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Home My WebLink About04-3388 F:\Vser FoJderIFilln DoCS\GClldocs200413628-Jdiv_compJaioLwpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA SUE Z, GONTZ, Plaintiff v, CIVIL ACTION - LA ~ . L ~ NO,2004- 3 u>P f:tc...>'- ~ DOUGLAS ALAN GONTZ, Defendant 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse, If you desire to pursue counseling, you must make your request for counseling within twenty (20) days ofthe date on which you receive this notice, Failure to do so will constitute a waiver of your right to request counseling, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA SUE Z, GONTZ, Plaintiff v. CNIL ACTION - LAW NO,2004- Jjff> Cio~L '-r~ DOUGLAS ALAN GONTZ, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 12 ~ day of July, 2004 comes Plaintiff, Sue Z. Gontz, by and through her attorneys, Hanft & Knight, P,C" and files the following Complaint in Divorce, and in support thereof avers as follows: I, The Plaintiff is Sue Z, Gontz, who resides at 199 Crain Drive, Carlisle, Cumberland County, Peunsylvania 17013, 2. The Defendant is Douglas Alan Gontz, who resides at 6 Kim Acre Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3, The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth ofPennsylvarua for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4, The parties were married on January 17, 1987, in Harrisburg, Dauphin County, Pennsylvania, 5, The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 6, Alternatively, Plaintiff avers that the Defendant has offered such indignities to her, the injured and innocent spouse, as to render her condition intolerable and her life burdensome, The foregoing facts are averred and brought under Section 3301 (a)(6) ofthe Divorce Code of 1980, as amended. 7, The Plaintiffhas been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same, WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, H M chael J, Hanft, Es Ire Attorney ill No, 57976 Sean M. Shultz, Esquire Attorney ill No, 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff VERIFICATION I VER[FY that the statements set forth in the attached document are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa, Section 4904 relating to unsworn falsification to authorities, .J~ ZH F \L'~r F"ldcf'FirTrI Docl'Fomu'.Lil;B.ltion\Vcriiklt;on scne", (J "9. - 17i ~ () u- ""' ...... - 0 ~ ~ - U1 -U ~ P-- J- .. rj C _ ~:; c:~ .L.~ ~.~ -' ~ rl":p ;.... ;~~~rG~1 ......~-*t.\ b -.' n ~ >,-.;:\:\ - ....- t'.) {.':; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUE Z. GONTZ, Plaintiffs CIVIL ACTION - LAW NO, 2004- 3388 v, DOUGLAS ALAN GONTZ, Defendants IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 2- Of day of July, 2004, I, Michael J, Hanft, Esquire, hereby certify that the following person was served with a True and Correct copy ofthe Complaint in Divorce filed in the above-referenced matter, The Complaint in Divorce was mailed on July 19, 2004, but actual service took place on July 20,2004, by Defendant signing for a copy ofthe Complaint in Divorce which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows: Douglas Alan Gontz 6 Kim Acre Drive Mechanicsburg, Pennsylvania 17055 A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof, Respectfully submitted, T & KNIGHT, P.C, M 'h~lYf!JJ1f Attorney ID No, 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff F:\User Folder\Firm Docs\Gendocs2004\362S.i cen,service. wpd . Complete items 1 , 2. and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece. or on the front if space permits. 1. Article Addressed to: Do tt3ttx's AIKIl Grvnk ~ lLirv\ k(je bfi ift Y\JUch(jflrrsb U(8J P1t '10~ 3. Service Type ,;iI'iS;rtlfied Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~s 2. Artich (Trans 7003 3110 0004 5768 8946 PS Form 3811 , February 2004 'Domestic Return Receipt 102595-02-M.1540 Exhibit "A" o c :;;:;:: ;:gc.rl ,~,,,._, 1 ' 4,~., " 95~i ~:~ .1.:>' - ?:,~ i~< >'> c Z' ::2 ,...., = c:;:'~ ....- (.- C-- r= r',) \.0 ~ ~:D -o~ :0 o ::r!'? 6:.!J ,.,,.0 Orn --,1 ?f:j -< -0 :J:: 0.' .1-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUE Z, GONTZ, Plaintiff v, CIVIL ACTION - LAW NO, 2004- 3388 DOUGLAS ALAN GONTZ, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code, 2, Date and manner of service of the Complaint: served on Defendant by United States Certified, Return Receipt Requested, Restricted Delivery Mail on July 20, 2004, 3, Date of execution of the Plaintiffs Affidavit of Consent required by Section 3301 (c) ofthe Divorce Code; June 8, 2006; by the Defendant; June 6, 2006, 4, Related claims pending: None. 5, Date Plaintiffs Waiver of Notice in g3301( c) Divorce was filed with the Prothonotary: June 16, 2006, Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: June 16, 2006, KNIGHT & ASSOCIATES, P,C. , Date: June 15, 2006 a-;1 Sean M, Shultz, Esquire Attorney LD, No, 90946 I 1 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff F:\User Folder\Finn Docs\Gendocs2OQ6\3628-1 pracci~.wpd ''-0 = '_-::7 0-. <-. C"~ o ."11 :::l r4i:D "IIi "'9 -) ~ ~ \_:' ...\--~;- '''j 215 ::'5rn ~::-! ::0 -< "-';-'.C.. '-D :;: ,r:-- 0' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUE Z. GONTZ, Plaintiff No, 2004-3388 In Divorce v, Civil Action - Law DOUGLAS ALAN GONTZ, Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS, ) COUNTY OF CUMBERLAND 1. 13, 2004, A Complaint in divorce under Section 3301( c) of the Divorce Code was filed on July 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry ofa final Decree of Divorce after service of notice of intention to request entry of the Decree, 4, I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court, 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" Section 4904 relating to unsworn falsification to authorities, Date:~,2006 ~U{ lfJ~ Sue Z, Gont . Sworn to and subscribed before me this R day of -:I{)I'1-e... ,2006, cIt/11i1l I'71c(l1Ll./a-.... Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL LINDA McCLELLAN, Notary Public Bora of Carlisle, Cumberland County . MtC.ommiol$iOn Ex~ires Oct. 26, 2009 -rJr r"":',1 C) c ......, g C7' <-- :--,:; ~,'.'..,. ..':) -n ~-n n,p: .T! ;g:C;:l J,.1., \.D -0 -J,;... i. Hl~ 'S?:~~ r'j :-::~ 'n :< .r:- 0) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUE Z. GONTZ, Plaintiff No, 2004-3388 In Divorce v, Civil Action - Law DOUGLAS ALAN GONTZ, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 53301(0 OF THE DIVORCE CODE 1, 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 correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S. 94904 relating to unsworn falsification to authorities, Date: 10-"3 - 0 ~ t~G~ - 8 OVlb n s: 0"" = l...,:;) "" L (.:..~ ...:;'!- ,-) '1', -1 I-n rn r=: :;:, t:; .~-.~ ,L.. \.0 ~,. ~ ::r: '\!{S c5r1. -l -.:> :'0 :< -. (,.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUE Z, GONTZ, Plaintiff No, 2004-3388 In Divorce v, Civil Action - Law DOUGLAS ALAN GONTZ, Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS, ) COUNTY OF CUMBERLAND 1. 13, 2004. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the 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, 4, I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court, 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" Section 4904 relating to unsworn falsification to authorities, Date: &1/ f.e ,2006 ntz Sworn to and subscribed before me this {, day of J , 2006, dlJ~ F:\User Folda\Finn Docs\Gendocs200613628-1 affconsent,wpd 0 ....., 0 = ,-:: = --n 0" .. <- :::l 1-: ffi:n , c.: ......;... r -am ill C~6 -0 I: ::;::: :; (OS r:: orn :~ .r. ~g '-'-' -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUE Z. GONTZ, Plaintiff No. 2004-3388 In Divorce v, Civil Action - Law DOUGLAS ALAN GONTZ, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 11330HC) OF THE DIVORCE CODE I. 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! 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 herein are made subject to the penalties of 18 Pa, C,S. 94904 relating to unsworn falsification to authorities, Date: Ir'l> -0 & /" z!} ..;jW - CIVI . Sue Z. Gontz ( 6 o c: ~ ..::;:";) 0"" i~ ,~, - ...0 -0 ~ o ~ -\ -:!",:n ',I r= -,,1'1'< :"'0 ;:~\~~; ~~j ~q "_)rn .-,\ -".. ~ - .r:- v:; . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . SUE Z. GCNI'Z, Plaintiff No. 2004-3388 VERSUS lXXJGLAS ALAN GCNl'Z, . Defendant . DECREE IN DIVORCE . . . . . . . . . . . . . o:f"((:J,)A./tI. ::r~y& (TO 2006 IT IS ORDERED AND AND NOW, SUE z. GCNl'Z , PLAINTIFF, DECREED THAT . . . lXXJGLAS ALAN GCNI'Z , DEFENDANT, AND . . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY, . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; N/A . . . . . . . . J, . . . ATTEST: . . . PROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . .h-P ~ ~u, ~ p ,,/f/"" /oW-f"9 . . , . <<.1".'''' ' . . ! ." ji..... ..~ ' . , 'j(J .Le'> "? ~.Lc'''l