HomeMy WebLinkAbout99-03854Y; C I.
I
F,
Q
ci
a
i
DINEDA M. GILLON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 -S? IVIL TERM
JOHNNIE LEE GILLON,
Defendant : IN DIVORCE
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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counselling. A list of marriage counselors is available in the Prothonotary's Office 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.
Court Administrator - Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
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. You
must attend the scheduled conference or hearing.
James J. Kayer, Esquire
Attorney for Plaintiff
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
DINEDA M. GILLON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
NO. 99 -3)<XCIVIL TERM
JOHNNIE LEE GILLON,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) and 3301(d) OF THE DIVORCE CODE
COMES NOW, Plaintiff Dineda M. Gillon, through her attorney, James J. Kayer, Esquire and avers
as follows:
COUNT I - DIVORCE
1. Plaintiff is Dineda M. Gillon, an adult individual, whose current address is 420 Forbes Avenue,
Box 72, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Johnnie Lee Gillon, an adult individual, whose current home address is 793
Hamilton Court, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 25, 1997 in Sierra Vista, Cochise County,
Arizona.
5. There have been no prior actions of divorce filed in this matter.
6. Plaintiff is a member of the United States Armed Forces.
7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) and
Section 3301(d) of the Divorce Code.
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.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
/I /i
Liberty Loft
4 Li rty Ave
Cazl1e, PA 1
(717}) 243-792
Date: June 16, 1999
VERIFICATION OF PLEADINGS
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. The language of the document may, in part,
be the language of my counsel and not my own. I have read the statements made in this
document and to the extent that it is based upon information which 1 have given to my counsel,
it is true and correct to the best of my knowledge, information and belief. To the extent that the
contents of the statements are that of counsel, 1 have relied upon counsel in making this
Verification. 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: k 1999
r
Om
s T
N ?
r o
= m <D
y N N•
A m ? d
M
C4
O
.
< o
ti N
N
O Q
r N j
W C
tD
Kayer andSrown'
'
.,
A Professional Corporation
{`„ •.; Liberty Loft 4 E. Liberty Avenue • Carlisle PA 17041,
(717) 243-7922 ,
DINEDA M. GILLON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
NO.99 - 3854 CIVIL TERM
JOHNNIE LEE GILLON,
Defendant : IN DIVORCE
PRAECIPE FOR SETTLEMENT AND DISCONTINUANCE
TO THE PROTHONOTARY:
Please mark the Plaintiffs claim filed in the above referenced matter as discontinued, settled and
ended.
Respectfully submitted,
lL
James`J. Kaye l3sqtre
Dated: October 5, 1999
I ..
;- J
l I/1
Il
r
n m
N'? o d
CD
. y
A y A N 3
m O
?<
0) r o
N 7,? O W
K 0
W >
C
m