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Home My WebLink About09-0204IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT OF PENNSYLVANIA-CUMBERLAND COUNTY BRANCH Karen A. Gagnon, Plaintiff Civil Action -Law vs. James J. Gagnon, Defendant No. pq - l~;a~ In Divorce a v.m. NOTICE TO DEFEND AND CLAIM RIGHTS iv i l T~exw 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, 1 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, 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800.692-7375 (PA ONLY) or 717-238-6807 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. IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT OF PENNSYLVANIA-CUMBERLAND COUNTY BRANCH Karen A. Gagnon, Civil Action -Law Plaintiff vs. No. James J. Gagnon, Defendant In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff is Karen A. Gagnon, a sui juris adult, who currently resides at 4937 Gettysburg Road, Mechanicsburg, Cumberland County, Pennsylvania, since 2007. 2. The Defendant is James J. Gagnon, a sui juris adult, who currently resides in Bedford, New Hampshire, with a mailing address of 7 Colby Court, Suite 110, Bedford, NH 03310, since 2004. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 22, 1994 in Chambersburg, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff and Defendant have lived separate and apart for a period in excess of two (2) years, the last day of marital cohabitation having been on or about September 2004. 8. Plaintiffhas been advised that marital counseling may be requested and that a list of marriage counselors is available in the office of the Franklin County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff prays that a decree be made divorcing him and the Defendant from the bonds of matrimony now existing between them. KAMINSKI & HAWBAKER, P.C. anice M. Hawbaker, squire Attorney for Plaintiff I verify that the statements in this Complaint 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 f lsification to authorities. Date: Karen agnon, Plainti Of Counsel: KAMINSKI & HAWBAKER, P.C. 22 ] Lincoln Way East Chambersburg, PA 17201 F~ ~~ w ~ ..fl ~ O ~'~ ~?' t-- s =Y~, ~ ~,~,~ , r ~ ~, ~, ; ; D r ~;. =s c=? - '~ - ~~ r` `F7 _ ` j ~ {"' r. ~"~ F,... ^A _ ~ ~ +~-r. V ~ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA-CUMBERLAND COUNTY BRANCH Karen A. Gagnon, Civil Action -Law Plaintiff vs. No. ~ - f7o10~ ~~v<< James J. Gagnon, Defendant In Divorce a v.m. AFFIDAVIT OF NONMILITARY SERVICE Now comes Karen A. Gagnon, Plaintiff in the above-captioned matter, and pursuant to the provisions of 18 Pa. C.S. Section 4904, deposes and says that the Defendant in this action, to wit, James J. Gagnon, is, to the best of his knowledge, not a member of the United States Armed Services and, at such time as this action was filed and at all times thereafter, was serving neither in any active or inactive capacity with any branch of the United States Armed Forces. I verify that the statements made herein 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. Date: K e .Gagnon, Plaintiff C'a c~ r.~ ~, '~ 'L~ j ° Q do "+- `-.~~1~ ~-- ~ ~ ~ r - ~- - ~ i Cly kjC.; t .~' J a ... !') ~ ~ T-> ~ .,J ~i +.. ~ Q i '„ IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT OF PENNSYLVANIA-CUMBERLAND COUNTY BRANCH Karen A. Gagnon, Plaintiff vs. James J. Gagnon, Defendant Civil Action -Law No. OQ - Qa.p~ In Divorce a v.m. NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(D) OF THE DNORCE CODE 1. The parties to this action separated in September 2004 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsificati n to authorities. Date: ~ fYt• K en .Gagnon, Plaints CJ ^' ~ -~ rr ... .rte ~ ~ ~ e -< c.~ . ~ ' ~ C -,-, ~-~ ...'~f-_ ' ;~' .. ~ ::~ -~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW Karen A Gagnon Plaintiff VS. James J.Gagnon Defendant FILE No. 09-0204 , IN DIVORCE NOTICE TO RESUME PRIOR SURNAME March 20 09 Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 17th day of March 2009 hereby elects to resume the prior surname of Karen Ann Weber and gives this written notice pursuant to the provisions o 54 P.S. 704. DATE: ~~. ~ ~~~ Signature ~.J~ Signature o name being resumed ~~ ,~ ~ S67 /6y COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the /3y day of D/e*-Lem ~ 20/0 ,before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. d~*-emu-- b'' Notary Public Prothonotary, Cwn4Kland Cow tx~ M iNy Caninisston EapMres the ~ ~ 1+~ 7~1lt u=`= i ~~ PC~Q~iN~i~~7 ~~;i`. 2~ h2 tdDY t ~ AM ilk ~UM~ER~.AAt~ G~~ti ; ~~. P~hfNSYLVA~~~-~ ~~ ~ s~~ s,~ .,,,, . ~:;..