Loading...
HomeMy WebLinkAbout06-6287,&A OF COMMON PENN YLV P,r1IA IN THE COURT N1BY, . CUMBERLAND CONY, V ALERIE R. GU plaintiff, CIVIL ACTION -LAW vs. DIVORCE BY, NO 06 CORY M. GUM Defendant NOTICE If you wish to defend wa against that if you fail to do VE BEEN SUED IN COURT ro • If action. You ar YOU HA ages, you must take prompt yo ?r any other laim or forth in the following page" thout you and a decree i n diedagainst n so, the case may proceed wi A judgment may also be enterlose moneyf Property or other rights against you by the court* the plaintiff. You may . relief requested in these Papers by custody or visitation of your children important to your including ties or irretrievable brelown of the marriage, ground for divorce is indict o age counselors mailable in the Office of When the counseling. A list of marriage Square, Cde, Pennsylvania. you may request marriage erland County' One Courthouse Prothonotary at Cunt DIVIS]OF PROPERTY, O NOT FILE A CLAIM FOR ALIMONY, IF YOU D pENSES BEFORE A DIVD MR A1?.MENT IS GRANTED, , EX LAWYER' SLOSE HE RIGHT TO CLAIM ANY OF YOU MAY YOUR LAWYER)NCE. IF YOU DO THIS PAPER TO ONE, GO TO OLEPHONE THE YOU S LAWYER OR CANNOT AFFORD YOU CAl" LEGAL HELP. NOT HAVE A OFFICE SET FORTH BELOW TO FIND OUT WHERE Lawyer Referral ar Association Cumberland County 32S * Bedford Street Carlisle, PA 17013 (800)990-9108 VALERIE R. GUMBY, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE CORY M. GUMBY, Defendant NO. -- 2P7 &Ltc---? COMPLAINT IN DIVORCE 1. Plaintiff is Valerie R. Gumby who currently resides at 904 South Humer Street, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Cory M. Gumby who has a last known address of 2260 Brim Lane, Enola, Cumberland County, Pennsylvania 17025. 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 June 19, 1999, in Enola, Cumberland County, PA . The parties have been living separate and apart since May, 2005. 5. No children were born of this marriage. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and it amendments. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 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 divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce divorcing Plaintiff and Defendant and such other Orders as are just and appropriate. Respectfully submitted, Melissa L. Van Eck, Esquire Attorney ID No. 85869 7810 Allentown Blvd. Suite B P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 Date: Jq&&1U4 Attorney for Plaintiff VERIFICATION I, Valerie R.Gumby, verify that the statements made in the foregoing COMPLAINT in DIVORCE are true and correct to the best of my knowledge, information and belief. 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: ?/x p?A? D , Valerie R. Gumby Q a 1 (? n r r3 fl c? --s ti Y i D DD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs . File No. Vic' (O)Arl `_ IN DIVORCE . ? Qrrl Yf Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that th lainti defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of W eri e Q , `*y" L , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: 0 LD P -.WLIL rn. Signature IzallAy.i Signature of name be' resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CiA m6erlew 1) yL On the _ %C day of n O y e m ?e r , 200(-o before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal i&tlo The M, Robertson. Notary Public %Wtboro Twp., Cumberland County ' Notary Public MY Gw#rlWM Expires Nov. 15, 2007 mm"ber, Pennsylvania Association Of Notaries AA -, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY NO. 06-6287 Plaintiff VS. CORY M. GUMBY , CIVIL ACTION-LAW Defendant DIVORCE PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint with regard to the above defendant in the above captioned matter. Respectfully submitted, VAN ECK & VAN ECK, P.C. Date: 7 v Melissa L. Van Eck, squire Attorney ID No.: 85869 7810 Allentown Blvd., Suite B. P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 a c? r.a 4- i. tv O -7m IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY Plaintiff VS. CORY M. GUMBY Defendant NO. 06-6287 CIVIL ACTION -LAW DIVORCE PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint with regard to the above defendant in the above captioned matter. Respectfully submitted, VAN ECK & VAN ECK, P.C. Date: U ? a,D lu? Melissa L. Van Eck, squire Attorney ID No.: 85869 7810 Allentown Blvd., Suite B. P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 C , C= K p a, Al" M X l •?•}u •-f l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY Plaintiff VS. CORY M. GUMBY Defendant : NO. 06-6287 : CIVIL ACTION -LAW : DIVORCE PROOF OF SERVICE I do hereby state that I served a true and correct copy of the Complaint in Divorce, in the above captioned matter, via Constable on July 10, 2007, as per the attached Affidavit of Service at: Cory M. Gumby 4700 Delbrook Road Mechanicsburg, PA 17055 Respectfully submitted, Date: D Melissa L. Van Eck, Esqdire Attorney ID No. 85869 7810 Allentown Blvd. Suite B Harrisburg, PA 17112 (717)540-5406 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CASE NO.: 06-6287 AFFIDAVIT OF SERVICE Valerie R. Gumby vs. Cory M. Gumby Conmonwealth of Pennsylvania County of Dauphin so. I, John Shinkowsky, a competent adult, being duly sworn according to law, depose and say that at 5:56 PM on 07/10/2007, I served Cory M. Gumby at 4700 Delbrook Road, Mechanicsburg, PA 17055 in the manner described below: ® Defendant(s) personally served. ? Adult family member with whom said Defendant(s) reside(s). Relationship is ? Adult in charge of Defendant(s) residence who refused to give name and/or relationship. ? Manager/Clerk of place of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. ? an officer of said Defendant's company. ? Other: a true and correct copy of Praecipe to Reinstate, Notice, Complaint in Divorce, Verification issued in the above captioned matter. Description: Sex: Male - Age: 28 - Skin: Lt.Brown - Hair: Black - Height: 599'T, Weight: x Sworn o and subsc of ib d before me on this 2047 Jctym Shinkowsky S inkowsky Investi 111t1)44 316 Fawn Ridge N Harrisburg, PA (800) 276-0202 NOTARYIPUBLIC COMMONWEALTH OF PENNSYLVANIA Atty File#: 06-6287 -Our File# 1463 NOTARIAL SEAL DONNA M. WIERMAN, Notary Public Susquehanna Twp., Dauphin County My Commission Expires July 28, 2009 Law Firm: Van Eck and Van Eck, P.C. Address: 7810 Allentown Boulevard, Suite B, Harrisburg, PA, 17112 Telephone: (717) 540-5406 t`? ti - ?? -rt -= -"' --1 .T, -- ?.,? ,- -n ?? ? `? i '^ .:a .?- r. .. ?.r ?_.? ?? c:} IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY Plaintiff VS. CORY M. GUMBY NO. 06-6287 CIVIL ACTION -LAW AFFIDAVIT OF CONSENT 2. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 27, 2006 4. 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. 5. 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.§ 4904 relating to unworn falsification to authorities. Date: Valerie R. Gumby Plaintiff .. 31 , . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY NO. 06-6287 Plaintiff VS. CORY M. GUMBY : CIVIL ACTION -LAW Defendant : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (C) OF THE DIVORCE CODE 4. I consent to the entry of a final Decree of Divorce without notice. 5. 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. 6. 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 relating to unworn falsification to authorities. Date: Valerie R. Gumby Plaintiff c7 r" C=D X cr rt'? ?., r'rt f"1'i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY Plaintiff VS. CORY M. GUMBY NO. 06-6287 CIVIL ACTION -LAW AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 27, 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. 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 unworn falsification to authorities. Date: 13101 l `M i Cory . Gumby rj +v t _- Q 2 rr= } ? 1 Mo IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY NO. 06-6287 Plaintiff VS. CORY M. GUMBY : CIVIL ACTION -LAW Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (C) 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 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 relating to unsworn falsification to authorities. Date: to ?l „C IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VALERIE R. GUMBY Plaintiff VS. CORY M. GUMBY Defendant NO. 06-6287 : CIVIL ACTION -LAW : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: 1. Ground for divorce: irretrievable breakdown under Section (3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served via constable on July 10, 2007. Affidavit of Service filed on July 24, 2007. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff on February 2, 2008; by defendant Febraury 18, 2008. (b)(1) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of service of the plaintiffs affidavit upon the defendant: N/A. 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 a copy of which is attached: b. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: Executed on February 2, 2008; filed on February 6, 2008. Date Defendant's Waiver of Notice was filed with the Prothonotary: Executed on February 18, 2008; filed on March 13, 2008. Respectfully submitted, T?A I Ao- Y- (?L Melissa L. Van Eck, Esquire Attorney ID No.: 85869 203 West Caracas Avenue Suite 201 Hershey, PA 17033 (717) 540-5406 Date: 3 '(? l -Q CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Valerie R. Gumby, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Praecipe to Transmit was served upon Cory M. Gumby, by depositing same in the United States mail, first class, on March 21, 2008 addressed as follows: Cory M. Gumby 4700 Delbrook Road Mechanicsburg, PA 17055 Date: Melissa L. Van Eck, Esquire 7810 Allentown Blvd. Suite B Harrisburg, PA 171112 Telephone: 717-540-5406 Fax: 717-540-5407 Attorney for Plaintiff C`7 c?..? C? . "j"f _ '7 ; ? ? ? n? ? , ---» -? ;, a_r 4? ?i t.? --+ .. --._ -? ? •-G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Valerie R. Gumby NO. 06-6287 VERSUS Cory M. Gumby DECREE IN DIVORCE AND NOW, 2008 , IT IS ORDERED AND DECREED THAT Valerie R. Gumb , PLAINTIFF, AND Cory M. Gumby , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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 BY THE COURT: ATT PROTHONOTARY v a ,• f ?a,