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Home My WebLink About06-1629GARY J. TUMA, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. (?p- I?oaG1 Cu?L CAROLE L. TUMA, IN 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 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 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, PA. 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. 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 ELIBIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford St. Carlisle, PA 17013 717-249-3166 GARY J. TUMA, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. No. J4-16.24 ( ttv( %E? , CAROLE L. TUMA, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Gary J. Tuma, through is attorney, Edward S. Finkelstein, Esq., and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Gary J. Tuma, is an adult individual, who currently resides at 6 Surrey Lane, Mechanicsburg, Cumberland County, Pennsylvania since June 26, 1999. 2. The Defendant Carole L. Tuma, is an adult individual, who currently resides at 6 Surrey Lane, Mechanicsburg, Cumberland County, Pennsylvania since June 26, 1999. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 9. The Plaintiff and Defendant were married on June 26, 1999 in Hershey, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. There were no children borne of the marriage. 7. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage is irretrievably broken. After ninety (90) days have elapsed from the date of the service of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. 9. 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. 10. Plaintiff requests the Court to enter a decree of divorce. Edward S. Finkelstein, Esq. Attorney for Plaintiff Attorney ID406869 700 Green St. Harrisburg, PA 17102-3015 717-233-1667 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 Pa.C.S.§4904, relating to unsworn falsification to authorities. Dated:. /I V06 Gary J1 ?I ma, Plaintiff J Cy G r- L Tfl C-:, n GARY J. TUMA, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CAROLE L. TUMA, Defendant No. 06-1629 Civil CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: . SS: COUNTY OF DAUPHIN: I, Edward S. Finkelstein, Esq., who being duly sworn according to law, depose and say that on March 22, 2006 I sent a true and correct certified copy of the Complaint in Divorce in the above-referenced matter to the Defendant, Carole L. Tuma, by certified mail, return receipt requested, addressee only, No. 7002 2410 0000 4123 8572, to 6 Surrey Lane, Mechanicsburg, Pennsylvania 17055. Said return receipt card was returned signed by the Defendant on March 24, 2006 as evidenced by Exhibit "A" attached hereto and made a part hereof. Edward S. Finkelstein Sworn to and subscribed before me This /per- day of April, 2006. Notary Public My Commission expires: NO4aMY11 an 0*)&M9MNM" "mow nbMe MI S C0 OND11M Cow" INCaernl W"O" OM 17, 2004 ¦ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name end.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. 1. Article Addressed to: ('Aa-olc L• OMA- & SL)a-a y (AN ??} ??os Me-A -?i(-SLUrz, A. rar, n ) 13 Agent X ILA L('.f' . / 8. Received by (Printed Name) C. Date of DelNery _.„ 3/2,//040- D. Is dilferentfrorn item l7 ?Yes M ery address below: ? No g Type o Express mail ? Return Receipt for Merchandise 0 C.O.D. 4. Restricted Delivery! (Extra Fee) w Yes z. Ar sfGrf (rrensrer»ntMservicelabel) 7002 2410 0020 4123 8572 PS Form 3811, August 2001 Domestic Return Receipt 10259502-M-1540 Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 0Lc, - 1 1 29 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, 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 Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573