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HomeMy WebLinkAbout06-0444 ) .. 0I.e _lJ41.f CI'O l~'-:r ~ :::--~ r ~ -; SAMIR R. GANDHI, ESQ. MODY & GANDHI, LLC ATTORNEYS AT LAW 233 CENTRAL AVENUE METUCHEN, NEW JERSEY 08840 732.548.7512 :'., c. r C~, _,) ~. 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 in indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of Judicial Support, 32 South Bedford Street, Carlisle, P A (717) 249-3166 or 800-990-9108 (in PA only) 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 CET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawver Refferal Information Service (Name) 32 South Bedford Street, Carlisle, P A 17013 (Address) (717) 249-3166 or (800)-990-9108 (in P A onlv) (Telephone Number) ,. ... 401 MODY & GANDHI, LLC. ATTORNEY AT LAW 233 CENTRAL AVENUE METUCHEN, NEW JERSEY 08840 TEL: 732.548.7512 FAX: 732.548.7514 ATTORNEY FOR THE PLAINTIFF PLAINTIFF SUPERIOR COURT OF NEW JERSEY CUMBERLAND COUNTY FAMILY COURT DIVISION ANSHU GUPTA DOCKET # Dt.. ,4l.f '-( (},'ulL Y0Llrj VS. SAN DEEP K. GUPTA CIVIL ACTION DEFENDANT COMPLAINT FOR DIVORCE COMPLAINT UNDER SECTION 3301( c ) OR 3301 ( d ) OF THE DIVORCE CODE The Plaintiff, Anshu Gupta residing at 5602 Pinehurst Way, Mechanicsburg, Pennsylvania hereby says by way of complaint: 1. The Plaintiff Anshu Gupta currently resides at 5602 Pinehurst Way, Mechanicsburg, Pennsylvania 17050 and is a bona fide resident of the Commonwealth of Pennsylvania and has so been for at least six months immediately preceding the filing of this complaint. 2. The Defendant Sandeep K. Gupta currently resides at 5602 Pinehurst Way, Mechanicsburg, Pennsylvania 17050 and is a bona fide resident of the Commonwealth of Pennsylvania and has so been for at least six months immediately preceding the filing of this complaint. 3. The Plaintiff and Defendant were married to each other on November 21, 1999 in the city of New Delhi in the country ofIndia by way of Hindu religious marriage ceremony. I .. .. 4. The marriage between the parties has been irretrievably broken. 5. That the Plaintiff has been advised that counseling is available and that the Plaintiff may have rights to request that the Court require the parties to participate in such counseling. I 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 P A.C'.S. & 4904, relating to unsworn falsification to authorities. Dated: \lILSloS- VERIFICATION OF COMPLAINT !, the undersigned, being duly sworn, according to law upon our oath, depose and say that: 1. I am the plaintiff in the foregoing complaint to which this is annexed. 2. The allegations made in the complaint are true to the best of my knowledge and belief. The complaint is made in truth and good faith and without collusion for the causes set forth therein. 3. To the best of my knowledge and belief, the matter is not the subject matter of any other action pending, nor is any such proceeding contemplated at this time. 4. ! certify that the foregoing statements made by me are true. ! am aware that if any of the foregoing statements made by us are willfully false, We, are subject to punishment. Sworn & Subscribed before me (/rY' On this b day of , 2005 i .. / ~ ., f I i Ii ) 'i1lik CfM)\G ANSHU GUPTA i,.. Plaintiff 2 ;D ~ r"~': ". ,~ f!:. ....... , ...0 ., .() ~'u 11'1 "- II) :",,:,> -..t w () 10 ...c: U ( - ~ (,..J p:: ~,-... ~ Co'] ~ GANDHI & ASSOCIATES 233 CENTRAL AVENUE METUCHEN, NJ 08840 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PLAINTIFF ANSHU GUPTA PLAINTIFF : COURT OF COMMON PLEASE : CUMBERLAND COUNTY : FAMILY COURT : DIVISION VS. SANDEEP K. GUPTA o(.-L[tJ4 .0'" - iJS~ Civd : DOCKET NO. etv ~L./il CiVt'lltri'f\ DEFENDANT : CIVIL ACTION : AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on jO.nWtr~ J-t.J1 200v 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. 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. Dated: Sworn and subscribed before me On this da~ of '7'ttJ' 2006 ~~v NotariaJ Seal Cad1een Pryor, Notary Public CIly Of Harrisburg, Dauphin County MyCcmnission Expires July 15, 2006 Member. Pennsylvania Association Of Notaries ;~""\, 2006-06-26 11:52 Commonwealth of PA 717-772-2168 >> 5172415031 P 2/2 GANDHI & ASSOCIATES 233 C.F.NTRAL A VENUE METUCJIEN, NJ 08H40 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PI.AINTJFF : COURT 01; COMMON PI,EASE : CUMllERLAND COUNTY ANSllU GUPTA. PLAINTIFF, : FAMILY COlJRT : DIVISION VS. SANDEEP K. GUPTA, t:j.-I.J t.fI : DOCKET NO. Q4 lli-5-CIVIL nRFEN1>ANT. : CIVIJ. ACTJON : W ATVER OF NOTICE OF INTENTION : TO REQlJl:;ST ENTRY OF ^ DIVORCE : DECREE UNDER ~33()1 (c) ANn ~3301 (d) : OF THE OIVORCE CODE 1. l.consentto the enlry of a final decree of divorce withoul nolice. 2. I understand that I may lose my rights concerning aJimony, division of pmperty, lawyer's fees or expenses in dn not claim them before a divorce is gran Led. J. I understand that I will nol be divorced until a divorce decree is enlered by the Court and that a copy orlhe decree will be sent to me immedialely utter it is filed with the pmthonnlary. I verify that the statemenls made in this Affidavit are true and correct. J understand that false statemenls herein are made su~iect to the penal lies or 18 Pa. e.s. section 4904 relating lo unsworn falsification to authorities. Dated: .... ANSlJU G Plaintiff c_ :.::1 , :1 -~-l ~,.) t_~ GANDHI & ASSOCIATES 233 CENTRAL AVENUE METUCHEN, NJ 08840 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PLAINTIFF ANSHU GUPTA PLAINTIFF : COURT OF COMMON PLEASE : CUMBERLAND COUNTY : FAMILY COURT : DIVISION VS. DEFENDANT c~-4if'l : DOCKET NO. -0'1' 11:J5 - Ci V \' \ : CIVIL ACTION SANDEEP K. GUPTA : AFFIDAVIT OF CONSENT 4. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on Jon u. a.'{ '-) 1..4 I 2..00 LP . 5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 6. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. Dated: ~k.~ SANDEE K. GUPTA Defendant Sworn and subscribed before me On this day3Cbf ~2006 (! Ei:-t~1 ~~ Notarial Seal CaIhIeen Pryor, Notary Public ClyOf Harrisburg, Dauphin County My Ccrmission Expires JIJy 15, 2006 Member. Pemsytvania Association Of Nolaries [-'~' c_ :....'\..) (.11 GANDHI & ASSOCIATES 233 CENTRAL AVENUE METUCHEN, NJ 08840 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PLAINTIFF : COURT OF COMMON PLEASE : CUMBERLAND COUNTY ANSHU GUPTA PLAINTIFF : FAMILY COURT : DNISION VS. SANDEEP K. GUPTA d--L/I/L( : DOCKET NO. ~ IIS5-CIVIL DEFENDANT : CNIL ACTION : WAIVER OF NOTICE OF INTENTION : TO REQUEST ENTRY OF A DIVORCE : DECREE UNDER ~3301 (c) AND ~3301 (d) : 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 my 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. section 4904 relating to unsworn falsification to authorities. Dated: ~kG~ SANDE P K. GU TA Defendant (" GANDHI & ASSOCIATES, LLC 233 CENTRAL AVE METUCHEN, NEW JERSEY 08840 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PLAINTIFF ANSHU GUPTA, COURT OF COMMON PLEAS CUMBERLAND COUNTY FAMILY COURT DIVISION CJI. -'IllY DOCKET #-e4 1155'-CIVIL PLAINTIFF, VS: SANDEEP K. GUPTA, CIVIL ACTION DEFENDANT. CERTIFICATION I, SAMIR R. GANDHI, ESQ. of full age, hereby certify: 1. That I am an Attorney at Law in the State of New Jersey with offices located at 233 Central Ave, Metuchen, New Jersey 08840 and represent the Plaintiff in the above-entitled cause of action. That I am also licensed to practice in the Commonwealth of Pennsylvania. 2. That on or about January 24, 2006, a Complaint for divorce was filed with the Court of Common Pleas, Cumberland County, Family Court Division under docket no 04-1155-CIVIL (See Exhibit A). 3. That the Defendant, Sandeep K. Gupta, was served with the summons and a copy of the Complaint on or about November 29,2005. 4. That the Defendant, Sandeep K. Gupta, has agreed not to file Answers to the Complaint and has executed an Affidavit of Consent on May 30, 2006 (See Exhibit B). 5. That the Defendant has consented to the entry of a final decree of divorce and has waived his right to notice of intention to request entry of a divorce decree under ~ 3301( c) and 3301 (d) (See Exhibit C). 6. That I am making this Certification in support of the Request to Enter a Divorce Decree for the parties. 7. That I hereby certify that the foregoing statements made by me are true to the best of my knowledge and information. I am further aware that if any of the foregoing statements made by me are willingly false, I am subject to punishment. Dated: July 6, 2006 MODY & GANDHI, LLC. ATTORNEY AT LAW 233 CENTRAL AVENUE METUCHEN, NEW JERSEY 08840 TEL: 732.548.7512 FAX: 732.548.7514 o ~ "'"~. -." [i~l,~'.;';: "--} g O'i C>l.-LNI..{ (3~,L 't~ :::.:;. o ...., ~ :::::1 ~ [~1:n r\) C:; ;.:;~ ..::- .~T? c.::.; .::::~~: (-~; 2::"", -,. rl ~~ : I :J5 .....;: 'Co..., ~_/ , ATTORNEYFORTHEPLAJNTWF !:::~. 4'.... j.;;" - >.~,.... i.... . ....:-'-.."..:~ PLAINTWF ~'~- ~ -=2 c...;> SUPERIOR COURT OF NEW JERSf5IY CUMBERLAND COUNTY FAMILY COURT DMSION ANSHU GUPTA VS. DOCKET # SANDEEP K. GUPTA CIVIL ACTION DEFENDANT COMPLAINT FOR DIVORCE COMPLAINT UNDER SECTION 3301( c ) OR 3301 ( d ) OF THE DIVORCE CODE The Plaintiff, Anshu Gupta residing at 5602 Pinehurst Way, Mechanicsburg, Pennsylvania hereby says by way of complaint: 1. The Plaintiff Anshu Gupta currently resides at 5602 Pinehurst Way, Mechanicsburg, Pennsylvania 17050 and is a bona fide resident of the Commonwealth of Pennsylvania and has so been for at least six months immediately preceding the filing of this complaint. 2. The Defendant Sandeep K. Gupta cUlTently resides at 5602 Pinehurst Way, Mechanicsburg, Pennsylvania 17050 and is a bona fide resident of the Commonwealth of Pennsylvania and has so been for at least six months immediately preceding the filing of this complaint. 3. The Plaintiff and Defendant were married to each other on November 21, 1999 in the city of New Delhi in the country of India by way of Hindu religious marriage ceremony. 1 Sworn & Subscribed before me On this l..~y of , 2005 " 4. The marriage between the parties has been irretrievably broken. 5. That the Plaintiff has been advised that counseling is available and that the Plaintiff may have rights to request that the Court require the parties to participate in such counseling. I 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 P A.C.S. & 4904, relating to unsworn falsification to authorities. Dated: l ( ( 2..8105" VERIFICATION OF COMPLAINT I, the undersigned, being duly sworn, according to law upon our oath, depose and say that: 1. I am the plaintiff in the foregoing complaint to which this is annexed. 2. The allegations made in the complaint are true to the best of my knowledge and belief. The complaint is made in truth and good faith and without collusion for the causes set forth therein. 3. To the best of my knowledge and belief, the matter is not the subject matter of any other action pending, nor is any such proceeding contemplated at this time. 4. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by us are willfully false, We, are subject to punishment. 2 Sworn and subscribed before me On this day3Cbf ~2006 (!H::t../t.i.u.,)~ NolariaJ Seal CaIIieen PIyor, NoIaIy PI.dc ClyOf Harrisburg, ~ ColI1ly Myo.,.rlisaiun Expires J~ 15, 2006 Member. Pennsvtvania Association Of Notaries GANDHI & ASSOCIATES 233 CENTRAL AVENUE METUCHEN, NJ 08840 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PLArnTWF PLAINTIFF : COURT OF COMMON PLEASE : CUMBERLAND COUNTY : FAMILY COURT : DMSION ANSHU GUPTA VS. SANDEEP K. GUPTA : DOCKET NO. 04 - II 55 - c.i V l \ DEFENDANT : CIVIL ACTION : AFFIDAVIT OF CONSENT 4. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on 5o.nu ll'f,,\ 1-4 I l.D0 tp . 5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 6. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. Dated: ~j(~ SANDEE K. GUPTA Defendant ~kG~ SANDE P K. GU TA Defendant GANDHI & ASSOCIATES 233 CENTRAL AVENUE METUCHEN, NJ 08840 TEL - 732.548.7512 FAX - 732.548.7514 ATTORNEY FOR THE PLAINTIFF : COURT OF COMMON PLEASE : CUMBERLAND COUNTY ANSHU GUPTA PLAINTIFF : FAMILY COURT : DNISION VS. SANDEEP K. GUPTA : DOCKET NO. Q4-1155-CML DEFENDANT : CNIL ACTION : WANER OF NOTICE OF INTENTION : TO REQUEST ENTRY OF A DNORCE : DECREE UNDER ~3301 (c) AND ~3301 (d) : OF THE DNORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose my 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. section 4904 relating to unsworn falsification to authorities. Dated: ~ ~ '- c:: ir :.:~J ;i f"".) ANSHU GUPTA IN THE COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY, PENNSYLVANIA SANDEEP K. GUPTA CIVIL DIVISION NO. 06-444 CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Complaint for Divorce. I certify that I am the Defendant. J Cv,,,,- -' ~ t;~ o~_ Date ~~~ K~~ Sandeep K. upta, Deft ndant 5602 Pinehurst Way Mechanicsburg, Pennsylvania 17050 '" f-..:I ,..-:::J ~~ (~ -n ~ 1 0-' ~ ~,) r- ~~- 0.:' ANSHU GUPTA IN THE COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY, PENNSYLVANIA SANDEEP K. GUPTA CIVIL DIVISION NO. 06-444 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry for a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 9330l(c) 3301 (d)(l) of the Divorce Code. 2. Date and manner of service of the complaint: January 30, 2006 served by Hand Delivery. Acceptance of Service attached. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) ofthe Divorce Code: By Plaintiff MAY 30, 2006 ; By Defendant MAY 30. 2006 (b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: _NONE 5. Complete either (a) or (b). a. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is at';ached: Hand Delivery on August 10,2006. (b) Date of plaintiffs Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: JULY 11, 2006 Dated: October 24,2006 Date defendant's Waiver of Notice in 93301 (c) Divorce was the Prothonotary: JULY 11 2006 <;~ ", ,'''Ii Of. l+: l+:Ef. '" "':Ii :Ii "'Ef. "''f. l+:Ef.'f.l+:'f."'l+:"''''''' 'f.l+:'f."''f.'"'''''''''''' "''''''''''''' '" "',.,'" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Anshu Gupta VERSUS Sandeep K. Gupta PENNA. NO.06-444' Civil-Term DECREE IN DIVORCE AND NOW,~ ~ DECREED THAT Anshu Gupt.a AND Sandeep K. GUpt.n ~ , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. J. 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; ~~ Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claim is PROTHONOTARY '" '" ,'''I, '" '" '" '" '" "'''' "'''''''''''''''' "'''''''''''''''''''''' "''''''''''''''''''''''''' oft ~ ~ ~/;t-. 1rJ- I - ef ~p~ ~ -r? dJ(j- I-d ...'