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Home My WebLink About04-2284MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :2004 - OVPy IN DIVORCE NOTICE CIVIL TERM 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 in 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, Carlisle, Pennsylvania 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 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 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. MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW 2004 -y CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTIONS 3301(C1 AND (D) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Michelle L. Gelsinger, by and through her attorneys, Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Joseph E. Gelsinger, representing as follows: 1. The Plaintiff is Michelle L. Gelsinger, an adult individual residing at 8 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17063. 2. The Defendant is Joseph E. Gelsinger, an adult individual currently residing at 8 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17063. 4. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 5. The Plaintiff and the Defendant were married on July 27, 1989 in Virginia. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The Plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage between the two parties. Respectfully submitted, IRWIN & McKNIGHT Dated: May 20, 2004 By: /" !/?V'?'?/` D gl Miller, Esquire Suprem Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. MICHELLE L. GELS NGER Date: May 17 , 2004 WI h Uf -L? ? /?[I ]Cf In the Court of Common Pleas of Cumberland County, Pennsylvania vs. No. Civil. 19 C 1nCP lb w ?i i _ ) J?)IVClCOC7 To Prothonotary 19 ttorne or Plaintiff ?.T/tA No. Term, 19 vs. PRAECIPE 19 Atty. 8e:I IN s? Mr %z ?. '"tO JOf I!Oad 3HI ?o D;1ia4CK73llj MICHELLE L. GELSINGER, Plaintiff V. JOSEPH E. GELSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2004-2284 CIVIL TERM IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO CURTIS R. LONG, PROTHONOTARY: Please reinstate the Complaint in the above-captioned case. Respectfully submitted, IRWIN & McKNIGHT i By: Douglas G. Miller, sq. 60 West Pomfret: Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No: 83776 Attorney for Plaintiff, Michelle L. Gelsinger Date: June 18, 2004 C -J c? 'T7 ril cz, CD - _.-' r"I Cil MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2004 -2284 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS: NOW, Douglas Miller, Esquire, being duly sworn according to law, does depose and state: That he is a competent adult and attorney for the Plaintiff in the captioned action. 2. That a certified copy of the Complaint was served upon the defendant, Joseph E. Gelsinger, on June 17, 2004 by certified mail, return receipt requested, addressed to Joseph E. Gelsinger, at his address at 8 Mooreland Avenue, Mt. Holy Springs, Pennsylvania 17063, with return receipt number 7002 0860 0000 1074 3172. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. IRWIN & MCE:NIGHT Date: June 22, 2004 By:c!`/ Douglas 14 Miller, Esquire Supreme Court Id # 83776 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Plaintiff Shannon Detter ru M1 °?? i8#nr C3 C3 Pomade E I (D O - C3 7 :: C3 Cenlfiel Fee ' 0 g (FndaeememeR rouI r" n , 75 i • o [:sdoreemwe Re iFb h ; 5 I ^ M °, `"I? • qu V ? u To a Fees $ S f f/ 117 7 nt sepg E. Gelsinger y a weer. eai Td: r .......... .............."'---. -? r O • no1Ty Springs PA 17063''•: Ila•ses?ra ¦ Complete items 1, 2, and 3. Also complete . item 4 if Restricted Delivery is desired. ¦ Prim your name and address on the reverse so that we can return the card to you. • A tech this card to the back of the mailpiece, or on the from N space permits. 1. A,ec; Addressedto: Joseph E. Gelsinger S Mooreland Avenue Mt. Holly Springs. PA 17063 t1saddressd1filarant 3. Service Q Certified Mall 0 Express Mail ? Registered 13 Return Receipt for Merche4lee ? Agent ? Addrosae (C. Date of Deliver fiem 19 ? Yea If YES, enter delivery address below: 13 No 1025e5m4?1035 ..---?, r una roe ?yBe 2. Ankle Number rnanarerfwRservice laoa9 7002 0860 00001 1074 3172 P8 Roan 3811. Augwt 2001 oortrepic Return Receipt N C`? .. C? - o r g .73 N L-0 j c7 <. , MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :2004-2284 CIVIL TERM IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, this 0 day of October 2004, comes the Plaintiff/Petitioner, Michelle L. Gelsinger, by her attorneys, Irwin & McKnight, and makes the following Petition for Special Relief against the Defendant/Respondent, Joseph E. Gelsinger: 1. The petitioner is Michelle L. Gelsinger, an adult individual who resides at 8 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 2. The respondent is Joseph E. Gelsinger, an adult individual whose mailing address and primary residence is 8 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Petitioner and Respondent are husband and wife, having been married on July 27, 1989. 4. On or about May 20, 2004, Petitioner instituted the above-captioned divorce action. 2 5. The parties share the marital premises at 8 Mooreland Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065 with their children, Levi E. Gelsinger, age 3, and Clayton L. Gelsinger, age 2. 6. On June 21, 2004, an Order for Protection from Abuse was signed by Judge Edward Guido and docketed to number 04-2544. 7. Thre Respondent, Joseph E. Gelsinger, has subjected Petitioner to numerous acts of physical and mental cruelty. Respondent has broken items in the marital residence. He has grabbed and pushed Petitioner. He has threatened to punch her in the face. Respondent has threatened to kill or harm Petitioner. The marital residence has become unsafe for Petitioner and her two children while Respondent continues to reside there. 8. Petitioner is without the financial resources to move with the children to another location. The marital residence is the only home the minor children have known and moving them would seriously affect their sense of stability at this difficult time. 9. Furthermore, Respondent has now refused to contribute financially to his family, forcing Petiutioner to assume sole responsibility for payment of the mortgage and other joint obligations. 10. Respondent has admitted to serious drug and alcohol problems. He continually comes to the marital residence at all hours of the day and night, often bringing other individuals who are under the influence of drugs and alcohol into the home. He creates disturbances with his friends 3 in the marital home during the night, interrupting the sleep of both the Petitioner and their children. 11. Despite numerous requests by Petitioner to Respondent that he cease engaging in the above-mentioned conduct and/or that he leave the marital residence, Respondent has refused to do so on a permanent basis. WHEREFORE, the Petitioner, Michelle L. Gelsinger, respectfully requests this Honorable Court to enter an Order awarding exclusive occupancy of the marital residence to Petitioner and denying Respondent access to the home. Respectfully submitted, IRWIN & McKNIGHT By: Doug la . Mi ler,, squire Attorney for Petitioner 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 717-249-2353 Supreme Court I.D. No: 83776 Date: October 1, 2004 4 VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. {????.?6Kx?v m MICHELLEi L LSINGt Date: October 1 2004 MICHELLE L. GELSINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JOSEPH E. GELSINGER, 2004-2284 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, hereby certify that a copy of attached Petition for Special Relief was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Joseph E. Gelsinger 8 Mooreland Avenue Mt. Holly Springs, PA 17065 Date: October 1, 2004 IRWIN & McKNIGHT illei•, Esquire est Pomfret Street Carlisle, PA 17013 (717) 249-2353 Supreme Court I.D. No. 83776 r Douglas . M 60 W 5 c? e: ?, s... c-? --a rr:? _? ? 7i•?; _,., ?„ ?;, ' i - c ' ... - ? _ a t; r:: r.; , j (.n) ?1 ? Vl -G. OCT 0 4 2004 MICHELLE L. GELSINGER K • IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW 2004-2284 CIVIL TERM JOSEPH E. GELSINGER, Defendant : IN DIVORCE ORDER OF COURT AND NOW, this I ) lA day of D&Cg? , 2004, upon consideration of the attached Petition for Special Relief, a hearing is hereby scheduled for -1-0 Ir o 2004, in Courtroom No. !?- , at /040 o'clock A .m., Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. ?a By: 1 Judge _,? ? , _ -',?? ,1p - „';? r : .7 !.,? "? j ?i i? h,??7 i y-? ? ?. ?'t ?. :?? ....a _ ... .._ MICHELLE L. GELSINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : 2004-2284 CIVIL TERM JOSEPH E. GELSINGER, Defendant : IN DIVORCE NOTICE 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 in 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, Carlisle, Pennsylvania 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 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 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. MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :2004-2284 CIVIL TERM IN DIVORCE AMENDED COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Michelle L. Gelsinger, by her attorneys, Irwin & McKnight, and files this Amended Complaint in Divorce against the Defendant, Joseph E. Gelsinger, representing as follows: COUNT II - COMPLAINT IN DIVORCE PUSUANT TO SECTION 3301(a) 9. The allegations of Paragraphs one (1) through eight (8) of the Divorce Complaint are incorporated herein as if fully set forth above. 10. Pursuant to the Divorce Code, Section 3301(a)(6), the Plaintiff avers as the grounds upon which this action is based that the Plaintiff is the injured spouse and that the Defendant has offered such indignities to her as to render her condition intolerable and life burdensome. 11. Pursuant to the Divorce Code, Section 3301(a)(3), the Plaintiff avers as the grounds upon which this action is based that the Plaintiff is the injured spouse and that the Defendant, by cruel and barbarous treatment, has endangered the life or health of the injured and innocent spouse. WHEREFORE, the Plaintiff requests the dissolution of the marriage between the two parties and for such further relief as your Honorable Court may deem equitable and just. COUNT III - ALIMONY, ALIMONY PENDENTE LITE AND COUNSEL FEES 12. The allegations of Paragraphs one (1) through eleven (11) of the Divorce Complaint are incorporated herein as if fully set forth above. 13. Plaintiff is unable to provide for, or afford her counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 14. Plaintiff is without sufficient property and otherwise unable to financially support herself through current and appropriate employment. 15. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses and costs, as well as alimony, and alimony pendente lite for the Plaintiff. WHEREFORE, Plaintiff requests the Court to enter an ordering requiring Defendant to pay for Plaintiff's counsel fees, expenses and costs as well as providing for payment of an appropriate alimony and alimony pendente lite to Plaintiff. Dated: Respectfully submitted, IRWIN & McKNIGHT 7?D?, AA'PL/?, Douglas T-- Miller, Esquire Supreme Court I.D. 83776 60 West Pomfret Street Carlisle, PA 17013 (717) 249-2353 Attorney for Plaintiff VERIFICATION The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. MICHELLE L. GELSINGER Date: L ZU -U-5 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: JOSEPH E. GELSINGER 8 MOORELAND AVENUE CARLISLE, PA 17013 Date: 1Cl cfitl-?, 2005 IRWIN & McKNIGHT Douglas Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 1P G r? r ? -t? MICHELLE L. GELSINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW :2004-2284 CIVIL TERM JOSEPH E. GELSINGER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SS. Michelle L. Gelsinger, being sworn according to law, deposes and says that she is a competent adult over 18 years of age; that she served a copy of the Amended Complaint in Divorce upon the Defendant, Joseph E. Gelsinger, by personallly handing hima true and correct copy thereof and informing him of its contents at? nrtu YxaaKYYt•k9U?f?r?is?e P$ 1109 on T s/,-20,,---2,0067 , at ;2,/,5 o'clock _6L, m. Deponent further avers that at the time of such service the Defendant identified him to deponent. MICHELLE L. GELSINGER Sworn to and subscribed Before me this a0qw-?) Day of `-I'Y) 2005 Mxft L Noel, Nowy Pt" ca we Saw, 0"Wrkr4 Cou fNC* r"ME*keeSept.18, C7 o p z c°s, -n x Vi c ? i a:: ni :rj i C: " l (ti iN THE COURT OF CCmYON PLEAS CF CL^?BERLJLND COUNTY, PE`MSYLVANLi MICHELLE L. GELSINGER, Plaintiff VS. JOSEPH E GELSINGER N0. 2004-2284 MOTION FOR APPOI_72 NTOF MASTER Michelle L. Gelsinger (Plaintiff) QDW&dffd9fft), moves the court to appoint a master with respect to the following clams: ( X ) Divorce (X } Distribution of Property ( ) ?nrulment (X ) Support ( X ) Pl imony (X ) Counsel Fees (X) A? imony Peadente Lite (X ) Casts and F_rPenses and in support of the motion states: (I) Discovery is camplete as to tie claims(s) _ar which the appointaent of a master is requested. (2) The defendant (has) (bit) appeared in the action (2er3ona1,1.7) tai Esquire). (3) The staturory ground(s) for divorce (xx) (are) 77n1( ) (r) and (d) (4) Delete the inapplicable paragraph(s): (a)nac:moedK3?sciQssaBS?. (b) aRc?Lficxc?cx,ttxRR#4t?t?4xXc:F?cxS?hx&t4txxx f p 1?xi??cik?LA : (c) The action is contested with raspect to the Following claims: All of the above listed claims. (5) The action O (does not involve) complex issues of law or fact. (6) The hearing is expected to take I (biaurs) (days). (i) additional informaticn, if any. relevant to the motion: Data: 6/6/05 alYD NOW is anpoiaced master 'With, respect to toe following clais: At -Ornyr for (('Iaintiff) GRDE3 A'POI`TTLVG }L45"E?ouglas G. Millen) Esquir=, By the Court: J cil C- 3'c' N v ? N MICHELLE L. GELSINGER Plaintiff VS. JOSEPH E GELSINGER IN THE COART OF COMMON PLE.1S OF CL':!BF-au2m COUNLTY, PE'`MSYLVANT-1 NO. 2004-2284 MOTION FOR AP°0L _ °- T OF MASTER Michelle L. Gelsinger (Plaintiff) 0DW-AwUW &), moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property ( ) Annulment (X) Support ( X) phony (X) Counsel Fees (X) Alimony Pendenta Lite (X) Costs and Expenses and in support of the maticn states: (1) Discever7 is complete as to the clains(s) far which the appoinment of a master is requested. (2) The defendant (ins) ($iC7Ct) appeared in the action (persanally) (1d9X%Xr Xwuubwdw( ---squire). (3) 44Q ?( 1 (rl a d (d The ) staturory ground(s) for divorce (XR) (are) (4) athe inapplicable paragraph(s): Delet (a) ! A ^c:eat)dxh®cxsxs3RB8sSSta(. (b) atQc??xcx?xktxi?3@aaF:Atcac5s4tx5cYtRxxx f o l?x4c?c.43?&A : (c) The action is contested with respect to the following claims: All of the above listed claims. (5) The action (:hams) (does not involve) complex issues of la« or fact. (5) ',he hearing is expectad to take i (tears) (days). (7) Add itional information, if any. relevant to the motion: Date: 616105 At.a n for (Plaintiff) 4t) Mi d er ORDE3 A_°°OI`ITLVG iL?S "'ouglas G. p1YD NOSr ?A dsac_se, is appointed #s tar wit: respect to the follcwiag claims: By the Cc rt: ??v111 PJ R?t' ` rnzi T• _ -y T`i N Ji N -?C AY 81 =6 WV 6- Nnr soot MV1CNvUO d BHI 30 MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .2004-2284 CIVIL TERM : IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW, this day of October, 2005, comes the Petitioner, Michelle L. Gelsinger, by her attorneys, IRWIN & McKNIGHT, and makes the following Petition for Economic Relief against the Respondent, Joseph E. Gelsinger, as follows: 1. The Petitioner is Michelle L. Gelsinger who is the Plaintiff in a divorce action filed at 2004-2284 in Cumberland County, Pennsylvania. Her address is 8 Mooreland Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Respondent is Joseph E. Gelsinger who is the Defendant this divorce action. 3. The Petitioner requests equitable distribution of the marital assets by the Divorce Master already appointed in this matter. WHEREFORE, the Petitioner, Michelle L. Gelsinger, requests the relief set forth above. Respectfully submitted, Dated: October 7, 2005 IRWIN & McKNIGHT By- Douglas . Miller, Esquire 60 West Pomfret Street Carlisle, PA 17013 717-249-2353 Supreme Court I.D. No: 25476 Attorney for the Plaintiff/Petitioner, Michelle L. Gelsinger CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: JOSEPH E. GELSINGER 8 MOORELAND AVENUE CARLISLE, PA 17013 Date: October 7, 2005 IRWIN & McKNIGHT Douglas Yr. Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Ei D 7 ?J t_ r c0 S' r> r> CJY ?-t i rT 'tl T1 ?C 1 a? MICHELLE L. GELSINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW 2004-2284 CIVIL TERM JOSEPH E. GELSINGER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND I, U?/.Eb ?ES.(? , being sworn according to law, deposes and says that I am a competent adult over 18 years of age; that I served a copy of the Order and Notice Setting Hearing upon the Defendant, Joseph E. Gelsinger, by personally handing him a true and correct copy thereof and informing him of its contents at 15 ,?fonQlL9r?? -?;z on /O- ih' D5 at o'clock ?m. Deponent further avers that at the time of such service the Defendant identified him to deponent. Sworn to and subscribed Before me this Day of b ,? _ 2005 Not ublic ?1MONWEALTH OF PENNSYLVANIA Martlie l Neel, No?yp? MY Oommbsbn E?key Sept 1d ?7 Member, Pennsylvania Aasodatbn Ot Nblarfea ?, c ± --„ ?? _, ?T .. ?..: :?: i `? ., `::1, L, i, .% ? .; f^ h =I f j ? =-. MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :2004-2284 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: NOW, Douglas G. Miller, Esquire, being duly sworn according to law, does depose and state: That he is a competent adult and attorney for the Plaintiff in the captioned action in divorce. 2. That a copy of the Notice of Intention to Request Entry of Divorce Decree and Counter-Affidavit were served upon the defendant on or about May 22, 2006, as evidenced by the Certificate of Service signed by John Chronister. 3. That the said Certificate of Service is attached hereto and made a part hereof. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unswom falsification to authorities Date: a3 O?fxP DOUGLA G. MIL, ESQUIRE y Attorney for Plaintiff MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 2004 -2284 IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE I, JOHN CHRONISTER, a competent adult, being duly sworn according to law, depose and say that at approximately / on /1/ft 2006, I personally served r- q by hand delivery the Notice to the Defendant and the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code and the Counter-Affidavit Under Section 3301(d) of the Divorce Code in reference to the above-captioned case: To: Joseph E. Gelsinger 8 Mooreland Avenue Mount Holly Springs, PA 17065 I verify that the statements in this return of service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unswom falsification to authorities. Date: May 22, 2006 Sworn and before me of May 20( HN CHRONISTER^"- Z14MOOVOM0 F?ENMYLVANIA be, AIMIMMWn on MICHELLE L. GELSINGER, IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW .2004-2284 CIVIL TERM JOSEPH E. GELSINGER, Defendant : IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about May 20, 2004 and have continued to live separate and apart for a period of at least two 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 herein are made subject to the penalties of 18 Pa. C.S. of 4904 relating to unswom falsification to authorities. Date: /9 0 MICHELLE L. GEL GER MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant 1. Check either (a) or (b): : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :2004-2284 CIVIL TERM : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): - (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): - (a) I do not with to make any claims for economic relief. 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. - (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. JOSEPH E. GELSINGER Defendant Date: .2006 NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. C7 rlo K ? S' G - MICHELLE L. GELSINGER, Plaintiff, V. JOSEPH E. GELSINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2004-2284 CIVIL TERM IN DIVORCE PRAECIPE TO WITHDRAW CLAIM FOR ALIMONY To Curtis R. Long, Prothonotary: Please withdraw the claim for alimony filed on April 25, 2005, on behalf of the Plaintiff, Michelle L. Gelsinger, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT Date: June 15, 2006 _ O-- 144 Douglas it. Miller, Esquire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 I CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: JOSEPH E. GELSINGER 8 MOORELAND AVENUE MT. HOLLY SPRINGS, PA 17068 Date: June 15, 2006 IRWIN & McKNIGHT Douglas G. filler; Esquire ?(. Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Attorney for Plaintiff N n r-' <47 C:- L11 T:. _ 4? (? ?? ?. ) -n _? -n .=.i `.- ?"r' -;7.._ `l'. a'F7 Curtis R. Long Prothonotary office of the Protbonotarp Cumbertanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor O"1 - 22RL/ CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573 MICHELLE L. GELSINGER, Plaintiff VS. JOSEPH E. GELSINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04 - 2284 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this 94 day of L!r , 2010, an order having been entered terminating the above-captioned proceedings for lack of activity, the case having been terminated in accordance with PA.R.C.P 230.2, the appointment of the Master is vacated. BY THE COURT, Kevi A. Hess, P.J. cc: Douglas G. Miller Attorney for Plaintiff ?seph E. Gelsinger Defendant (Pro Se) r. Pal L t t n l.: l S /)-tat ll4c?, ` ' co =7 ` <