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Home My WebLink About07-0473 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. $8732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. GAYLE E. GILLIGAN, Defendant : NO. 07 - 7.3 CIVIL TERM : IN DIVORCE NOTICE 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 in 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW GAYLE E. GILLIGAN, : NO.07 - 5 73 CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(Cl OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is David A. Gilligan, an adult individual residing at 102 Royal Road, Palmyra, Lebanon County, Pennsylvania 17078. 2. The defendant is Gayle E. Gilligan, an adult individual residing at 40 Betty Nelson Court, Lot 157, Carlisle, Cumberland County, Pennsylvania 17015. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parries were married on March 28, 2003, in Cumberland County, Pennsylvania.. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. .,. 6. The plaintiff avers that he has been advised of the availability of counseling and that said parry has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. ?A a 3 , 2007 David A. Gilligan, Plaintiff WOLF & WOLF dZ , 2007 BY: Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff STACY B. LF, ESQUIRE 1? b 110 D ?_e C7 ? r <-? __..a -TI --w -? m j STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 98732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GAYLE E. GILLIGAN, Defendant : CIVIL ACTION - LAW N DI - NO. 07 I -i?C.3---- CIVIL TERM N DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotar/s Office, 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. JA •? a 3 , 2007 -----V?d - - David A. Gilligan, Plaintiff N -TI J FTI ??v STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. GAYLE E. GILLIGAN, Defendant : CIVIL ACTION - LAW NO. 07 - 473 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO 1920.4 (a)(11(il NOW, Stacy B. Wolf, Esquire, being duly sworn according to law, does depose and state: 1. That she is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about February 14, 2007 by certified mail "restricted delivery," addressed to the defendant at 40 Betty Nelson Court, Lot 157, Carlisle, Pennsylvania 17015, return receipt No. 7004 1350 0003 7288. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. February 19, 2007 STACY B.''WOLF Attorney for Plaintiff C7 C, 5 ro rr, C:) , Y 7n:z,? Lt --G tL3 N T COD -" 3 rn a j ? Q Ch CD O v N Q O Q oyo?.mo + s`- v ? X33 W CD O v. y` 'y 9 5 Gi ? CD j' CD -+ V to O C N Q CD + CL. .. C7 d , 'C3 N O CD D W grow o - aN N 4 O CD O ; ? O ,'' r+ N_. O CD -no 0 CD v1 ID! oil cc cn o `o W L N ja b D v p ID 0 N v N C1 ?S y O rn su STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GAYLE E. GILLIGAN, Defendant : CIVIL ACTION - LAW :NO. 07- CIVIL TERM IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, 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 Prothonotarys Office, 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 counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. GS. Section 4904 relating to unworn falsification to authorities. 2007 _ AJ, f- Gayle E. Gillig efendant -1' ?B r ? f 7-4 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 89732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. GAYLE E. GILLIGAN, Defendant : CIVIL ACTION - LAW NO. 07 - 473 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about January 23, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of filing and service of the complaint. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. Y 2007 C GA E E. GILLIGAN' ?? ?=fi ?? ? ?. a _;? L.-'. ? 1?1 1'-; ,.' ??i ?:? G3 ?? .?_ c..:> STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GAYLE E. GILLIGAN, Defendant : CIVIL ACTION - LAW NO. 07 - 473 CIVIL TERM IN DIVORCE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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 to authorities. Date: / `l )4e) Y7 ' GA E E. GI ['"1 ? ? ?? C? "4l _ ,_? ,- ? ?..7+. C.,_. Z'T': ?'.? -?. s i ',. ?.?.+ , (' ? _. :. __` , ._,.., C"a .. _T STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION LAW GAYLE E. GILLIGAN, : NO. 07 - 473 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about January 23, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. 7 - aS CPA , 2007 u DAVID A. GILLIGAN -in C5 3 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GAYLE E. GILLIGAN, Defendant CIVIL ACTION - LAW NO. 07 - 473 CIVIL TERM : IN DIVORCE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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.-S. Section 4904 relating to unworn falsification to authorities. Date: 7-r?C7? DAVID A. GILLIGAN G Qi STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF DAVID A. GILLIGAN, V. GAYLE E. GILLIGAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 473 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary. decree: Please transmit the record, together with the following information, to the court for entry of a divorce 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about February 14, 2007, defendant was served with a copy of the divorce complaint via certified mail. (See Affidavit of Service previously filed February 20, 2007) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: July 25, 2007. By the defendant: July 14, 2007. (b)(1) Date of execution of the affidavit required by Section 3301(4) of the Divorce Code: N/A. (b) (2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 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 to transmit record, a copy of which is attached: N/A. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: July 30, 2007. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary. July 23, 2007. August 2007 AVI STACY B. OLF Attorney for Plaintiff r ?- - - r - c _ n r-- ?;' CS' C N un IN THE COURT OF COMMON PLEAS David,k Gilligan No. 2007 0473 VERSUS DECREE IN DIVORCE AND NOW,4 IT IS ORDERED AND DECREED THAT _ David A- Gilligan , PLAINTIFF, AND 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 PROTHONOTARY OF CUMBERLAND COUNTY STATE OF PENNA. /!'C? ?? ??? "? ? ?O- Off- 3