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Home My WebLink About04-0159KENNETH F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff I.D. ~69383 TONY GINDER, Plaintiff v. CINDY L. GINDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. d3z,/~ oL : : CIVIL ACTION - LAW : 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 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, One Courthouse Square, Carlisle, PA 17013. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff TONY GINDER, Plaintiff CINDY L. GINDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. Oq- ISq : : CIVIL ACTION - LAW : DIVORCE COMPLAINT IN DIVORCE COUNT I Request for a No-fault Divorce Under ~3301(c) of the Domestic Relations Code Curtis Drive, 2. Plaintiff is Tony Ginder, who currently resides at 88 East Berlin, Adams County, PA 17316. Defendant is Cindy L. Ginder, who currently resides at 2786 York Road, Gettysburg, Adams County, PA 17325. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 16, 1988 in Cook County, Illinois. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. Defendant is not a member of the armed services. WHEREFORE, Plaintiff respectfully requests this Court to of Divorce pursuant to § 3301(c) of the Domestic enter a Decree Relations Code. DATE: 1/12/04 KE N~E H~F. LEWIS, ESQUIRE 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff TONY GINDER, Plaintiff CINDY L. GINDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. DATE: CINDY L. ~NDER IN THE COURT OF COMMON PLEAS OF CUMBER.LAND COUNTY, PENNSYLVANIA Vs : File No. \ Defendant : _. IN DIVORCE NOTICE TO RESUME PRIOR SUI~NAME Notice is hereby given that the Plaintiff/defendant in the above matter, [select one l~y marking "x"] fi( prior to the entry of a Final Decree in Divorce, or __ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of (~)l?~_f'~ , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. (~,~gnature ~ignaturelof n~ne being resumed CO OSW ra OF PE S VX¥ ) COUN OF m _ _Od On the ~ day of X-~cc~ ,200~ before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and aclmowledged that he / she executed the foregoing for the purpose therein contained. In Wimess Whereof, I have hereunto set my hand hereunto set my hand and official seal. NOTARIAL SEAL CLAUDIA A BREWBAKER, NOTARY PUBLIC Cariisle Boro, Cumberland County My Commission Expires April 4, 2005 Notary Public KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff TONY GINDER, : Plaintiff : : v. : : CINDY L. GINDER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-159 Civil Term CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on January 13, 2004. 2. The marriage of Plaintiff and Defendant irretrievably broken and ninety (90) days have elapsed from date of the filing and service of the Complaint. is the CINDY L.~ GINDER 3. I consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. 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. KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff TONY GINDER, Plaintiff : IN THE CO~T OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 04-159 Civil Term : : CIVIL ACTION - LAW : DIVORCE CINDY L. GINDER, Defendant WAIVER OF NOTICE OF INTENTION ~O REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 1. I consent to 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. 3. I understand that I will not be divorced until a 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. 4. I verify that the statements made in the foregoing document 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. Dated' 4/~)0~ ~ ~ ~ CINDY L. GINDER KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff TONY GINDER, : Plaintiff : V. : : CINDY L. GINDER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-159 Civil Term CIVIL ACTION - LAW DIVORCE after service decree. AFFIDAVIT OF CONSE~ 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on January 13, 2004. 2. 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 in Divorce of notice to intention to request entry of the 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. KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff TONY GINDER, Plaintiff : IN THE CO~T OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 04-159 Civil Term : : CIVIL ACTION - LAW : DIVORCE CINDY L. GINDER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UND~IR SECTION 3301 (C) OF THE DIVORCE ~ODE 1. I consent to 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. 3. I understand that I will not be divorced until a 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. 4. I verify that the statements made in the foregoing document 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. TON~Y G~ND ~R TONY GINDER, Plaintiff vo CINDY L. GINDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-15!) Civil Term CIVIL ACTION - LAW DIVORCE PRAECIPE TO TRANSMIT RECO~ 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 Section X33/~ 3/~ of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service signed January 15~ 2004; filed February 3, 200~. 3. Date of execution of the Affidavit of Consent required by Section 3301{c) of the Divorce Cods and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on 4/22{04; by the Defendant on 4/2?/04; all filed contemporaneously with this Praecipe. 4. Related claims pending: NONE, no economic issues requeste~ in Com lalnt. DATED: 4/30/04 KE~ET~ F. LEWIS, ES~. Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF curvIBERLAND COUNTY STATE Of TONY GTNDER VERSUS CINDY L. GINDER PENNA. NO. 04-159 Civil Term DECREE IN DIVORCE AND NOW, DECREED THAT TONY GINDER 2004 AND CINDY L. GINDER ARE DIVORCED FROM THE BONDS OF MATRIMONY. , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTrON FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; N/A BY THE /C~,~)URT: ~ / ATTES/I /,') PrOtHONOtARY