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Home My WebLink About00-03645 " ~~ "-.~""".;i.',^ GARY L. GIFT, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. otW-~l.(S-'CIVIL TERM v. CHERYL A. GIFT, Defendant : IN LAW - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VB 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 relief requested in these papers by the Plaintiff. You may loose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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, First Floor, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 1"'lI'~'" ~ ~ =".. ~ M1_tri,,>' GARY 1. GIFT, JR., Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. .2rtov - 3f. <r5" CIVIL TERM CHERYL A. GIFT, Defendant : IN LAW - DIVORCE COMPLAINT IN DIVORCE AND NOW COMES the Plaintiff, Gary 1. Gift, Jr., by and through his counsel, William 1. Grubb, Esquire, and complains of the Defendant, Cheryl A. Gift, as follows: COUNT I COMPLAINT UNDER SECTION 3301 Cc) OR 3301 Cd) OF THE DIVORCE CODE 1. Plaintiff is Gary 1. Gift, Jr., who currently resides at 430 North Second Street, Wormleysburg, Cumberland County, Pennsylvania. 2. Defendant is Cheryl A. Gift, who currently resides at 21 Blair Mountain Road, Dillsburg, York County, Pennsylvania. 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. Plaintiff and Defendant were married on June 14, 1997 at Shiremanstown, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. ~'""' ,;,,'C-, ." .', ~ ~r'l; . 6. Neither party is in the Armed Services of the United States or its allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order dissolving the marriage between the parties. COUNT II EOUlTABLE DISTRIBUTION 10. Plaintiff incorporates the allegations of paragraphs one (1) through nine (9) by reference as if set forth at length herein. 11. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after reqUITIng full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Date: t~, I - I (,., 2iJOll Respectfully submitted, L012a-: If~ ,~. William 1. Grubb, Esquire !.D. # 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 Attorney for Plaintiff ~"~ .~I CERTIFICATE OF SERVICE I, WILLIAM L. GRUBB, Esquire, certify that I have served a copy of the foregoing document on the individual listed below by depositing the same in the United States Mail, Certified, First Class, restricted delivery, postage prepaid, at Carlisle, Pennsylvania: Cheryl A. Gift 21 Blair Mountain Road Dillsburg, P A 17019 Date: ~ '2<>00 ()~??bA -4r. William L. Grubb, Esquire 3105 Old Gettysburg Road Camp Hill, PA 17011 ~-" - .~ ~~'" !;<,/ll m VERIFICATION I, GARY 1. GIFT, JR., verifY that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: ~//~Al!f' /~/~ G . Gift, Jr ff . ~. ilIl1'!i .;>, . GARY 1. GIFT, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO.Z.~-0~'l.~ CIVIL TERM v. CHERYLA. GIFT, Defendant : IN LAW - DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Gary 1. Gift, Jr., 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 counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subj ect to the penalties of Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: Pr'"/6/pe . / ~'!'~~~ Gary 1. Gift, Jr. I ;, ~I < ~_' ., , . --= ,~ "i~.1 ... GARY 1. GIFT, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-3645 CIVIL TERM CHERYL A. GIFT, Defendant : IN LAW - DIVORCE PROOF OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce filed in the above matter, was served on Cheryl A. Gift by first class, certified mail, return receipt requested, deliver to addressee only, at 21 Blair Mountain Road, Dillsburg, PA 17019, on June 16, 2000. Addressee acknowledged receipt of the same on June 19, 2000, as shown by the Acknowledgment of Service, attached hereto as Exhibit "Au. I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: ~I '2<:0> LJ"L /~ ..<- '7") Esquire william L. Grubb, I.D. 72661 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 763-5580 ~,,--- " , ~ - It! - GARY 1. GIFT, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-3645 CIVIL TERM CHERYL A. GIFT, Defendant : IN LAW - DIVORCE ACKNOWLEDGMENT OF SERVICE I, CHERYL A. GIFT, acknowledge that I was served on June 19,2000, via United States Mail with a copy of the above captioned Complaint in Divorce, No. 2000-3645, which was filed on June 16,2000. I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa. C.s. ~ 4904, relating to unsworn falsification to authorities. 'Ii ;),(J,f 00 Dat ( Ch9~ (] ,AJ~ Cheryl . Gift "A'l E Jl't1. '13 1'1 - ~"~'" ~~ , ~_"""O , .'t~"i GARY 1. GIFT, JR., Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-3645 CML TERM CHERYL A. GIFT, Defendant : IN LAW - DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above captioned action discontinued. Respectfully submitted, Date fWJ < \, 2<J<>u U)~,t.tJ! .~. William 1. Grubb, EsqUlre Attorney for Plaintiff 3105 Old Gettysburg Road Camp Hill, PA 17011 (717)763-5580 LD.72661