HomeMy WebLinkAbout03-6232
PATRICIA A. GORDON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
. ,2.4 A
; NO. 02 -/, CIVIt TERM
RICHARD J. GORDON,
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
will proceed without you and a decree in divorce or annulment 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle,
Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER 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 A venue
Carlisle, Pennsylvania 17013
(717) 249-3166
;-----
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: oj- {p:J..jJ.-
: NO. CIVIL TERM
PATRICIA A. GORDON,
Plaintiff
RICHARD J. GORDON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
1.
Plaintiff is Patricia A. Gordon, an adult individual, currently residing at 836
CAlhf fl.-II J fA
/7011
Defendant is Richard J. Gordon, an adult individual, currently residing at 660 Boas
Meadow Lane, Hampden Township, Cumberland County, Pennsylvania.
2.
Street, Apt. 2018, Harrisburg, Dauphin County, Pennsylvania 17102.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing of this
complaint.
4. Plaintiff and Defendant were married on June 3, 1972 in Chalk Hill, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the parties.
6. The Defendant is not a member of the Armed Forces of the United States of
America, or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the right to
request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff
does not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since December 31, 2000 and continue to
live separate and apart as of the date of this Complaint.
10. The parties' marriage is irretrievably broken.
11. Plaintiff desires a divorce based upon:
a. The fact that Defendant has offered such indignities to the person of the
Plaintiff, the innocent and injured spouse, as to render her condition
intolerable and life burdensome, and this action is not collusive or, in the
alternative,
b. It is believed that Defendant will after ninety (90) days from the date of the
filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce.
COUNT II
ALIMONY. ALIMONY PENDENTE LITE. AND COUNSEL FEES
12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their
full text.
13. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs
during the pendency ofthis divorce action, and through its resolution.
14. Plaintiff is without sufficient property and otherwise unable to financially support
herself and children.
15. Defendant is presently employed and receiving substantial income and benefits and
is able to pay for counsel fees, expenses and costs, as well as alimony, and alimony pendente lite for
Plaintiff.
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring
Defendant to pay for Plaintiff's counsel fees, expenses, and costs as well as providing for payment
of an appropriate alimony and alimony pendente lite for Plaintiff.
COUNT III
EQUITABLE DISTRIBUTION
16. Paragraphs 1 through 15 are incorporated herein by reference as if set forth in their
full text.
17. Plaintiff and Defendant are joint owners of real property located at 836 Meadow
Lane, Hampden Township, Cumberland County, Pennsylvania, as well as various items of personal
property, including pension and retirement accounts, and furniture, and household furnishings
acquired during their marriage which are subject to equitable distribution.
18. Plaintiff and Defendant have incurred debts and obligations during their marriage
which are subject to equitable distribution.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing
the parties' property and equitably apportioning the debts incurred by the parties.
Respectfully Submitted,
2.'-1 JLl cJV Zoo?;;
Date
Q
ROBERT P. KLINE, ES
714 Bridge Street
Post Office Box 461
New Cumberland, P A 17070-0461
(717) 770-2540
Attorney for Plaintiff
VERIFICATION
I verifY that the statements made in the foregoing Divorce Complaint are true and correct. I
understand that false statements herein made are subject to the penalties of Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
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PATRICIAA. GORDON,
PLAINTIFF
VB.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-6232
RICHARD J. GORDON,
DEFENDANT
IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must
file a counter-affidavit within twenty (20) days after this affidavit has been served on
you or the statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 330 Ie d)
OF THE DIVORCE CODE
1. The parties to this action separated on or about 31 December 2000 and
have continued to live separately and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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 gpanted.
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: IDIl7/d::,
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lduv-vl t lJ~wJ
RICHAR J.' GORDON
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PATRICIA A. GORDON,
PLAINTIFF
vs.
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IN DIVORCE
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 03-6232
RICHARD J. GORDON,
DEFENDANT
AFFIDAVIT OF SERVICE BY CERTIFIED MAIL
AMY M. HARKINS, being duly Sworn according to law, deposes and says as follQws:
1. That she is an employee Qf Samuel L. Andes, attorney for the Defendant herein.
2. That on November 14, 2006, she delivered to the U.S. Postal Service in Lemoyne,
Pennsylvania, as certified mail (Receipt No. 7004 0750 0002 7282 3973) return receipt
requested, addressed to the Plaintiff herein, a true and correct copy of the 3301 (d) Affidavit
filed in the above-captioned action.
3. Said return receipt card is attached hereto as Exhibit A showing a date of delivery to
the Plaintiff on November 15,2006.
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Sworn to and subscribed
before me this Z I s+- day
of NOUN! B t'R, , 2006.
fi-~
Notary Public.
NOT~IIAL
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. Complete items 1,2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on the fr.Rnt if space permits.
1, Article Addn.iiSed to:
fbkic.i~A. QavJon
1ft AI \u1\1{tAJ) Drl ~
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~, ~ice Type
~ified Mail
o Registered
o Insured Mail 0 C.O.D.
4, Restricted Delivery? (Extra Fee)
Dyes
PS Form 3811, August 2001
7004 0750 0002 7282 3973
,
Domestic Return Receipt
102595-02-M-1540
EXHIBIT A
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PATRICIA A. GORDON,
PLAINTIFF
vs.
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)
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)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-6232
RICHARD J. GORDON,
DEFENDANT
IN DIVORCE
DEFENDA.l\1T'S COUNTER-AFFIDAVIT
UNDER SECTION 3301(D) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a)
V(b)
_(i)
V(ii)
2. Check either (a) or (b):
(a)
~)
I do not oppose the entry of a Divorce Decree.
.I oppose the entry of a Divorce Decree because
(check (i), (ii) or both):
The parties to this action have not lived separate and
apart for a period of at least 2 years.
The marriage is not irretrievably broken.
I do not wish to make any claims for economic relief. 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 wish to claim economic relief which may include
alimony, division of property, lawyer's fees or expenses
or other important rights.
I verify that the statements made in this Counter-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 autho~ities.
Date~ .~,jH i
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PATRICIA A. GORDON /
IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU
DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT
FILE THIS COUNTER-AFFIDAVIT.
NOTICE:
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