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Home My WebLink About08-4676 Heidi Gutshall, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall, Defendant : NO. 08- `? U 7 G CIVIL TERM 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled' individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Heidi Gutshall, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall, Defendant : NO. 08- q4 7 ?• CIVIL TERM DIVORCE COMPLAINT The plaintiff, Heidi Gutshall, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. 4§3301(,cc) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Heidi Gutshall , who has resided at 279 Plaza Drive Boiling Springs, Cumberland County, Pennsylvania 17007 since February 2005. 2. Defendant is Chad Gutshall who has resided at 153 Ligonier Street, New Florence Westmoreland County, Pennsylvania 15944 since June 2005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 1, 2000 in Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since May 14, 2007. 6. Chad Gutshall filed action for divorce on March 18, 2005 in Potter County, docket number 2005-1011, but it was terminated on January 30, 2008 for lack of activity. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. icole Berman Certified Legal Intern yZc,?O?r? ROBERVf E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date 00 8 Plaintiff /-C/ e . o? ?"- c Heidi Gutshall LLL Y- v ?,M 'mil cri Heidi Gutshall, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall Defendant : NO. 08- Y 94 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Heidi Gutshall, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date klm Nicole Berman Certified Legal Intern "', ? "_ 4! i?_ ? Z " %. ROBE . RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 r?.) rra `__ -' - e,_? ;_ ..r.? ? :? - u% ';?°g Tf- ?? ?? ?? .? ? ?. ?.? ?.i? Heidi Gutshall, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Chad Gutshall, Defendant NO. 08 - 4676 CIVIL TERM CERTIFICATE OF SERVICE I, Nicole Berman, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Chad Gutshall, residing at 134 Ligonier Street, New Florence, Pennsylvania 15944, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Chad Gutshall, on the 15th day of August 2008, as evidenced by the attached green card. Ndole Berman Certified Legal Intern Anne a ona d-Fox, Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 1./ . ,, ¦ Complete items 1, 2, and 3. Also complete Rem 4 ff Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the rack of the mailpiece, or orv the front ff space permits. 1. Article Addressed to: 7e,w ?/d2?cR P?1 A. X alrr ? Agent ? Addre B. by (PRnW Nam) C. Data of Del CeeV' K t fit 4 ?f S -t? D. Is delivery address dmererrt from stern 1? ? Yes If YES, enter delivery address below: ? No 3. Type _pvlce certined Mall ? Express Mall ? Registered 45f Retum Receipt for Merchandiss ? Insured mail ? C.O.D. 4. Restricted Delkwy? (Extra Fee) If Y. 7008 1140 0001 6163 6013 102595-024A-1540: ry _: x} µ co eFY ,, i Heidi Gutshall, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall, Defendant : NO. 08 - 4676 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on August 4, 2008. Defendant was properly served with the Complaint on August 15, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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 a OO $ / ere 6`ds aw Heidi Gutshall, Plaintiff v Heidi Gutshall, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall, Defendant : NO. 08- 46--?;, '(010CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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. 3. 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. §4904 relating to unworn falsification to authorities. Date Dec (o, Joog Heidi Gutshall, Plaintiff h +^v ?' ?° t { ??' t? ?' ,r..: : j .? ? C..;7 ^?i -. Heidi Gutshall, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall, Defendant : NO. 08 - 4676 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on August 4, 2008. Defendant was properly served with the Complaint on August 15, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. 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 V J?)' Chad Gutshall Defendant °? ? a e ?'? r P"t c`T°1 ' ? "??`} t`?? ? ?;} : .?-; '?? .N?i"C"' '? : G .a ' ..?' Heidi Gutshall, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Chad Gutshall, 416 7? Defendant : NO. 08-467/ CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &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. 3. 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. §4904 relating to unsworn falsification to authorities. Date Chad Gutshall, Defendant 1 r. a Lt.7 f, . r5 _ r^=} C:l Heidi Gutshall, Plaintiff V. Chad Gutshall, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE AND CUSTODY No. 08-4 5 T CIVIL TERM 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. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Chad Gutshall on August 15, 2008. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff- December 7, 2008; by defendant- December 9, 2008. 4. Related claims pending: none 5. Date plaintiff s Waiver of Notice was filed with the Prothonotary: December 9, 2008. Date defendant's Waiver of Notice was filed with the Prothonotary : December 12, 2008. Dat Nicole Berman Certified Legal Intern Anne a -Fox, Esq. Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff r-? r +g C? t ? ' ? ? .. . 5 ,. s -'ilk.: ., ? ;- _ ;'' ;' - ,?^ . T? % . . - IN THE COURT OF COMMON PLEAS OF Heidi GUtShall CUMBERLAND COUNTY, PENNSYLVANIA V. Chad Gutshall NO. 08-4676 DIVORCE DECREE -'lo. 40 yC4 .M . R/ dW91 AND NOW, , it is ordered and decreed that Heidi Gutshall , plaintiff, and Chad Gutshall , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") None. the Court, Attest: J. Prothonotary -eel, i7 ,,v