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Home My WebLink About09-6748 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jan Craig Gibboney, Jr. Plaintiff Pro Se, vs. NO. ?Q -Ljga lConnie Lorrain Gibboney Defendant Pro Se. 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 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 Cumberland County Courthouse, S. Hanover St., 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 OR CANNOT AFFORD ONE, 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. CUMBERLAND COUNTY LAWYERS REFERRAL SERVICE 3 Z- 5, ,dgp? sT , CAkkiuE , PA rjal 3 Telephone: 3/ ?- - Zq 9 -31t.6 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 Notice to Defend and Claim Rights Pagel of 2 disabled individuals having business before the Court, please contact the Court Administrator at (717) 240-6195. All arrangements must bemade at least 72 hours prior to any hearing or business before the Court. Notice to Defend and Claim Rights Page 2 of 2 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jan Craig Gibboney, Jr. 3739 Valley Rd. Marysville, PA 17053 Plaintiff Pro Se, vs. NO. o q - L -T-c,?,,_ Connie Lorrain Gibboney 324 4th St. Apt. C. Newcumberland, PA 17070 Defendant Pro Se. COMPLAINT IN DIVORCE Plaintiff, Jan Craig Gibboney, Jr., pro se, respectfully represents: 1. Plaintiff, Jan Craig Gibboney, Jr., currently resides at 3739 Valley Rd., Marysville, PA 17053. 2. Defendant, Connie Lorrain Gibboney, currently resides at 324 4th St. Apt. C., Newcumberland, PA 17070. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 04/22/2006, in Enola, PA. 5. The parties were separated on 04/09/2009. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 7. The parties have no minor or legally dependent children. 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, fees and costs. Complaint in Divorce Page 1 of 2 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce pursuant to Section 3301(c) of the Divorce Code. GLv? J raig Gibboney, Jr., Plaintiff o e VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. J raig Gibboney, Jr., Plaint' Pro?6 Date: 8,1110 Complaint in Divorce Page 2 of 2 CERTIFICATION OF EXCERPTS FROM MARRIAGE LICENSE RECORD STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND I, GLENDA FARNER STRASBAUGH , CLERK OF ORPHANS' COURT in and for said County, hereby do certify that the records in as contained in Marriage License Docket, Vol.20060 Page 256 Marriage License No. 256 April 21, 2006 to G/BBONEY JAN C JR this office, show that was issued on and HOLT CONN/EL that the Return to (Last, First, Middle) said License shows that said persons were married on April22,2006 at ENOLA by GILBERT THERESA C REVEREND GIBBONEY JAN C JR stated his date of birth was August 10, 1979 his birthplace CARL/SLEPA and the names of his parents G/BBONEY JAN C and HOL T CONN/E L was June 15, 1981 and the names of BROD/SH SHARON stated her date of birth her birthplace NORMAL /L her parents HOLT ROGER HOL T MARNA IN TESTIMONY WHEREOF, I have hereunto set my hand and the seal of said court this 9th day of October , A . D . , 2009 GLENDA FARNER STRASBAUi CLERK OF ORPHANS' COURT ''IT O 2at9 OAT -9 A? 11 ? 24 ,tCv;?L 1°C X33 8.5b 7{cL a3 ru-y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Jan Craig Gibboney, Jr. Plaintiff Pro Se, vs. NO. TC-1 Connie Lorrain Gibboney Defendant Pro Se. ACCEPTANCE OF SERVICE I, Connie Lorrain Gibboney, defendant in this divorce action, hereby certify that I personally received a copy of the Complaint in Divorce with a Notice to Defendant and Claim Rights on or about 0CA0u pla, aQm .cam Connie Lorra ibboney, Defen t Date: !0.33 , ()q Exhibit A: Acceptance of Service Page 1 of 1 OF &$?nrIv 2009 OCT 26 PM 2: 39 CUMBI. 4-- to (:3UINTY PENN3LVA[,%4,