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HomeMy WebLinkAbout03-2707Gloria M Gates, Plaintiff : IN THE COURT OF COMMON PLEAS · . CUMBERLAND COUNTY, PENNSYLVANIA : NO. V. .. Thomas S Gates, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 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 the Cumberland County Courthouse, 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, PA 17013 (717) 249-3166 Gloria M Gates, Plaintiff Thomas S Gates, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. t~...2'7t~7 ~' .' : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Gloria M Gates, who currently resides at 191 Woods Drive, Mechanicsburg PA 17050. 2. Defendant is Thomas S Gates who presently resides at 191 Woods Drive, Mechanicsburg PA 17050. 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 October 27, 1991 in Cumberland County, PA. parties. There have been no prior actions for divorce or annulment between the 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint reference as though set forth in full. 10. are incorporated herein The marriage of the parties is irretrievably broken. by WHEREFORE, Plaintiff requests this Honorable Court to: a) enter a decree dissolving the marriage between Defendant; Plaintiff and Respectfully Submitted, Miller Lipsitt LL-,~/,,/,~ ~, James A ~iller, Esquire Attorney ~or Plaintiff 2157 MCket Street Camp,~ill, PA 17011 J37-~400 Gloria M Gates, Plaintiff Thomas S Gates, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I verify that the statements made in this Divorce 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. GI~ M Gates, Plaintiff Gloria M Gates, Plaintiff Thomas S Gates, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2707 Civil Term : : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, Thomas S Gates, Defendant in the above captioned matter do hereby on the date indicated below accept service of the divorce complaint filed by Plaintiff, Gloria M Gates, to the above term and docket. Thomas S G~tes, Defendant Gloria M Gates, Plaintiff Thomas S Gates, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2707 : CIVIL ACTION .. LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 9, 2003, and Defendant accepted service thereof on ,June 28, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree ~n Divorce after service of notice of intention to request entry of the decree. 4. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divome decree being handed down by the Court. 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.A. Section 4904, relating to unsworn falsificatioyc~authoritie,s. T~on~as S Gates Gloria M Gates, Plaintiff Thomas S Gates, Defendant : iN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2707 : CIVIL ACTION .. LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCF CODE 1. I consent to the entry of a final decree of divorce wit~hout 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 diivorce 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 irnmediately after it is filed with the prothonotary. I verify that the statements made herein in this affidavit are true.and correct. I understand that false statements are made subject to ~,~=/penalties of/18 Pa. C.S.A. Section 4904, relating to unworn falsification of author,~t~,~/ Date: ....~ --~ ~ ,~" ~ Thomas S Gates Gloria M Gates, Plaintiff Thomas S Gates, Defendant : iN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2707 : : CIVIL ACTION .. LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 9, 2003, and Defendant accepted service thereof on ,June 28, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 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.A. Section 4904, relating t7nsw,~e/~.ation to aut~;x~i Date,'_~ ~o~G~ ,~/~?'~ Gloria M Gates, Plaintiff V= Thomas S Gates, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2707 : CIVIL ACTION -. LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c)OF THE DIVORCI-' CODE 1. I consent to the entry of a final decree of divorce witlhout 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 di~vorce is granted. 3. I understand that I will not be divomed until a divorce decree is entered by the Court and that a copy of the decree will be sent to me irnmediately after it is filed with the Prothonotary. I verify that the statements made herein in this affidavit are true and understand that false statements are made subject to the penalties~l'8~ Section 4904, relating to unworn falsificati.~.~uthorities. / Dat¢ . ,.. t,, .11 correct. I =a. C.S.A. Gloria M Gates, Plaintiff Thomas S Gates, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2707 : : CIVIL ACTION. LAW : 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. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner service of the Complaint: Defe,r~dant accepted personal service of a CERTIFIED COPY OF THE COMPLAINT IN DIVORCE on June 20, 2003 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: May 7, 2004 by Defendant: May 7, 2004 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: May 11, 2004 by Defendant: May 11 2004 Related claims pending: There are no related claims pending. Respectfully Submitted, Miller~ By: Jar~es"~ Miller, Esquire At~y for Plaintiff ~ 2157 Market Street Camp Hill, PA 170111 (717) 737-6400 IN THE COURT OF COIVIMON PLEAS Gloria M Gates Planitiff VERSUS Defendant OFCUMBERLAND COUNTY STATE Of ~~~. PENNA. N O. 03-2702 DECREE IN DIVORCE DECREED THAT Gloria ~ Catoc , PLAINTIFF, AND Thomas S Gates , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF BECORD IN THiS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; BY THE COUrt: ATTEBT/~/~~ ~ j. ~ ~L ~ PROTHONOTARY + + + + + + + +++ + + + + ++ ++ ++ + + + T