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Home My WebLink About03-6663COLLEEN A. GLADFELTER, Plaintiff VINCENT J. GLADFELTER, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. CIVIL : 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 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 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 Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAW~fER'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 Countv Bar Association 2 Libertv Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 COLLEEN A. GLADFELTER, : Plaintiff : VINCENT J. GLADFELTER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION IN DIVORCE LAW COMPLAINT 1. The Plaintiff in this action is COLLEEN A. GLADFELTER, an adult individual, who currently resides at 5 Winding Hill Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant in this action is VINCENT J. GLADFELTER, an adult individual, who currently resides at 605 Wingert Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on May 6, 1989, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. -1- 7. The Plaintiff avers that no children have been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of di- vorce. I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 P.C.S. to authorities. ~4904, relating to unsworn falsification STOl & SHEKLETSKI Co~ ID %60251 P.O. Box E PA 17070 ,ne 717-774-7435 2orneys for Plaintiff -2- COLLEEN A. GLADFELTER, Plaintiff VINCENT J. GLADFELTER, Defendant IN THE COURT OF gOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-6663 CIVIL TERM : CIVIL ACTION LAW : IN DIVORCE APFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND ) SS: I, ELIZABETH B. STONE, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, VINCENT J. GLADFELTER, at 605 Wingert Drive, Mechanicsburg, PA 17055, by United States Certified Mail, postage prepaid, restricted delivery, on January 15, 2004, as evidenced by the attached 71 return receipts. SWORN TO AND SUBSCRIBED before me this ~)~ day of ~Z4~ , 2004. h ....... NOT~I~ S~L I ~E R. LUC~, N~ ~blic N~ C~i~ ~ro. ~d Co. C~mmiss~on F.~ir~ ~ 27, ~BETH STONE Law ~G~NICSB(.I~ P~ 170~ fl\div\lconsentaffidavit COLLEEN A. GLADFELTER, : Plaintiff : VINCENT J. GLADFELTER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6663 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CON:DENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on December 31, 2003, and served January 29, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety {90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's before a divorce is granted. I verify that the statements correct. I understand that false to the penalties of 18 Pa. C.S. ~ tion to authorities. Date fees or expenses if I do not claim them made in this affidavit are true and statements herein are made subject 4904 relating to unsworn falsifica- C~4fLEEN A. GLADFE , lalntlff' ' fl~div\lconsentaffidavit COLLEEN A. GLADFELTER, : Plaintiff : VINCENT J. GLADFELTER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-6663 CIVIL TERM CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on December 31, 2003, and served January 29, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety {90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees before a divorce is granted. I verify that the statements made in correct. I understand that false to the penalties of 18 Pa. C.S. ~ tion to authorities. Date or expenses if I do not claim them this affidavit are true and statements herein are made subject 4904 relating to unsworn falsifica- INcENT~ GL~~ Defendant COLLEEN A. GLADFELTER, Plaintiff VINCENT J. GLADFELTER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-66613 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE notice. 2. division of property, lawyer's before a divorce is granted. 3. I understand that I decree sent I consent to the entry of a final decree of divorce without I understand that I may lose rights concerning alimony, fees or expenses if I do not claim them will not be divorced until a divorce is entered by the Court and that a copy of the decree will be to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. to the penalties of 18 Pa. tion to authorities. B~te I understand that false statements herein are made subject C.S. ~ 4904 relating to unswozn falsifica- COLLEEN A. GLADFELTER, Plaintiff COLLEEN A. GLADFELTER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 03-6663 CIVIL TERM VINCENT J. GLADFELTER, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without lawyer's a divorce is granted. I understand that I will not be divorced until a divorce is entered by the Court and that a copy of the decree will be notice. 2. division of property, before 3. decree I understand that I may lose rights concerning alimony, fees or expenses if I do not claim them sent to me I verify that the statements correct. I understand that false to the penalties of 18 Pa. C.S. ~ tion to authorities. Date immediately after it is filed with the Prothonotary. made in this affidavit are true and statements herein are made subject ~oa~ ~.~za. tmng to unsworn ~al~ca VINC~T~J. GL~ELTER, Defendant fl\div\ltransmitpraecipe\7-97 COLLEEN A. GLADFELTER, Plaintiff VINCENT J. GLADFELTER, Defendant : IN THE CODRT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-6663 CIVIL TERM : : ACTION 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)) (~0~x~$X~$ of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: January 15, 2004, U.S. Certifi Mail, Return Receipt Requested, Restricted Delivery, postaqe prepaid 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: by Plaintiff June 8, 2004 June 8, 2004 ; by Defendant (b) (1) Divorce Code: (2) Date of execution of the affidavit reguired by ~ 3301(d) of the ; A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: NO CLAIMS RAISED 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of~ Notice in ~ 3301(c) the Prothonotary: Date Defendant's Waiv. er~f,Notice in ~ 3~1(c) Divorce~filed At/n~ ~AINTJ)(DEFENDANT) Divorce was filed with with IN THE COURT Of COiVIMON PLEAS COLLEEN A. GLADFELTER, Plaintiff VERSUS VINCENT J. GLADFELTER, Defendant OFCUMBERIANDCOUNTY STATE Of ~ PENNA. NO. 03-6663 CIVIL TERM DECREE IN DIVORCE AND NOW, , 2J~13~"~ , IT IS ORDERED AND DECREED THAT COLLEEN A. GLADFELTER , PLAINTIFF, AND VINCENT J. GLADFELTER , 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; BY ThE COURT: ~TT : J. )TARY