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Home My WebLink About01-4868BROUJOS & GILROY, p.c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 717-243-4574 766-1690 HAROED C. (]ABLER. 111. Plaintiff BETH ANN C. GABI.ER. Defendant : IN TIfE COURJ OF COMMON PLEAS OF : CUMBEREAND COUNTY, PENNSYLVANIA : NO. 01- '/~'(-f' CIVIL ACTION : 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 lbllowing 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 Plaintifl~ You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds tbr divorce is indignities or irretrievable breakdown of the marriage, you may' request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT 1S GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 HAROLD C. GABLER, III, Plaintiff V BETH ANN C. GABLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- '/~'t,,~ CIVIL ACTION IN DIVORCE COMPLAINT Plaintiff, Harold C. Gabler, III, by his attomeys, Broujos & Gilroy, P.C., sets tbrth the following: 1 Plaintiff; Harold C. Gabler, III, is an adult individual residing at 149 Fifth Avenue, Chambersburg, Franklin County~ Pennsylvania. 2 Defendant, Beth Ann C. Gabler, is an adult individual residing at 803 East Catherine Street, Chambersburg, Franklin County, Pennsylvania. 3 The parties were married on August 20, 1983~ in Camp ttill, Cumberland County, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 There have been no prior actions lbr divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff: 6 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is iiretrievably broken. WHEREFORE~ the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the DefEndant. BROUJOS & GILROY, P.C. 717 - 243-4574 I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unswom falsification to authorities. HAROLD C. GABLER, 111, Plaintiff V BETH ANN C. GABLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O I - q~'(, ~ CIVIL ACTION : : IN DIVORCE ACCEPTANCE OF SERVICE I, Beth Ann C. Gabler, hereby acknowledge that I was served with a copy of the divorce complaint, including a Notice to Defend and Claim Rights, on the~'~day of August, 2001. Date: Beth Ann C~. (~able~/~' -- BROUJOS & GILROY, P.c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 717 243 4574 766-1690 HAROLD C. GABLER, 111, Plaintiff V BETH ANN C. GABLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 01-4868 CIVILTERM : : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE tINDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divome Code was filed on August 17, 2001. 2. Defendant acknowledges receipt and accepts service of the Complaint On or about August 21,2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. I understand that 1 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 1 verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: Harold C. Gabler, Ill,=Plaintiff BROUJOS dr GILROY, P.c. ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 717-243-4574 766-1690 HAROLD C. (;ABLER, 111, Plaintiff V BETH ANN C. GABLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01 -4868 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(e) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on August 17, 2001. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about August 21,2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification to authorities. Date: HAROLD C. GABLER, III, Plaintiff v BETH ANN GABLER, Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 01- 4868 CIVIL : : CIVIL ACTION - LAW : AFFIDAVIT OF gERVICE /D/~Dt I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant, Harold C. Gabler, III, by certified mail on August 21, 2001. A copy of the Certified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. Hu ~~ ' ~Rb°e.~~?;!t!.~1re 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before me this /~t~- day of ~.IZ~, 2001 Notarial Seal Bridget Ann Corcoran, Notary Public Carlisle Boro, Cumberland County My Commission Expires June 10, 2002 · 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 mailpiece, or on the front if space permits. 1. Article Addressed to: Beth Ann C. Gabler 803 Catherine Street Chambersburg, PA 17201 A. Received by (P/sese Print Clearly) D. Is deliver 17 Yes If YES, enter delivery address below: r-i No 3. Service Type ~ Certified Mail [] Express Mail [] Registered ~ Return Receipt for Merchandise [] Insured Mail [] C.O.D. 2. Article Number (Copy from service ~abel) ~ 7099 3400 0018 5046 3342 PS Form 3811, July 1999 Domestic Return Receipt I02595-00-M-0952 HAROLD C. GABLER, III, Plaintiff V BETH ANN GABLER, Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01- 4868 CIVIL : : CIVIL ACTION - LAW _. PRAECIPE TO TRANSMIT RECORi~ TO THE PROTHONOTARY: 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 (X)3301(c) ()3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: August 21, 2001, First Class Certified Mail, Return Receipt Requested, Restricted Delivery. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: November 21, 2001; Defendant: November 25, 2001. (b) (1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: ; (2) Date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 28, 2001. (c) Date Defendant's Waiver of Notice in §3302(c) Divorce was filed with the Prothonotary: December 4, 2001. Hubert~'X~Esquire Attomeaf for Plaintiff Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 HAROLD C. GABLER, III Plaintiff VERSUS BETH ANN GABLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of .,~. PEN NA. NO. 01 - 4868 DECREE IN DIVORCE AND NOW, DECREED THAT AND HAROLD C. GABLER, III BETH ANN GABLER IT iS ORDERED aND , PLAINTIFF, , DEFENDANT, 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; BY The COUrt: Jo PROTHONOTARY