The URL can be used to link to this page

Home My WebLink About09-5231CANDACE GRACE WOOD ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) V. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. _5x31 vat lerti. ERIC MATHEW GERBER ) IN DIVORCE DEFENDANT ) NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 CHILD(REN). WHEN THE GROUND FOR THE DIVORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT . PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY, LAWYERS 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. LAWYERS REFERRAL SERVICE Telephone: ( For Petitioner: Candace Grace Wood Address: 11 E Front St. Suite 201 Shiremanstown,, PA 17011 Telephone: (717) 357-6577 ty I R CANDACE GRACE WOOD PLAINTIFF, V. ERIC MATHEW GERBER DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA } CIVIL DIVISION )NO: Oq - X31 ???1 ?orm COMPLAINT IN DIVORCE AND NOW COMES, the Petitioner, CANDACE GRACE WOOD , by FILING PRO SE, who files this Complaint in Divorce statement of which is as follow: 1. The Petitioner is CANDACE GRACE WOOD , and adult individual currently residing at 11 E Front St. Suite 201 Shiremanstown PA 17011 2. The Defendant is ERIC MATHEW GERBER and adult individual currently residing at 7 E Front St. Suite 200 Shiremanstown, PA 17011 3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Petitioner and Respondent were married on date: 05-17-2008 in. Camphill, State of Pennsylvania. Attached hereto and marked Exhibit "A" is the original marriage license or a certified copy of the marriage license. 5. There (is) are NO child(ren) born of this marriage. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 10. The marriage is irretrievable broken. 11. After ninety (90) days have elapsed from the commencement and service of this action, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the commencement and service of this action, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code. Respectfully Submitted, Plaintiff: Candace Grace Wood Full Address: 11 E Front St. Suite 201 Shiremanstown. PA 17011 Telephone Number : (717) 357-6577 I verify that the statements made in the Complaint are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unworn falsification to authorities. 0 Dated -29. A09 i?) OF TV - 2021-3 JUL 29 P1 a ,TY 02's .so pe, PLFr- CASH kt-t as 8,5w CANDACE GRACE WOOD ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION V. j NO. -5431 ?lVr? ter"" ERIC MATHEW GERBER ) IN DIVORCE DEFENDANT ) ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE PLEASE take notice that I, ERIC MATHEW GERBER . Defendant, was provided with a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept service of same. I further enter my appearance in this action for all purposed. Defendant: Eric Mathew Gerber Address: 7 E Front St. Suite 200 Shiremanstown, PA 17011 F;Lur, OF TPE 2OP9 AI 29 PH 2: 5 5' CANDACE GRACE WOOD ) IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION ERIC MATHEW GERBER ) NO: OQ - SoaN 0-ivt't leryn DEFENDANT.) IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF: CUMBERLAND ) Before me, thPys?l???c?iyal_c in and for said Commonwealth and County, personally appeare , who being du ly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his/her knowledge, information, and belief, and that he/she is authorized to make this Affidavit. D Name Sworn to and subscribed ?efore me this _ day of S(.c 200_a. COMMONWEALTH OF PENNSYLVANIA MCI A Notarial Seal Marsha S. Miller, Notary Public Swatara Twp., Dauphin County NOTARY PUBLIC My Commission E)q*as Aug. 28, 2011 Member, Pennsylvania Association of Notaries OF TF IE i ?aRY 2009 JU " 29 P l 2: 5; 6 CUPID: :?,, CANDACE GRACE WOOD ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION ERIC MATHEW GERBER ) NO. CA - 5013) (e? DEFENDANT ) AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:) 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division ofproperty, 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 here-in are made subject to the pen lties of 18 Pa C.S. Section 4904 re 'ng to unsworn falsification to authorities. Date: 69 M we intiff: Candace Grace Wood Fl fL' ; OF THE 2009 J 29 ?'?`4 ? L CANDACE GRACE WOOD ) PLAINTIFF, ) V. ) ERIC MATHEW GERBER ) DEFENDANT ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. CA - 6a31 ai „i l e_rw. AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Q)-,)s - "Oct (date:). 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 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 convect. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: 7-0 l O ? ?G-1</ 1__?2 Defendant: Eric Mathew Gerber Al OF Tyr i r -I,. t I! PY 2009 JlU L 29 Ptti 2: r,;? 6 - yr; ?; fli'll ., CANDACE GRACE WOOD ) PLAINTIFF, ) V. ) ERIC MATHEW GERBER ) DEFENDANT ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION NO. Qq -'5031 bva-Terw, IN DIVORCE MILITARY AFFIDAVIT I, CANDACE GRACE WOOD , the Plaintiff, knows of his own personal knowledge, and therefore avers that: 1. ERIC MATHEW GERBER is the Defendant in the above captioned divorce. 2. That the Defendant is 2ears of age. 3. That the Defendant lives at 7 E Front St. Suite 200 Shiremanstown. PA 17011 4. Defendant is employed as 5. That Defendant is not in the military or naval services of the United States or it sallies, or is otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940 and its amendments. I understand that the statements made herein are subject to the penalties of 18 Pa.C.S.A.Section 4904, relating to unsworn falsification to authorities. DATED: 3 - 119 1 0 z ? A IiiJ &'/ W '-*?) Signature of Plaintiff Printed Name: Candace Grace Wood Address: 1 I E Front St. Suite 201 City, State, Zip: Shiremanstown. PA 17011 Telephone Number: -717) 357-6577 Fax Number: -1- STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND On the ?,9 day of j'LA.'1 y , 20_, before me, a Notary Public, personally appeared CANDANCE GRACE WOOD , known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. D 90 'A No Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Marsha S. Miller, rdotary Public Svatara Twp., Dauphin County My Commission Expire Aug. 28, 2011 Member, Pennsylvania Association of Notaries -2- 0= THE F` 'n ray 2009 JUI 29 Ni Z. b- CANDACE GRACE WOOD ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) v. ERIC MATHEW GERBER DEFENDANT ) CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 09-5x31 C ?i) Term IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE To: ERIC MATHEW GERBER CANDACE GRACE WOOD, . Plaintiff intends to file with the court the attached Praecipe to Transmit Record on or afterOr- 1. s , 20 0 ?, requesting that a final decree in divorce be entered. 0A6MY1 /a/c Plaintiff - I - OF THE ?T#lY M NOV 18 PM 1: 43 0 k:H *'Q COUNTY PE*SYLYA IA 41 .4. CANDACE GRACE WOOD ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION ERIC MATHEW GERBER ) NO. (? 9' I C Vi I TerM DEFENDANT ) PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: irretrievable breakdown under Section ® 3301 (c) or ? 3301 (d) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: on or about (GIVE DATE): JI- 1 a 9 a?? via (check one) ® Personal Service or ? Certified Mail. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent/Consent Waiver required by Section 3301 (c) of the Divorce Code: by Plaintiff (CaAd" j j&c) ) by Defendant (Er-i G Cdr-).. (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: 4. Related claims pending: None. S. (Complete either (a) or (b)). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: -.10c I Date Defendant's giver ofNotice in Section 3301(c) Divorce was filed with the Prothonotary: Su i a 9 . aA29 - I - 6. The following is requested: Decree in divorce with property settlement attached. Bifurcated Decree in divorce with the court to retain jurisdiction over unresolved claims which shall be listed for a hearing. Stipulation or order to bifurcate required. V Decree in divorce with no other relief granted. Order approving ground for divorce and referring matters for a hearing on unresolved claims. Decree in divorce deferred. 7. Pennsylvania Vital Statistics form is attached. ignature of Plaintiff Candace Grace Wood Print Name Telephone Number RS)-0FFKX `{Rj! OF THE T ? 2009 NOV 18 PM 1: 4 3 CUWBC 1 ;- .-, PENNSYt CANDACE GRACE WOOD, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. ERIC MATHEW GERBER, DEFENDANT 09-5231 CIVIL TERM ORDER OF COURT AND NOW, this 2kA day of November, 2009, the request for the entry of a decree in divorce IS DENIED AT THIS TIME.' By Edgar B. Bayley, Candace Grace Wood 11 E. Front Street Suite 201 Shiremanstown, PA 17011 Eric Mathew Gerber 7 E. Front Street Suite 200 Shiremanstown, PA 17011 :sal XAf d ii- ? Y-Ut ' The affidavits of consent of both plaintiff and defendant were signed and filed on the same day the complaint in divorce was filed. Ninety days must elapse from the date of the filing of the complaint before the affidavits of consent can be executed and filed. O THl ^n t.! 'j?Tttt 2009 NOV 24 PM 12*.07 1, lnl fN THE COURT OF COMMON PLEAS OF Y~ .CUMBERLAND COUNTY, PENNSYLVANIA V. ~~C,VI~7YlPllJ h~°1Y~Y~o (mil ~~_~\ DIVORCE DECREE AND NOW, in a.~~ i'~ ,, ~( ~L ono , it is ordered and decreed that 1 V~ ~JU ,plaintiff, and ~~ ~ ~ ~ ~)il ~ ~ ,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.") ~~~~ By the Court, ~~ Attes : ~ ~, rothonotarv 3-a-ic yla ~~ ~ G~~