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Home My WebLink About06-2810 KEITH A. GUTSHALL, Plaintiff VS. NICHOLE GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O -0 /6 Civil Term 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 KEITH A. GUTSHALL, Plaintiff VS. NICHOLE GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. GAG a P?0 Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE Plaintiff is Keith A.Gutshall, a competent adult individual, who resides at 83 Southside Drive, Carlisle, Pa. 17013. 2. Defendant is Nichole Gutshall, a competent adult individual, who resides at 798 Roxbury Road, Newville, Pa. 17241. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 24, 1995 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together, namely, Gabryel Alexis Gutshall, date of birth, December 10, 1995, and Ethan Edward Gutshall, date of birth, May 27, 1998. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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 unworn falsification to authorities. /? Q (p Date: ;tA a. ith A. Gutshall, 1 Miff Respectfully submitted, Jan/Adams, Esquu No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF W W d c C) m r_ ma n - c (-i z :ern P r , T O GO KEITH A. GUTSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 06 - 2810 Civil Term NICHOLE GUTSHALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this May 26, 2006, 1, Jane Adams, Esquire, hereby certify that on May 22, 2006, a certified true copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT was served, via certified mail, return receipt requested, addressed to: Nichole Gutshall 798 Roxbury Rd. Newville, Pa. 17241 ' . `.. , INo.79 465 6 outh Pitt Street arlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF C) ? 0 W -7 C7 Yi •' cr _ Z? 23 ? "?C Ln , ?.i KEITH A. GUTSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06 - 2810 Civil Term NICHOLE GUTSHALL, ACTION IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT OF SEPARATION The parties to this action separated on December 26, 2005, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. §4904 relating to unsworn falsification to authorities. Date: b a AotiL'A ith A. Gutshall, intiff Mn, t*? czt m 79 'j cr, r-n C4 { KEITH A. GUTSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 2810 Civil Term NICHOLE GUTSHALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this February 16, 2008, I, Jane Adams, Esquire, hereby certify that on February 8, 2008, a certified true copy of the AFFIDAVIT OF SEPARATION was served upon the following person, via certified mail, return receipt requested at the following address: Nicole Gutshall ¦ Complete items 1, 2, and 3. Also complete 83 Southside Drive item 4 if Restricted Delvery Is desired. ¦ Print your name and address on the reverse Newville, Pa. 17241 so that we can return the card to you. DEFENDANT ¦ Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed to: NICOLE GUTSHALL 83 SOUTHSIDE DR NEWVILLE PA 17241 A. Signature X C ? Agent ? Addressee B. by r•,.,?•/q??/){I ) C. D/pte Delivery V/`? ar Ll? ?. D. Is delivery address dlflerent from'f n 1? ? Y86 If YES, enter delivery address betaw: ? No x 0 Express i4aH C3 Return Receipt for Merchandisa ? Insured Md 0 C.O.D. 4. Restricted DeMwtaryt pft F" ? Yes 2. Articis Number (lw"ib?ftmseMoe mw 7007 2680 0003 0341 3398 Ps Form 3811, February 2004 Domestic Return Receipt t0?i6-021rFtbq ; Respectfully Submitted: F J e Adams, Esquire No. 79465 4 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF C - n T ?7, 160 , t 3i c KEITH A. GUTSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 2810 Civil Term NICOLE GUTSHALL, ACTION IN DIVORCE Defendant PRAECIPE TO CORRECT CAPTION TO THE PROTHONOTARY: Please be advised that Defendant's name is spelled Nicole Gutshall. Kindly correct the caption of the case as set forth above. Date: ? 6s' lql Respectfully Submitted: )fhe Adams, Esquire I . No. 79465 7 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff s .,?- r ?? ?? KEITH A. GUTSHALL, Plaintiff vs. NICOLE GUTSHALL, Defendant To: Nicole Gutshall 83 Southside Drive Newville, Pa. 17241 DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 2810 Civil Term ACTION IN DIVORCE NOTICE TO PLEAD You are hereby notified to file a written response to the enclosed Plaintiffs Petition for Economic Relief within Twenty (20) days from service hereof or a judgement may be entered against you. Respectfully submitted, Date: J e Adams, Esquire . No. 79465 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF KEITH A. GUTSHALL, Plaintiff vs. NICOLE GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 2810 Civil Term : ACTION IN DIVORCE PLAINTIFF'S PETITION FOR ADDITIONAL CLAIMS AND NOW COMES, Petitioner, Keith A. Gutshall, by and through his Attorney, Jane Adams, Esquire, and respectfully represents the following: COUNT I - EQUITABLE DISTRIBUTION OF PROPERTY 1. Plaintiff and Defendant were married on June 24, 1995 and were separated on December 26, 2005. 2. Plaintiff filed a Complaint in Divorce under the above-captioned docket number on May 17, 2006. 3. During the course of the parties' marriage, the parties acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 4. Plaintiff and Defendant have been unable to agree as to an equitable division of said marital property. 5. Plaintiff is seeking an equitable division of all marital property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Plaintiff and Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. Date: (2//6 16g, Respectfully submitted, "J one Adams, Esquire I /D. No. 79465 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this PETITION 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. Date: ?p-3 - O? A-,L? V -A 44ith utshall laintiff f? T? Qs Q A vi 1, J?l KEITH A. GUTSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06 - 2810 Civil Term NICOLE GUTSHALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 17, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 1 verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: o ic le utsha 1, fe ant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE DIVORCE CODE 1. I consent to 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904,mi*n1 to unsworn falsification-lo authorities. Date: ( 6 f l (/ Ni e Gutshall, D e t r .. cr 'n. KEITH A. GUTSHALL, Plaintiff vs. NICOLE GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 2810 Civil Term ACTION IN DIVORCE PRAECIPE TO WITHDRAW CLAIM TO THE PROTHONOTARY: Please withdraw Plaintiff's Petition for Additional Claims, which contained a count for Equitable Division of Property. Respectfully Submitted: Date.- I I61o9 ,11T No. 79465 Ya W . South St. rlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ? ;?> . . ?, ? ?- .?3 ?Fti? - ??,?? ?. KEITH A. GUTSHALL, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 06 - 2810 Civil Term NICOLE GUTSHALL, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 17, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 1 verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. Date: aAGutshall, rth Pla tiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 0301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if l do not claim them before a divorce is granted. 3. 1 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. §4904 relating to unsworn falsification to authorities. Date: I 9 / ith A. Gutshall, Plaint ff ? C., eta . ? KEITH A. GUTSHALL, Plaintiff vs. NICOLE GUTSHALL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 2810 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce decree: Code. 1. Ground for divorce: irretrievable breakdown under 3301 c of the Divorce 2. Date and manner of the service of the Complaint: Served certified mail, restricted delivery, received by Defendant on May 22, 2006. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: January 8, 2009. By Defendant: January 6, 2009. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 7, 2009. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 9, 2009. itted: Date: t • 01, Jam,= Adams, Esquire 1. o.79465 17 South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff C rr; r ? ? pr. CO IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH A. GUTSHALL, Plaintiff V. NICOLE GUTSHALL, Defendant DIVORCE DECREE AND NOW, </d..?a+r? t?rd Zao it is ordered and decreed that KEITH A. GUTSHALL, Plaintiff , plaintiff, and NICOLE GUTSHALL, Defendant defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NO. 06 - 2810 Civil Term NONE. By the Court, Prothonotary t .. L e4 r