form 3811, July 1999 2. Article Number (Copy from servic,'abe~, . ;:J. 13 8. J., ~, :7 :is . .j ;; ,. Domesti.c Return Receipt ~'".J 102595-99-M-1789 L ~ C) ,- ""D ,~; n.jr~ ~E:: r>c....f: --=- -' ,- ~';t~ ::--::::c.' ~>r.:: ~ =< r" C. D ~ -~ "" "" co o ~q ::.7r-::'.! ')f'i1 , ,1(:;:] iJ!.1 Sf ;0 --< -0 -:-,. ;."? .J;:..-~ -... DEBRA ANN GORDON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-1111 Civil Term GARY S. GORDON, Defendant CIVIL ACTION-LAW IN DIVORCE M..<'wA VIT OF SERVICE I, Judith A. Calkin, Esquire, deposes and says: 1. That she is an adult individual residing in Cumberland County, Pennsylvania. 2. That on March 1, 2000, she sent by certified- restricted mail, return receipt requesting from Harrisburg, Pennsylvania (No. 273 825 751) the~3301(D) Divorce~Complaint in the above captioned case to: Gary Gordon 1056 Rebecca Street Carlisle, PA 17033 3. That on March 3, 2000, Gary Gordon signed the receipt (No. 273 825 751) which is attached to this affidavit. .~ Calkin, Esquire for Plaintiff 2201 North Second Street Harrisburg, PA (717) 238-2312 ..j;.. --~ -..... Z 273 82"5 751 , us Postal Service Receipt for Certified Mail No Insurance -Coverage Provided. Do not u 10r International Mail See reverse $entto o,..d~ o S il~hut- j P~ffice. Stale. . ZIP Cod, I 7 I ~ L.-f()/ /-is Ie. b ~ $ ,S-S- CJ Posta~e Certified Fee Special Delivery Fee Restricted Delivery Fee '" m Return Receipt Showing to Whom & Date Delivered 'g. RetumReceiptSl1 <( Date, & Mdt o o CO '" E <; u.. '" a. Complete items 1, 2, and 3. Also 'complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can retum the card to you. . Attach this card to the back of the mailpiece, OLan the front if spa~e permits. 1. Article Addressed to: (; f'(V--'1 ~c.d~,J \O~~ ~ S"+ C~L.SIe.- ~~ 110 \3 .~5 f5 x o Agent o Addressee, DYes DNo D. Is delive address different from item 1? If YES, e ter delivery' address below: RESTRICTED DELIVERY 3. Service Type ~ertlfied Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise DC.C.D. 4. Restricted Delivery? (Extra Fee) 2. Article Number (Copy from service label) c> -r ~ _ J ,=l,3 ~ J5 .L ~ PS Form 3811, July 1999 Domestic Retum Receipt 05 "- i> " 102595-99-M.1789 : i. -~- ..:- , 0 c..-::> 8 c:: 0 -'1 ""t''::' :!'::not n-f!+-:' -" 'n ??t~' ':::J .- r-., , .'J; (;)0.'-: ':0 :"7 ;$;--;.:, -:S ~'-- -" :f;1 "- 18 -M ::1:. i5 c: {\...) 0 n-, 2: '" ~ =< t'.) :co -<