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HomeMy WebLinkAbout02-2722GREGORY S. PLANK, Plaintiff V. DENISE L. PLANK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. ~ ~'7~ CivilTerm 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 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 at the Cumberland County Courthouse, 1 Courthouse Square, 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. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue Carlisle, Pennsylvania (717) 249-3166 GREGORY S. PLANK, : Plaintiff : .. V. .. DENISE L. PLANK, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. ~ -~ ~ .2 7.2 ~- Civil Term CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Gregory S. Plank, by and through his attorneys, the Law Offices of Richard C. Gaffney, who files this Complaint in Divorce under Sections 3301(c) and 3301 (d) of the Divorce Code, and who, in support thereof, avers as follows: 1. Plaintiff is Gregory S. Plank, who currently resides at 6214 Edgeware Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 since June 2001. 2. Defendant is Denise L. Plank, who currently resides at 6214 Edgeware Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 since June 2001. 3. Plaintiff and Defendant are suijuris and have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaim. 4. The Plaintiff and Defendant were married on October 10, 1998 at Camp Hill, Cumberland County, Pennsylvania. 5. The Parties to this action separated on May 1, 2002 and have continued to live separate and apart since then. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. 9. Neither the Plaintiff nor the Defendant is in the military or naval service or in any branch of the armed forces of the United States of America or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, if both parties file affidavits consenting to the divorce after ninety (90) days have elapsed from the date of filing and service of this Complaint, Plaintiff respectfully requests this Honorable Court to enter a decree of divorce pursuant to 23 P.S. § 3301(c), or in the alternative, to enter a decree of divorce pursuant to 23 P.S. § 3301(d). Respectfully submitted, LAW OFFICES OF RICHARD C. GAFFNEY PA Supreme Court ID No. 86128 2120 Market Street, Suite 101 Camp Hill, PA 17011 (717) 975 -9033 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief I understand that false statements therein are made subject to the. penalties of 18 Pa.C, S,A. § 4904 relating to unswom falsification to authorities.