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HomeMy WebLinkAbout99-04255N 3 'N Ef \1 A? Af .. r?7 i L n a a ?l Al CHARLES W. GENTILE, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION-LAW WOUTERA J. M. GENTILE, : NO. 99- 4a2ss CIVIL TERM 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 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. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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 Cumberland County Courthouse Carlisle, Pennsylvania 717/240-6200 CHARLES W. GENTILE, Plaintiff, VS. WOUTERA J. M. GENTILE, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 99- `PY5 CIVIL TERM IN DIVORCE COMPLAINT Plaintiff Charles W. Gentile, by her/his attorney, Broujos & Gilroy, P.C., sets forth the following: 1. Plaintiff Charles W. Gentile is an adult individual who currently resides at 113 Walton Avenue, Carlisle, PA 17013. 2. Defendant Woutera J. Gentile is an adult individual who currently resides 105 Claridon Place, Carlisle, PA 17013. 3. Plaintiff and Defendant have been bona tide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The parties were married on September 21, 1972, in Treebeek, The Netherlands. 5. In accordance with Section 3301(c) of the Divorce, the marriage between the parties is irretrievably broken. 5. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 6. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. July 9,1999 Nitorney for Plaintiff Supreme Court I.D. No. 06268 BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717)243-4574 or(717)766-1690 I verify that the statements made in this pleading 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 unswom falsification to authorities. Charles W. Gentile July 9, 1999 4- c Z N r <? '? Tr LL'; slL, LL D9 C7% G cn U CHARLES W. GENTILE, Plaintiff VS. WANDA J. M. GENTILE, Defendant TO THE PROTHONOTARY: M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.99 - 4255 CIVIL TERM IN DIVORCE PRAECIPE Please enter my appearance as counsel of record for the above-captioned Defendant. Dated: r t I l q Respectfully submitted, es J. y Esquire iberty L ft E. Lille Avenue Carlisle', A 17013 17)243-7922 cc: John H. Broujos, Esq. 1 -7 ? D O C C r Om 4 r 0 ?. Y N C m T. ? a E. s fJ `=?G A C. 0 E. 0 N * Fu 0 O o o' 3 ?> > m CHARLES W. GENTILE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW WOUTERA J.M. GENTILE, Defendant No. 99-4255 CIVL TERM ORDER OF COURT i' AND NOW, this 22nd day of October, 2002, upon consideration of a letter from John H. Broujos, Esquire, Plaintiff's counsel, requesting that the case be stricken from the purge list, and there being no objection presented in open court, the request is granted, the case is stricken from the purge list, and the case shall remain active. /John H. Broujos, Esquire For the Plaintiff Woutera J.M. Gentile 105 Claridon Place Carlisle, PA 17013 Defendant Court Administrator wcy V -161 By the Court,