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HomeMy WebLinkAbout06-6173:/ CRAIG P. GALIC, Plaintiff vs. KAREN D. GALIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OCR ~' (o ~~ ~,~,c`r~ CIVIL ACTION -LAW 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. 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, Pennsylvania. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 4th Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 CRAIG P. GALIC, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~y~ ,1.~ vs. NO. C~~ .... ~ I t~ ~tv ~ ~~ KAREN D. GALIC, :CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301d OF THE DIVORCE CODE 1. Plaintiff is Craig P. Galic, an adult individual who resides at 1455 C State Road, Duncannon, Perry County, and Pennsylvania 17020. 2. Defendant is Karen D. Galis, an adult individual who resides at 212 Rosemont Avenue, New Cumberland, Cumberland County, and Pennsylvania 17070. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on November 8, 2003, at Mechanicsburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that plaintiff has the right to request that the court require that the parties participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce /C~ Timothy J. O'Connell, Esquire TURNER AND O'CONNELL 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff Verification I verify that the statements made in the foregoing Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Craig P. Galic Date: ~ ~~ Q~ CRAIG P. GALIC, : IN THE COURT OF COMMON PLEAS Plaintiff ~~~ COUNTY, PENNSYLVANIA :CUMBERLAND NO. v. KAREN D. GALIC, :CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TD 'THE DEPEi11DANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. Plaintiff s Affidavit Under Section 3301(d) of the Divorce Code l . The parties to this action have continued to live oe4parate and apart for a period of at least two years, since September 20 2. The marriage is irretrievably broken. 3. I understand that I may to exr enstes iif I do not laimo themlbefore divorce property, lawyer's fees o p is granted. I verify that the statements made in thide subaect t the penalt es of 18 Pa. C.S.A. understand that false statements herem are ma ~ Section 4904 relating to unsworn falsi:iication to authoriiies. / - - Q~ Date: ~~ Z~ 0(P Craig P. alic ~~ ~ w {~ .-~ D ~'~. 1 ~ ~, Q c7 _ ~ O ~~ 4..~ ~ Ta a-- ~ _~ a~;~, c.y ~-n ~/ ~ a -r ` _ ~ ~ :;1 j CY% ~ -_ -r' + ~. __ =~ " - ~ ~ ~ E~~"~ ~~ _ # =- =< CRAIG P. GALIC, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.06-6173 CIVIL TERM KAREN D. GALIC, :CIVIL ACTION -LAW Defendant IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint under Section 3301(c) filed in the above captioned action. Date: ~ ( ~ 0 (,,. Karen D. Galic ll~(-s~-lc~Zi Social Security No. C'; ~ ~- G~ ~ -r~t ~ ~ . ..~..j i t . ~~ .- .~ Y: ~ _ _ _ ~ ~ ~ ~' "J ~'~ ` L ;? .. { -'j ~ ~.+.~ _'~ CRAIG P. GALIC, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO.06-6173 CIVIL TERM KAREN D. GALIC, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 23, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed frum tt.e 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. WAIVER OF NOTICE OF INTENTION TO RE4UEST ENTRYOFA DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. Section 4904 relating to unsworn falsification to authorities. l _ ~~K.~v Date: Craig P. Ga c Social Security No. l ~ 1 ~~ ~~ ( o E:1 ~ ~ .ara _,~ ~ ,j= ~ ~ ~ ~ ~ s :. :_: .,: -T. ~- __. =t._ .~" t`.~ ..~ CRAIG P. GALIC, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-6173 CIVIL TERM KAREN D. GALIC, :CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 23, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OFA DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final decree in 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 i8 Pa. C.S. Section 4904 relating to wisworn falsification to authorities. Date: ~ ' ~ Z ' ~ ~] ~~~~~ ~~Q~~/\ ~ - Karen D. Galic Social Security No. (~ ~ ' CJ ~ '" (~ .Z r-~ ; ~j L..-. •°~ ~-"~ '~`i~l ~~ j ~ ~~ Jn'1 ~„`.' ~' `~ ~.~ it` Y~s ~,~ f • ~__ .•w ,? CRAIG P. GALIC, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. N0.2006-06-6173 CIVIL TERM KAREN D. GALIC, :CIVIL ACTION Defendant IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD 1. Grounds for divorce: Section 3301(c) of the Divorce Code 2. Date complaint filed: October 23, 2006 Date of service of the complaint: November 15, 2006 If service 30 days after date of filing, date complaint reinstated: Manner of service of the complaint: Certified mail, restricted delivery to and return receipt signed by defendant _X_ Acceptance of service (Copy attached) 3. Affidavit of consent required by Section 3301(c) of the Divorce Code: By plaintiff: dated March 19, 2007, and filed herewith By defendant: dated April 12, 2007, and filed herewith 4. Related claims pending: None 5. Date waiver of notice to file praecipe to transmit was filed with the Prothonotary By plaintiff: dated March 19, 2007, and filed herewith By defendant: dated April 12, 2007, and filed herewith VERIFICATION I verify that the statements made in this praecipe are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date: 04/16/07 r ~~ Tim y J. 'Connell, Esquire 4415 North Front Street Harrisburg, PA 17110 Attorney for Plaintiff £~:~ ~ ~ C. ~~ ~.., -rt -, ,` ;;;' e ~~ F u _ . ~ __~ ~- cya ~ ~~ - ma '4 .~ c~ - c I N THE COURT OF COIWI MON PLEAS OF CUMBERLAND COUNTY' STATE C)F ~~ PENNA. _,~ ° - - CRAIG P. GALIC VERSUS KAREN D. GALIC N ~ 06-6173 Civil Term DECREE IN DIVORCE A.ND IOIOW, ~~~~ ~ ~1 2007 IT IS ORDERED AND DECREED THAT (`raid P_ C~lir- _ PLAINTIFF, AND Karen D. Galic ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; none r ~+W+SCVi~+++++++++++++++ i v T r ~ r ~ n ~ I O T 'fps ~~ e° f / /, / L t~ f ,/•~,. ~,, .~' ;r ~~ i _ _ ,y