HomeMy WebLinkAbout08-6036
Tanya M. Gross IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
v• N0.08- (003(0 CIVIL TERM
Joseph M. Gross
Defendant 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
a
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, Cumberland County Courthouse, 1 Courthouse Square, 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 THI5 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
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
a
Tanya M. Gross
Plaintiff
v.
Joseph M. Gross
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
N0.08- L ~ ~~ CIVIL TERM
IN DIVORCE
COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE
1. Plaintiff is o rv~ ~coss ,who currently resides at
420{ Allent ~:d CarY.o N,11 t~A \'lC1\1
Cumberland County, Pennsylvania.
2. Defendant is ~~sQ ~c~« ,who currently resides at
4Zc~r=1 ~4ue•~ ~cl Ga~,o Nett ~A -~011
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on Vie. ~, 2~F, 2003 at
New ~&~,~ !d /'~i4 ~
5. The marriage is irretrievably broken, and the parties separated on
6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
given in Paragraph 2 above.
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
o~ 2le ~ o1L`c~T(
Date Plaintiff ro Se
I, anus -~r~~ ,verify that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities as
provided in 18 Pa. C.S. §4904.
Se~. 2~, zao8
Date: Plaintif ro Se
Assisted by:
Michael A. Hynum, Esq.
Hynum Law Office
X2608 North 3rd Street
)F-Iarrisburg, PA 17110
(717) 774-1357
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Tanya M. Gross
Plaintiff
v.
Joseph M. Gross
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
N0.08- (o p3(p CIVIL TERM
IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Tanya M. Gross, Plaintiff, to proceed in forma au ris.
I, Michael A. Hynum, attorney for the party proceeding in forma au eris, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the
P~Y•
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'chael A. Hynum, Es ui
Attorney for Plaintiff
Hynum Law Office
2608 North 3rd St.
1Harrisburgy PA 17110
(717) 774-1357
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David D. Bueff
Prothonotary
2kirkS. Sohonage, ESQ
solicitor
Wenee X Simpson
151 Deputy ftothonotary
Irene E. Morrow
2"d Deputy ftothonotary
office of the ftothonotary
Cumbe&tnd County, Tennsykania
QA" Z03? CIVILTERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R.C.P 230.2
BY THE COURT,
DAVID D. BUELL
PROTHONOTARY
One Courthouse Square • Suite 100 0 Cartiste, P.A 17013 • (717)240-6195 9 Eax (717 240-6573