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Home My WebLink About00-01866 NANCY A. STUMP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.oo- JPr..J" CIVIL TERM Defendant CIVIL ACTION - LAW IN DIVORCE GARY C. STUMP, 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 CUMBERLAND COUNTY COURTHOUSE. 1 COURTHOUSE SOUARE. CARLISLE. PENNSYLVANIA 17013. IF YOU DO NOT WISH TO 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. YOUR 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: 249-3166 800-990-9108 ~ _7';,- . '0 _ "~._ . -"_', -, . _",,"',_ ,;:?.-J w "~ >_,-"T_~__ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. &v ./f~' CIVIL TERM CIVIL ACTION - LAW NANCY A. STUMP, Plaintiff GARY C. STUMP, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff, by Lori K. Serratelli, Esquire and the law firm of SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: COUNT I 1. Plaintiff is Nancy A. Stump, who currently resides at 20 York Hill Road, Etters, York County, Pennsylvania 17319 since 1981. Plaintiff's Social Security Number is 184-48-8096. 2. Defendant is Gary C. Stump, who currently resides at 229 West Main Street, Apt #2, Mechanicsburg, Cumberland County, Pennsylvania 17055, since January 19, 2000. Defendant's Social Security Number is 194-44-9743. "-' '-'^""'r', ,',_",'"".r,-,'_-,-' _ ,,0. . >, '__,___L,,_ __c_,'),, ,. <. "- =~ . ." 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 29, 1978, in Dauphin County, Pennsylvania. 5. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 6. A prior divorce action was filed by the Plaintiff herein. The matter was docketed with Dauphin County Court of Common Pleas, at Docket No. 1407-8-1987. The parties attempted reconciliation and the matter was terminated January 28, 1991. 7. The marriage is irretrievably broken. 8. The Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The Plaintiff and Defendant are both citizens of the United States. 10. Plaintiff avers that there are two children of the parties under the age of 18, namely Alicia Stump, born January 8, 1986; and Derek Stump, born August 7, 1989. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. >~,._,- " , -, - ~- '- , - -"_''''''''--0 -- - .-< ,~ COUNT II INDIGNITIES 11. Paragraphs one through ten are hereby incorporated by reference herein. 12. The Plaintiff avers as the grounds on which this action is based is that the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 13. This action in divorce is not collusive. WHEREFORE, the Plaintiff prays Your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. COUNT III ALIMONY 14. Paragraphs one through ten are hereby incorporated by reference herein. 15. Plaintiff is unable to adequately support herself through appropriate employment. " ,foe ".','''1, P..'___ .- . - - - -C' ,,~~-~, ",'. 16. Plaintiff lacks sufficient property, including but not limited to, any property distributed pursuant to the Divorce Code of 1980, as amended, to provide for her reasonable needs. WHEREFORE, Plaintiff prays that Your Honorable Court grant an Order upon Defendant: (a) Compelling the Defendant to pay alimony to Plaintiff; COUNT IV ALIMONY PENDENTE LITE. COUNSEL FEES AND COSTS 17. Paragraphs one through ten are hereby incorporated by reference herein. 18. That by reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs. 19. That the Plaintiff's income is disproportionately lower than Defendant's income, and Plaintiff is without adequate funds to pay the costs and expenses of this litigation, and is, likewise, without adequate funds to maintain herself during the pendency of the litigation. ,." '''1'.- ',',",, ," -1-'- .1-< 20. The Plaintiff is employed at Hospice of Central Pennsylvania and earns approximately $2,000 per month net income. 21. The Defendant is employed at F.M.S.O. Navy Depot in Mechanicsburg, Pennsylvania and earns approximately $4,500 per month net income. WHEREFORE, Plaintiff prays that Your Honorable Court grant an Order upon Defendant to pay Plaintiff alimony pendente lite and counsel fees and costs of litigation. COUNT V EOUITABLE DISTRIBUTION 22. Paragraphs one through ten are hereby incorporated by reference herein. 23. Plaintiff states that Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by the court. I'-~ ,_ "'_'''_~''__ ,_~,__,lO_,_ 24. Plaintiff requests that this court grant equitable distribution. WHEREFORE, Plaintiff prays that Your Honorable Court: (a) Equitably distribute all property, personal and real owned by the parties; (b) Grant Plaintiff exclusive possession of the marital residence; (c) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, )[;2~. LorilK. Serratelli, Esquire SERRATELLI, SCHIFFMAN, BROWN & CALHOON, P.C. 2080 Linglestown Road Suite 201 Harrisburg, PA 17110 (717) 540-9170 ATTORNEY FOR PLAINTIFF 'n', ,;'._ - , :'~'T-"-- ,-,"'," -. . 1'~-' "' '-~-~"- ;-'~'=--- - VERIFICATION I verify that the statement made in the foregoing Complaint in Divorce 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: 3/;;1/ tJo ~C1'A.1:::r "" - ,~.,'. c', ,. " , ~--, .'.-- q,-- "~ ."".~ . .".' ":-: H 105.157 REV.aoSO COMMONWEAl.TH OF PENNSYLVANIA OEPARTMENT OF HEALTH VITAL RE:CQROS DIVQR_c:"-_ CKJ RECORD OF __ _OR ANNULMENL (CHECK ONE) 0 COUNTY I CUMBERLAND 1.~,i!~lml:;I;!iiil;ill""'i,f',i ,.'",,' >:: "":::: ;~ :::;j;:::,,:/,;;:.,:;',:::.:: ~<\;~.,. .-..... .... i.~ ::);",'-:(,o;iU:,:,:;".":!".,:",,,..u...m ,1~ml!l11jl!j!mhlm~;!i11Hli!?;}HH;;iJ!!Hllli1j)lf.j~m~ ' " .'..;""""11:1 :::;: . : ,:;~;:..: STATE FILE NUMBER STATE FILE OATE [iJst ." SSN: 194-44-9743 " NAME (Firsr) GARY 2, RESIDENCE -Streeto,-R.D. 229 West Main St. , " NUMSER OF THIS 1 MARRIAGE HUSBAND (Mkfdle) 2. DATE OF BIRTH 4. PLACe OF , BIRTH USUAL OCCUPATION-- CHESTER "'Ctri'.-so(o. oi'iWp. STUM:p Mechanicsburg, " , 'i1ta> Apt :-#2, 6. RAClf WHITE (XJ BLACK o ~~HEOpecifYl Mont 00' 4-26-53 at~ or ore(gn unU'y. Pennsylvania SSN: 184-48-8096 --WIFE Computer Systems Analyst 8, (First! (MiddTd 9. DATE OF BIRTH -,'l.'""PL.ACE 0' BIRTH CCUPATION (Um) STUMP MAIDEN NAME HALL ANNE NANCY "" sr,e"eto;-k'b:'" County .:.tate Ciry, Bora, or Twp. '0, RESIDE;N_CE 20 York Hill York Count Road Etters 13. RAC WHITE i:XI ", NUMBE;R OF TWIS MARRIAGE PLACE OF DF THIS MARRIAGE NUMBER-OF CHIL- DREN THIS MARRIAGE NUMBER -QF HUSBANO CHILDREN TO 0 CUSTODY OF DATE OF DE"CREE 23, ........~~ ";...~"'----~----"-'-'--~ "-"-- BLACK o 1 (State or Foreign Country) OATE OF " THIS MARRIAGE '5, (County) '7A, OTHER (Specify) o HUSBAND o Wlf=E IXJ 2 2 (Month) Year: Day) 2-05-58 _.n ($tafeor-Fore;-gn Co"untry) Pennsylvania Nurse (Month) Day Year) 4-29-78 WIFE; IX! OTHER (Specify) o & Indi ni ties j 00''--- - LEGAL GROUNDS FOR DIVORCE OR ANNULMENT Irretrievable Breakdown DA TE REPORT sE"NT "" Month Day TO VITAL. RECORDS Yoo, SPLIT CUSTOCY o 20, Q,THEfl (Spedfy) o 21. WIFE I2J (Dayl (Month) 22, 24. SIGNATURE DF TRANSC-R-mING CLERK :1;,' t :-:;~: !; .. '< . NANCY A. STUMP, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-1866 CIVIL TERM GARY C. STUMP, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Edward J. Weintraub, Esquire, attorney for the Defendant in the above-captioned matter, hereby certify that I accept service of the Complaint in Divorce filed in the above captioned matter. Dated: 1Jf~(trO Sworn and Subscribed to before me this ~day of ~ , 2000. NOTARIAL SEAL EMl~YA FRITZ Notary l'Ub1lc , HarrlsburgCfly, Oauphln County , Com~slon ExPlr~ Qeq..4, 20110 ' - - - ',.-, ~- c . , - . " '\ - ;. ,. NANCY A. STUMP, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1866 CIVIL TERM Defendant : CIVIL ACTION - LAW : IN DIVORCE GARY C. STUMP, PRAECIPE TO WITHDRAW APPEARANCE Please withdraw the appearance of Edward J. Weintraub, Esquire, on behalf of the Defendant, GARY C. STUMP, in the above captioned action. Edward J. Weintraub, Esquire 2650 North Third Street Harrisburg, P A 1711 0 fri~) 2"Pftf , PRAECIPE FOR ENTRY OF APPEARANCE PLEASE enter the appearance of Diane S. Baker, Esquire, on behalf of the Defendant, GARY C. STUMP, in the above-captioned action. e S. Baker, Esquire 27 South Arlene Street P.O. Box 6443 Harrisburg, PA 17112 (717) 671-9600 ID#53200 DATE: of~/()::; - ,~ , ..", " ~~" '" " -~ I' . - ',~'~ << .. -" .. ~I ~'-' ~ ~ o C -rJ ~~ rnf';';'j z::;:; vsS ~~~ <'-_.. >e zc' :S>C ::~ -~ II ...1 "~' c::> o ~ 1..__ C") i"-,) \.0 C) --1'1 ,~ ....l,. '=:> ~ -, ~ .. ~,~.,.,_ ...~~ITh"r!!'f;;,""m"ll'i1"~~~l\Jl'J'lm~Affl!!!~~'!f'iWLfi!jJI~i~'"i