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HomeMy WebLinkAbout05-0773KAREN L. GUMMO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW GREGG D. GUMMO, NO. d -'5? 7'10 CIVIL TERM 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 KAREN L. GUMMO, Plaintiff V. GREGG D. GUMMO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. US- 77-3 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Karen L. Gummo, an adult individual currently residing at 312 College Hill Road, Enola, Cumberland County, Pennsylvania. 2. Defendant is Gregg D. Gummo, an adult individual currently residing at 312 College Hill Road, Enola, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 19, 2000, in Newville, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. 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, 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' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Brian C. Bornman, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. r; DATE: 2 - I _ Q?) Karen L. Gummo, Plaintiff /l 0 4 KAREN L. GUMMO, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYL\ VS. : CIVIL ACTION -LAW GREGG D. GUMMO, : NO. 05-773 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 23`d day of March, 2005, comes Brian C. Bornman, Attorney for Plaintiff, Karen L. Gummo, and states that he mailed a certified copy of a Complaint in Divorce to the Defendant, Gregg D. Gummo, at his addrt College Hill Road, Enota, Pennsylvania, by certified mail, restricted delive, receipt requested. A copy of said receipt is attached hereto indicating service on March 18, 2005. Brian C. Bornman, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 Sworn and subscribed to before me this j.3 day of j jjaAe?A_ , 2005. NOTARY PUBLIC id true of 312 return made NOTARIAL SEAL NDBNI J. GOSHORN, NOTARY PUBLIC CARLISLE BORO., CUMBERLAND COUNiY MY COMMISSION EXPIRES APRIL 17, 2007 . 0 f Pasisge $ ? I Genitiad Fee Z W ? ? ?p Posimar l?„? 7 0 Return Receipt Fee (Endorsement Required) Here 00 t 1 Q Restricted Oellvery Fee l a t R ? equ re l (Endorsemen I Total Postage & Fees $ QQ "!1 _ f1J sent ? D St t A t N 6 u«, nA 0 ry ree p . or PO Box NO City. State. 9P?d rv ¦ Complete items 1, 2, and 3. Also complete A. SI lure item 4 if Restricted Delivery is desired. X ¦ 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 mailplece, or on the front if space permits. /P OV 1. Article Addressed to: I D. Is delArery ad If YES, enter Q• bumtltcb is Il fhll ,?d, l4, p??7oas ? Agent ? Addre tad?lame) C. Date of Deli l/?Lvr?ritr s different from item. l9 ? Yes VefyaVii-jW below: ? No 3. Ice Type ` ' Certlfletl Mail Y] Express Mail Registered ? Return Receipt for March ? Insured Mail 0 C.O.D. 4. Restricted Delivery? (E M Fee) Yes 2. Article Number ,nn x oa (rransfer fmm sen1ce labeq 700/ ?J0 Oobq /0/81 790 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M- 540 W/,, t .> o PQ N Curtis R. Long Prothonotary office of the i3rotbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor OE -'IV CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Sauare • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573