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HomeMy WebLinkAbout03-5341KELLY R. GORMAN, Plaintiff JEFFERY E. GORMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. :003 CIVIL ACTION - 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 will proceed without you and a decree in divorce or ~amulment may 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 C. ourthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFOI(E A DIVORCE 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, Pennsylvania 17013 (717) 249-3166 5 KELLY R. GORMAN, Plaintiff JEFFERY E. GORMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- / CIVIL ACTION - DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Kelly R. Gorman, by her attorney, Laguna Reyes Maloney, LLP, and represents as follows: 1. Plaintiff, Kelly R. Gorman is an adult indilvidual who currently resides at 3478 Sullivan Street, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, Jeffery E. Gorman, is an adult individual who currently resides at 3478 Sullivan Street, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married in Perry County, Pennsylvania on May 2 l~t, 1994. 5. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since September 2nd, 2003 and continue to live separate and apart as of the date of filing this Complaint. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. 6. There have been no prior actions of divorce: or for annulment between the parties. 7. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. Plaintiff and Defendant are both citizens of the United States. 9. Plaintiff has been advised of the availability of marriage counseling and of the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff waives the right to request that the Court require the parties to participate in counseling prior to a Divorce iDecree being issued by the Court; WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter a Decree of Divome. Respectfully submitted, Roger R~jLaguna, Jr~ EsqUir~- Attorney for Plaintiff Supreme Court I.D. No.: 75900 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233.-5292 VERIFICATION I verify that the statements made in the foregoing document(s) are tree and correct to the best of my knowledge, information and belief. I understand that false statements made herein may subject me to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. y R. Gorman LAGUNA REYES MALONEY, LLP A'I-rORNEY FOF~ PLAINTIFF KELLY R. GORMAN, Plaintiff § IN THE COURT OF COMMON PLEAS OF § CUMBERLAND COUNTY, PENNSYLVANIA v. § NO. 2003 - 5341 CIVIL TERM JEFFERY E. GORMAN, § CIVIL ACTION - DIVORCE Defendant § ACCEPTANCE OF SERVICE I accepted service of the Divorce Complaint under Sections 3301 (c) or 3301 (d) of the Divorce Code, filed in the above-captioned matter, via regular first-class U.S. mail on October 11th, 2003. Mechanicsburg, PA 17050 EXHIBIT A KELLY R. GORMAN, Plaintiff ; V. JEFFERY E. GORMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003 - 5341 CIVIL TERM CIVIL ACTION - DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER § 3301(c) OF THE DIVORCE CODE A ComFlaint iii Divorce under Section 33C i(c) of the Divorce Code was filed on October 8~, 2003. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in thi§ affidavit are tree 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 Kelly R. Gorman EXHIBIT B KELLY R. GORMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JEFFERY E. GORMAN, Defendant NO. 2003 - 5341 CIVIL TERM CIVIL ACTION - DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND 3301(d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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. /- 3/-o f Date Kelly R. Gorman KELLY R. GORMAN, Plaintiff Vo JEFFERY E. GORMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 5341 CIVIL TERM CIVIL ACTION ~ DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER § 3301(c) OF THE DIVORCE CODE. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 8th, 2003. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. I consent to the entry of a final decree of divorce after 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. §4904 relating to unsworn falsification to authorities. Date KELLY R. GORMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA JEFFERY E. GORMAN, Defendant NO. 2003 - 5341 CIVIL TERM CIVIL ACTION - DIVORCE DEFENDANT'S WAIVER OF NOTICE OE INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND 3301(d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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. Date KELLY R. GORMAN, Plaintiff JEFFERY E. GORMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 5341 CIVIL TERM CIVIL ACTION - DIVORCE _PRAECIPE TO TRAN~SMIT RECORD_ TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry ora divorce decree: Ground for Divorce: irretrievable breakdown under Section 3301(c). Date and Manner of Service of the Complaint.. October 11 t~, 2003, via regular first-class U.S. mail (see Acceptance of Service attached hereto as Exhibit A). Date of Execution of the Affidavit of Consent Required by Section 3301(c) of the Divorce Code: by Plaintiff on January 31 st, 2004; by Defendant on January 31 st, 2004 (Exhibit B). Related Claims Pending.. no other marital claims pending. Notice of Intention to Request Entry of Divorce Decree.. waived by Plaintiff on January 31st, 2004 and by Defendant on January 31 st, 2004 (Exhibit B). ~ Attorney for Plaintiff-/ ' ~ Supreme Court I.D. No. 78075 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Kelly R. Gorman, Plaintiff VERSUS Jeffrey E. Gorman, De~endant~ N o. 2003 5341 DECREE IN DIVORCE DECREED THAT AND Kelly R. Gorman Jeffre/ E. 8orman ARE DIVORCED FROM THE BONDS OF MATRIMONY. -, PLAINTIFF, , DEFENDANT, 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; BY ATTEST: J~~~T~DTHONOTARI'