The URL can be used to link to this page

Home My WebLink About03-5167 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, Plaintiff VS. Deborah S. Gamble, Defendant Civil Action - Law 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 in divorce or annulment may be 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 the custody or visitation rights of your children. When the ground for 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, LAVVYER'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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, : No. Plaintiff : : Civil Action - Law VS. : In Divorce Deborah S. Gamble, : Defendant : COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE Plaintiff is Douglas K. Gamble who currently resides at 65 Diller Drive, Apartment 2, Shippensburg, Cumberland County, Pennsylvania, since October 15, 1997. 2. Defendant is Deborah S. Gamble who currently resides at 11398 Old Mill Road, 2nd Floor Apartment, Shippensburg, Franklin County, Pennsylvania, since July 1, 2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on September 7, 1991 in Middle Spring, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the ~arties. 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 of divorce. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (7:[7)-532-3270 I verify that the statements made in this Complaint are true and correct. ! understand that false statements herein are made subject to the penalties of Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /] Date: ~//~/~ D~i s~?/~~ ougas . Gamble IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, : No. 03-5167 Civil Term Plaintiff : : Civil Action - Law VS, : In Divorce Deborah S. Gamble, : Defendant : AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Deborah S. Gamble, of 11398 Old Mill Road, 2nd Floor Apt., Shippensburg, Pennsylvania, 17257, certified mail, return receipt requested on September 30, 2003 and was accepted on delivery by Deborah S. Gamble on October 2, 2003 as shown by the attached receipt. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this ~v~ day of October.~_,"O0' Notary Public My Commission Expires NOTARIAL SEAL DEBORAH WARREN, Notary Public Shippensburg, Cumberland County My Commission Expires Nov, 8, 2005~ · Complete items 1, 2, and 3. Aisc complete item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reverse so that we can return the card to you. · Attach this card to the Peck of the mailpiece, or on the front if space permits. 1, Arti~ Addressed to: B. R~ceived D. Isdeliva3 ~miteff 17 rlyes If YES, enter detivery address be~o~ ri No 4. Restricted Delivery? (E~-'tra Fee) for Merchandise IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, : No.03-5167 Plaintiff : : Civil Action- Law VS. : : In Divorce Deborah S. Gamble, : Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce alter service of notice of intention to request entry of the decree. 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. Section 4904 relating to unsworn falsification to authorities. Date: Deborah S. Gamble IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, Plaintiff VS. Deborah S. Gamble, Defendant : No.03-5167 : Civil Action -- Law : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without 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 divorce is granted· 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 immediately alter it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. Date: /-/~'~/~/ Deborah S. Gamble IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, : No.03-5167 Plaintiff : : Civil Action - Law VS. : In Divorce Deborah S. Gamble, : Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 2003 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce a~cer service of notice of intention to request entry of the decree. 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. Section 4904 relating to unsworn~T~fication to authorities/ Date:/77-/~'- 0~' ~ugl~'sJK. Gamble ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble, Plaintiff VS. Deborah S. Gamble, Defendant No.03-5167 Civil Action ,- Law In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without 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 divorce is granted. 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 immediately after it is filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Douglas K. Gamble : No. 03-5167 Civil Term Plaintiff : : Civil Action - Law VS. : : Deborah S. Gamble : 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. Ground for divorce; irretrievable breakdown under 3301(c) of the Divorce Code. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on September 30,2003 and was accepted October 2,2003. An Affidavit of Service has been filed. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff.lanuary 19, 2004; by Defendant .lanuary 17, 2004. 4. Related claims pending: None. Plaintiff's Waiver of Notice was signed on January 19, 2004 and is being filed herewith and Defendant's Waiver of Notice was signed January 17 2004 and is being filed herewith. H. Anthony Adams, E~ir'F~ Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 1N THE COURT OF COiVIIVION PLEAS OF CUMBERLAND COUNTY STATE OF Douglas K. Gmmb]m Plaintiff VERSUS Deborah S. Gamble Defendant PENNA. NO. 03-51,q7 O, ivil Term DECREE iN DIVORCE AND NOW, DECREED THAT Douglas K. Gamble AND Deborah S. Gamble ?C)(~/,, IT I$ ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. The COURT RETAINS JURISDICTION Of THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE bY THE COURT:/ AT~//~~ROTHONOTA:Y' + . + +