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HomeMy WebLinkAbout09-7814Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive, Harrisburg, PA 17109 (717) 657-4795 smeilton@dzmmglaw.com MAUREEN A. GALLAGHER, : IN THE COURT OF COMMON PLEAS Plaintiff V. GRANT H. FLEMING, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA NO. cA - 78t4 a 1v t I Term CIVIL ACTION -LAW 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 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 Court House, 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 or 1-800-990-9108 andra L. Meilton, Es ire, No. 32551 Attorney for Plaintiff DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive, Harrisburg, PA 17109 (717) 657-4795 6 Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton@,dzmmglaw.com MAUREEN A. GALLAGHER, Plaintiff V. GRANT H. FLEMING, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. '15't Y T+ CIVIL ACTION -LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Maureen A. Gallagher, an adult individual who is sui juris and resides at 1033 Hillview Lane, Hershey, Dauphin County, Pennsylvania. 2. Defendant is Grant H. Fleming, an adult individual who is sui juris and resides at 101 West Main Street, Hummelstown, Dauphin County, Pennsylvania. The present whereabouts of the Defendant, Grant H. Fleming, to the knowledge of the Plaintiff, is the same. 3. Both 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 July 9, 2004, in Hershey, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. DALEY ZUCKER MEILTON MINER & GINGRICH, LLC By: Sandra L. Meilton, quire, I.D. No. 32551 1029 Scenery Drive Harrisburg, PA 17109 717-657-4795 Attorneys for Plaintiff I verify that the statements made 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 unworn falsification to authorities. Maureen A. Gallagher, Plaintiff Dated: 11 ! / 01 it ... Tt ?' • t ? ,. ? ..•. Jq i !U Pill 1,2: lrL'tV i .. ?? +'J .. t o di:'1 4 539.50 PD AT-r,/ ocr 38ga RTO x3331 a Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive, Harrisburg, PA 17109 (717) 657-4795 smeiltonAdzmmglaw.com MAUREEN A. GALLAGHER, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-7814 Civil Term GRANT H. FLEMING, CIVIL ACTION -LAW Defendant Dl DIVORCE , AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN ) AND NOW, this 19th day of November, 2009, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, paralegal to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on November 19, 2009, she personally served the above-named Defendant with a time stamped and certified copy of the Complaint in Divorce filed in the above matter by handing same to him on November 19, 2009 at 8:03 a.m. at 101 West Main Street, Hummelstown, PA. Gloria M. Rine Sworn to and subscribed before me this 19th day of November, 2009. of Public CommoN 4wALT" OF PVdkSVLVAhNA (SEAL) A.PATRICIAA. P/ATTON, NNolery PuW Lower Paxton UP., ©aa?ph n county Commission Expires June 20, 2010 AILED-O?-i SCE OF THE PROTHUI?OTARY 2009 NOV 20 PM 2: 04 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MAUREEN A. GALLAGHER V. GRANT H. FLEMING NO. 09-7814 CIVIL TERM DIVORCE DECREE AND NOW, f' ~3 , ~~V , it is ordered and decreed that MAUREEN A. GALLAGHER plaintiff, and GRANT H. FLEMING ,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.") NONE.