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Home My WebLink About07-1467 LAURIE GUMBY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MARCUS GUMBY, Defendant CIVIL ACTION - LAW NO. 07 -ILll, 1 CIVIL TERM IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB ALA WYER., GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO IllRE A LAWYER., TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle. PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. LAURIE GUMBY, PlaintitT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. MARCUS GUMBY, Defendant CIVIL ACTION - LAW NO. 07 - / 'I {, 7 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301W OF THE DIVORCE CODE 1. Plaintiff is Laurie Gumby, an adult individual, who resides at 144 Tower Circle, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Marcus Gumby, an adult individual, who is currently incarcerated at Cumberland County Prison, 11 0 1 Claremont Road, Carlisle, Pennsylvania 17013. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 16,2004, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: March 13,2007 Respectfully submitted, Rominger & Associates '2onring~, Esqui:-- 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID. # 81924 Attorney for Plaintiff LAURIE GUMBY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. MARCUS GUMBY, Defendant CIVIL ACTION - LAW NO. 07 - CIVIL TERM IN DIVORCE VERlFICA TION 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. ~4904, relating to unsworn falsification to authorities. Date: 3-/ L{ '-07 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAURIE GUMBY, v. MARCUS GUMBY, Defendant CIVIL ACTION - LAW NO. 07 - CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Complaint in Divoorce upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Marcus Gumby/Inmate Cumberland County Prison 1101 Claremont Road Carlisle, Pennsylvania 17013 Date: March 13, 2007 Respectfully submitted, Rominger & Associates )- Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID. # 81924 Attorney for Plaintiff r"') ~ ''1"\ C::~, ...4 o <;::., ,_"( ~ <;:'" ~,... fi'\ I~, ':'":.... ......1..,- . ~ 1)~~ :::: .~~ <.:-? ~ f'-' ..- ... \}' ~\' ~ .\\ ~~~\ \~ ~~ '~~ ~;11) ~ O""J. 0> .I? if <"1" F1LEC ?- o FIFE 7ARY r T! f 3 Rl LAURIE GUMBY, v. MARCUS GUMBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 1467 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the original Divorce Complaint in the above captioned matter a copy of which is attached for certification and service. Respectfully submitted, Rominger & Associates Date: Karr . Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff .#1o. Oo P? A77"/ ?-t X847 Q °? d{ 81010 IV LAURIE GUMBY, V. MARCUS GLrMBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - I Y4 Defendant : IN DIVORCE CIVIL TERM You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. , Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 - (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. r , LAURIE GUVIBY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - LAW NO. 07 - CIVIL TERM IN DIVORCE V. MARCUS GUMBY, Defendant COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Laurie Gumby, an adult individual, who resides at 144 Tower Circle, Carlisle, Cumberland County, Pennsylvania 17013, 2. Defendant is Marcus Gumby, an adult individual, who is currently incarcerated at Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania 17013. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 16, 2004, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. 01 WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, Rominger & Associates Date: March 13, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff LAURIE GUMBY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - CIVIL. TERM : IN DIVORCE V. MARCUS GUMBY, Defendant VERIFICATION 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. §4904, relating to unsworn falsification to authorities. Date:, J =! ` VW I ' l r? ??- Laurie Gumby, Plaintiff n LAURIE GUMBY, V. Plaintiff MARCUS GUMBY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Complaint in Divoorce upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Marcus Gumby/Inmate Cumberland County Prison 1101 Claremont Road Carlisle, Pennsylvania 17013 Respectfully submitted, Rominger & Associates Date: March 13, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court I.D. 9 81924 Attorney for Plaintiff LAURIE GUMBY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARCUS GUMBY, NO. 07 - 1467 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO AMEND DIVORCE COMPLAINT TO THE PROTHONOTARY: Please amend the above captioned matter to include sections 3301C and 3301D of the Divorce Code. Date: t C7 Respectfully submitted, Rominger & Associates Karl . Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff LAURIE GUMBY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARCUS GUMBY, : NO. 07 - 1467 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, do hereby certify that I served a copy of the Praceipe to Amend Divorce Complaint upon the following by depositing same in the United States mail, certified, with return receipt, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Marcus Gumby/GZ2540, pro se SCI-Albion 10745 Route 18 Albion, Pennsylvania 16475-0001 Date: q//&//,) Respectfully submitted, Rominger & Associates Karl . Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff LAURIE GUMBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARCUS GUMBY, NO. 07 - 1467 CIVIL TERM Defendant IN DIVORCE 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. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or around July 25, 2006, and have continued to live separate and apart for a period of at least two 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. § 4904 relating to unsworn falsification to authorities. Date:_ 3 . /0 4uw june Gumby/Plaintiff LAURIE GUMBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARCUS GUMBY, : NO. 07 - 1467 CIVIL TERM Defendant : IN DIVORCE 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 notice to me, and I shall be unable thereafter to file any economic claims. 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. § 4904 relating to unsworn falsification to authorities. Date: Marcus Gumby, Defendant NOTICE: 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. vs Case No. V~ ~~p~ _ ,.-° ~„ ~_ Statement of Intention to Proceed x,:_.- ~~ - =- ~.. To the Court: ~~'`'` II ,w, tT:. - l~(~r ` -'~~ intends to proceed with the above captio~~~natter 1~' \ 1. u 11'' ~- ~----~ ._ _ _ .. Print Name r (1x-~ t/.~('S1f~t Sign Name ~ • '~" ~~~~~ Date: Q f'Q Attorney for ~~'~„ Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. I. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. lI Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. ARer giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Ru1e230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. [n such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. e~ ~..t ~6~ ~' .. -~ ~:> r "1k SR, r ILL ?-bi? !ll 1 2 P 4• ti 3 LAURIE GUMBY,t`}; yr t,tl E COURT OF COMMON PLEAS OF Plaintiff r x , * BERLAND COUNTY, PENNSYLVANIA . ??. . _..r ,?.?.` V. : CIVIL ACTION - LAW MARCUS GUMBY, : NO. 07 - 1467 CIVIL TERM Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 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. 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 notice to me, and I shall be unable thereafter to file any economic claims. 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. § 4904 relating to unsworn falsification to authorities. Date: Marcus Gumby, Defe ant NOTICE: 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. 11 LAURIE GUMBY, Plaintiff V. MARCUS GUMBY, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 07 - 1467 CIVIL TERM : IN DIVORCE RETURN OF SERVICE On October 1, 2010, at 9:15 a.m., Matthew Psillas, personally served upon Marcus Gumby at SCI-Albion, 10745 Route 18, Albion, Pennsylvania 16475, the Praecipe to Reinstate Complaint, Praecipe to Amend Divorce Complaint, Plaintiff's Affidavit Under Sections 3301(d) of the Divorce Code, and Counter Affidavit Under Section 3301(d) of the Divorce Code. An Affidavit of Service signed by Matthew Psillas is attached hereto. Respectfully Submitted, Rominger & Associates Date: / / o Karl-E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 81924 Attorney for Plaintiff -w 9 ? 7 ,? T3 -- ?? AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania County of Cumberland Common Pleas Court Case Number. 07-1467 Plaintiff: Laurie Gumby vs. Defendant: Marcus Gumby For Karl Rominger Rominger & Associates Received by Pennsylvania Professional Process Svc. to be served on Marcus Gumby, SCI-ALbion, 10745 Route 18, Albion, PA 16475. 1, R1i9't9i. eW RJ f , being duly swom, depose and say that on the L_ day of.6Cj,0_4%_ , 20jjQ at m., executed service by delivering a true copy of the Praecipe to Amend Divorce Complaint, Counter A"vii Under Section 3301(d) of the Divorce Code, Prose" to Reinstate Complaint, Affidavit Under Section 3301 (D) of the Divorce Code in accordance with state statutes in the manner marked below: INDIVIDUAL SERVICE: Served the within-named person. SUBSTITUTE SERVICE: By serving as () NON-SERVICE: For the reason detailed in the Comments Below () OTHER COMMENTS: i certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. Subscribed and Sworn to bpfore me on the f day 40--CESS SERVER # Of Cxi? 0454 , AA 0 by the affiant who is Appointed in accordance ZRy"PUBLIC (mown to me. with State Statutes Pennsylvania Professional Process Svc. 48 W. High St. P.O. Box 1148 EMILLCREEK OTARIAL SEAL Carlisle, PA 17013 NDA A CIOTTI (800) 883_2341 Notary Public Our Job Serial Number. 2010000367 TWP. ERIE COUNTY ion Expires Jun 11. 2014 6IM2005Dethbow ssrvkn Im Pmas S~9ToolmV5.5i V. I t ?dv?Isn=ir 12 Pt1 3• !.a i1 ,i Ai il?tt%. P'•.t wt ' i ,1"'" -.1 LAURIE GUMBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARCUS GUMBY, : NO. 07 - 1467 CIVIL TERM Defendant : IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under § 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: October 1, 2010, was served on Defendant by Private Process Service, a return of service with the Affidavit of Service is being filed simultaneously with this Praecipe. 3. Related claims pending: None. 4. (1) Date of execution of the Plaintiff's Affidavit required by §3301 (d) of the Divorce Code: December 29, 2009; (2) Date of filing and service of the Plaintiff s Affidavit upon the Respondent: Filed December 29, 2009, and served June 30, 2010, by Private Process Service. (3) Counter Affidavit under Section 3301(d) signed by Defendant on October 5, 2010, raising no claims, is being filed simultaneously with this Praecipe. 5. Date and manner of service of the Waiver of Notice to file praecipe to transmit record, a copy of which is attached: October 15, 2010, via first class mail attached hereto. Respectfully Submitted, Rominger & Associates Date: November la, 2010 . Karl E. Rem" inger, Esquire 155 Hanover Street Carlisle, Pennsylvania 17013 Supreme Court ID # 81924 (717) 241-6070 Attorney for Plaintiff TROMINGER & Ass®CIATES Attornevs at Law Karl E. Rominger Michael O. Palermo, Jr. Eric R. David Vincent M. Monfredo October 15, 2010 Marcus Gumby/GZ2540 SCI-Albion 10745 Route 18 Albion, Pennsylvania 16475-0001 RE: Gumby v. Gumby Docket No.: 07-1467 - In Divorce Dear Mr. Gumby: Enclosed please find a Notice of Intention to Request Entry of Divorce Decree for the above referenced matter. Should you have any questions, you should consult an attorney of your own choosing. Sin2=re KER/tlp Enclosure cc: Laurie Gumby (w/Enclosure) 155 South Hanover Street, Carlisle, Pennsylvania 17013 - Tel: (717) 241-6070 - Fax: (717) 241-6878 www.romingerlaw.com ADVOCACY - ADVICE *ANSWERS LAURIE GUMBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARCUS GUMBY, : NO. 07 - 1467 CIVIL TERM Defendant : IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Marcus Gumby, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or after October 21, 2010, 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 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. Pennsylvania Bar Association Lawyer Referral Service 1-800-692-7375 (PA only) or 1-717-238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Laurie Gumby V. Marcus Gumby IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-1467 DIVORCE DECREE AND NOW, //a geed L- 23 , -?2-0 la , it is ordered and decreed that Laurie Gumby , plaintiff, and Marcus Gumby , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") None. By the Court, Attest: J. Prothonotary copy =nl mr;?rq ell. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Laurie Gumby Plaintiff : FILE NO. 1467 52007 VS. IN DIVORCE Marcus Gumby Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 23rd day of November, 2010 hereby elects to resume the prior surname of Laurie Smith and gives this written notice pursuant to the provisions of 54 P.S. 704. /71iAlI L DATE: jai to I ` ` tgnature S ature of name being resumed COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND On the day of CQ, 20-JJ?L, before me, a Notary Public, personally appeared the above afffant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and cial seal. COMMONWEALTH OF PENNSYLVANIA ,Q NotaftSeal Notary Public Tww ile L Peters, Notary Public Cadisle Bm, Cunbertand Cou* W Catxnission E)ires Sept. 9, 2011 Member. Pennsylvania Association of Notaries OF T FILED-OFFICE 2010 DEC -6 PM 3= 52 CUM RLAND COUNTY PNSYLVANIA ?-?as3 Q.? asa??a