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Home My WebLink About01-2605 KANDICE L. GALASPY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ; v. : NO. : CHARLES D. GALASPY, : CIVIL ACTION - DIVORCE Defendant : 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 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, 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 KANDICE L. GALASPY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. : CHARLES D. GALASPY, : CIVIL ACTION - DIVORCE Defendant : COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes the Plaintiff, Kandice L. Galaspy, by and through her attorney, Gary L. Kelley, and represents as follows: DIVORCE UNDER SECTION 3301~¢) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kan&ce L. Galaspy who presently resides at 233 Locust Pointe Road, Mechanicsburg, Pennsylvania 17050. Her Social Security Number is 199-54-4691. 2. Defendant is Charles D. Galaspy who resides at 45 Carton Avenue, Carlisle, Pennsylvania 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 3, 1995 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The parties are the parents of two (2) minor children under the age of eighteen years. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Neither party is a member of the United States Military Service or in any branch of the armed forces of the United States or its Allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. 10. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff, Kandice L. Gaiaspy, respectfully requests that this Honorable Court enter a decree in divorce divorcing the parties from the bonds of matrimony. COUNT II EQUITABLE DISTRIBUTION 11. Plaintiff repeats and reaileges the averments of paragraphs 1 through 10 which are incorporated by reference herein. 12. Plaintiff and Defendant possess various items of both real and personal marital properly which is subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests this Court to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. COUNT Iii ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 13. Plaintiff repeats and realleges the averments of paragraphs 1 through 12 which are incorporated by reference herein. 14. Plaintiff requires support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests the Court to award her reasonable alimony pursuant to Section 3701 of the Divorce Code. COUNT IV ALIMONY PENDENTE LITEr COUNSEL FEES, COSTS AND EXPENSES UNDER SECTION 3702 IS. Plmntiff repeats and realleges the averments of paragraphs 1 through 14 which are incorporated by reference herein. 16. Plaintiff has no adequate means of support for herself during the course of this litigation. 17. Plaintiff does not have sufficient funds to pay counsel fees, costs or expenses incidental to this action. 18. Plaintiff has no health insurance other than that presently available to her through Defendant's employment. WHEREFORE, Plaintiff requests the Court to award her alimony pendente lite, counsel fees, costs and expenses. Respectfully submitted, ID N'57. 46801 ~' 132-134 Walnut Street Harrisburg, PA 17101 (717) 238-1484 ATTORNEY FOR PLAINTIFF VERIFICATION 1 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 unsworn falsification to authorities. KANDICE L. GALASPY, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v : NO. 01 - 2605 CIVIL ACTION - LAW : CHARLES D. GALASPY, : Defendant : IN DIVORCE PRAECIPE Please enter the appearance of Hubert X. Gilroy, Esquire and the tirm of Broujos & Gilroy, P.C. on behalf of Defendant Charles D. Galaspy in the above matter. Respectfully submitted, Brou joseY~fo~Jir r~e~Y~'~ 4 North Hanover Street Carlisle, PA ! 70 ! ~5 (7! 7) 24.~5-4.574 the Court of Common Pleas of cUMB~Esi~sECA~TiON County, Pennsylvania DOMESTIC RELATION~ } Dockct Number 01=2605 CIVIL Plaintiff ) PACSES Case Number 166103693 'tD'~°~ CI-IiLRL~S D. C~I.J~PY ) Other State ID Number Defendant AND NOW, to wit on this 26~ DAY OF s~r~B~a, 200~ IT IS HEREBY ORDERED that the O Complaint for Support or O Petition to Modify or (~) Other filed on aY x, 200x in the above captioned APL CONFBP. ENC~ matter is dismissed without prejudice due to: 0 The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: ~'~ ','-~,,~,~ ,,~-,,~ WoOer ID 21005 Sc~ice T~ M KANDICE L. GALASPY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 01-2605 Civil Term CHARLES D. GALASPY, : CIVIL ACTION - LAW Defendant : IN DIVORCE PRAECII~ TO I)ISCONTIN~IE, To the Prothonotary: Please mark the above-referenced divorce action discontinued and dismissed. K~dice ~."Oala~py - Plaimiff c/o COSTOPOULOS & WELCH 1400 North Second Street Harrisburg, PA 17102 (717) 221-0900 KANDICE L. GALASPY, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 01-2605 Civil Term : CHAI~I.I~S D. GALASPY, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Kandice L. Oalaspy, Plaintiff, hereby certify that I am th/s day serving a copy of the foregoing Praecipe to Discontinue upon the persons and in thc manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, at Harrisburg, Pennsylvania, through first class certified mail, prepaid and addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Sweet Carlisle, PA 17013 Gary Kelley 132-134 Walnut S~et Harrisburg, PA 17101 Kandi~e L. Oalaspy- Plaintiff ! c/o COSTOPOULOS & WELCH 1400 North Second Street Harrisburg, PA 17102 (717) 221 -O9O0