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Home My WebLink About04-6309 'I Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04- Co30'1 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE v. Mindy Marie Martin, 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 will proceed without you and a decree in 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 at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 II Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04- (P109 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE v. Mindy Marie Martin, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Gary W. Martin, an adult individual, currently residing at 907 Newville Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Mindy Marie Martin, an adult individual, currently residing at Apt 1A, Chestnut Street, Mount Holy Springs, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on April 20, 2001 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since October 13, 2004 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. 12. All property has previously been distributed to both parties satisfaction. 13. There has been no children born of the parties during the course of this marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted TURO LAW OFFICES ~;;~ ;If Date (~ ~"~tz, uire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff I' VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. 94904 relating to unsworn falsification to authorities. / d. - J (1- 0 'I Date ~ /PZs4~ Gary WMartin CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint in Divorce upon Mindy Marie Martin, by depositing same in the United States Mail, Certified Return Receipt on the , (Q j#', day of ))"c~- J::,cy , 2004, from Carlisle, Pennsylvania, addressed as follows: Mindy Marie Martin Casses Chiropractic 313 South Hanover Street Carlisle, PA 17013 TURO LAW OFFICES r~ Galen R. Waltz, squi 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 (:1 1--_' 1 ~ c.:.." ,-.. ~ ~...: ..) '_ I .J.:. - -n ~ r-: ::-;:1 r"~ I ., :' ;('1:~ ! C) H,"; , .. "- ~ C{- , .. , i \. ,) tI( - ", , , Yv ....,>>: .. ~',' l - ...L"( ~ -cJ f".) . i 01 ..~ W F ...,< .,) ..;:. ~ '-.} J- '1'1 1- . Ii Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-6309 CIVIL TERM Mindy Marie Martin, Defendant CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Complaint in Divorce filed in the above captioned case upon Mindy Marie Martine, by certified mail, return receipt requested on December 16, 2004 addressed to: Mindy Marie Martin Casses Chiropractic 313 S. Hanover Street Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated December 17,2004. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PAC.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES S-b3/oS- Date . L' alen R. Walt q 28 South Pitt Stree Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff SENDER: \) If ore e c orY\ leu (l t .. ~ " .~ ~ ~ ~ > e ~ = o Complete items 1 and/or 2 for additional services Complele items 3, 4a, and 4b. o Print your name and address on the reverse of this form $0 that we can return this card 10 you. o Attach this form to the frOll1 althe mailpiece, or on the back if space does not permit o Write "Return Receipt Requested' on the mailpiece below the article number. o The Return Receipt will show 10 whom the article was delivered and the dale delivered I also wish to receive the follow. ing services (for an extra fee): c o -g 3. Article Addressed to: <;; Q. E o u ml('d~ f{l6.fie Nllfirhn Lu SS::'.<:, CnWC(7IClCHl Ji~ 5 }iCiflCVfr.st CC1rli)\f Q~ Ile\ ~ 5. Received By: oj u .~ .. Ul a Q; -- u '4a. Article Number _ q~ -WI ;i~IO~at3cUcqsG= E .--- = 4b. Service Type /'; o Registered 0'Certified a: '" D 9P'ress Mail D Insured .~ [l:YRelurn Receipt for Merchandise D COD ~ 2 ~ ~ '" ~ ~ '" .. 1. 0 Addressee's Address 2. 0 Restricted Delivery ~ ~ o >- !!2 7. Date of Del" ery 7 8. ddressee's Address (Only if requested and fee is paid) 102595-99-B-0223 Domestic Return Receipt \~,., - II 1- Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-6309 CIVIL TERM Mindy Marie Martin, Defendant CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on December 16, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. ~4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 5' - / 7- c )~ Date ..-_.--;7 ~L~~/) Gary W. Martin - ,. -.:1 C. - II r Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-6309 CIVIL TERM Mindy Marie Martin, Defendant CIVIL ACTION - LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (9 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. S4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. s - /;- 0 )- Date ..---------~'_.--------" , / .~, ') (-. - -------- II I- Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-6309 CIVIL TERM Mindy Marie Martin, Defendant CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on December 16, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. 512010J) Date I TI! [/)(1 CI!Iv "{YW,'I!! 7 7Y1(j~ Mindy Mari4 Martin ~.,'" (:" ';:~, ~\ ,I < , II Gary W. Martin, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-6309 CIVIL TERM Mindy Marie Martin, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 S (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: Certified. Returned Receipt mail delivered on or about December 17, 2004. 3. Date of execution of the Affidavit of Consent required by S3301(c) of the Divorce Code. By Plaintiff: May 17, 2005 By Defendant: May 20,2005 4. Related claims pending: None. Date the Waiver of Notice in S3301 (c) divorce was filed with the Prothonotary: By Plaintiff: May 24, 2005 By Defendant: May 24, 2005 ./ -.\, " ...". C.. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Gary W. Martin Plaintiff No. 04-6309 VERSUS Mindy Marie Martin Defendant DECREE IN DIVORCE AND NOW, 2005 DECREED THAT Gary W. Martin AND Mindy Marie Martin , IT IS ORDERED AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; A out E 2 . =;l