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HomeMy WebLinkAbout09-1068 Norma J. Gonce Plaintiff v. Louis A. G. Gonce Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- /00( CIVIL TERM : 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 your children. When the ground for divorce is indignities or irretrievable breakdown of the marria-e, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, I 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 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Norma J. Gonce Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. Louis A. G. Gonce Defendant NO. 09- 'b (pC? CIVIL TERM IN DIVORCE COMPLAINT UNDER r§3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is O V M U Ll 011C who currently resides at q"9 k Siy COsLe , PQ, )7d l3 Cumberland County, Pennsylvania. 01 2. Defendant is I S a I G O C Q-; who currently resides at 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 Q- ?. Q.C V at Spa) .AM 5. The marriage is irretrievably broken, and the parties separated on Oecq?ry\beA- A'7, © Y 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. A/aVo (? _ If i Date laintiff, Pro Se 4( 9 I, erify 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. AZ ?,O/ Date: a, pejc??? Plaintiff, Pro Se Assisted by: Michael A. Scherer, Esq. O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 ri Norma J. Gonce Plaintiff V. Louis A. G. Gonce Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.09- 166C- CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Norma J. Gonce, Plaintiff, to proceed in forma aR uperis. 1, Michael A. Scherer, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. C MichdeI 4. SclYereY, Esquire Attorney for Plaintiff O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 .. ._ ? , > ;: ? ' `;? _:_? ;? - ?_.; . ? . _ ? - :fF"£ ?=; :X ?`' \ ?? c , ?< Norma J. Gonce IN `:'HE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v : NC 09- IM0 CIVIL TERM Louis A. G. Gonce Defendant IN :aVORCE 1 4 ACCEPTANCL OF SERVICE I, Louis A. G. Gonce (Defendant), accep,ed service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of !he Divorce Code on the date written below. I understand that false statements herein are mace subject to the penalties of 18 Pa. C.S. §4904. relating to unsworn falsification to authorities. Go ne Date Louis A. G. Gonce, Defendant Y €Fr' f ' - -'t '7ARY 2009 M Y 13 Ph 2: 3 L CUB':- ?„ ???' `?' P ', U