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HomeMy WebLinkAbout09-0092V M JAMES E. GILLILAND, Plaintiff v. JOANN M. GILLILAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. t~ 9 ' ~ D q ~- c ~ , ~ 'f ciM. CIVIL ACTION -LAW IN DNORCE 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 ,. OM ~' LITLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 JAMES E. GII.LILAND, Plaintiff v. JOANN M. GILI..ILAND, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. ~q-ao4~ CN.~~ ~«~ CIVIL ACTION -LAW IN DIVORCE 1. Plaintiff is James E. Gilliland, who currently resides at 2007 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Joann M. Gilliland, who currently resides at 2007 Douglas Drive, Carlisle, Cumberland County, Pennsylvania.. 3. The 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 February 13, 2002, in Cumberland County, Pennsylvania. COUNT I -DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, ~~ 3301 (a) (3), 3301(a) (6), 3301 (c) and 3301(d), in that: a. By cruel and barbarous treatment, endangered the life or health of the injured and innocent spouse. b. Offered such indignities to the innocent and injured spouse as to render that spouse's condition intolerable and life burdensome. c. Plaintiff and Defendant have lived separate and apart since January 9, 2009, and continue to do so. 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 such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs one (1) through nine (9) of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from February 13, 2002, until January 8, 2009, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. De'rE t I ~ ~Oq Respectfully submitted, Aao~r ~ K~TVr.AxIS, L.L.P. ~GC . Michelle L. Sommer, squire Supreme Court ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaint I, James E. Gilliland, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. X4904 relating to unsworn falsification to authorities. Date ~ Q JAMES E. GILLILAND yQ~ (may T =^^ w ~/ ~.,! ~ / 1 ~.,~ W 1 d d O O, "~e ~ v P ~ f ~- ~ ~ v a e~ t+ c~ '`~ ~-~ ~~ ~~ :~ ~ r~ 4l I'.. '+~~ _T l ~ „~ t ~, 4 ~~ ~ i~'~ _ r..c.J _'C"