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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
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STATE OF
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nnrothy M Gr'Js
No, 00-2274
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VERSUS
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Dennis J. Grub
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DECREE IN
DIVORCE
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AND NOW, AI.J<:J,-,~-t 'I.I ,20tlO, IT IS ORDERED AND
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DECREED THAT Dorothy M. Grub , PLAINTIFF,
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Dp-nn:i S IT. ~rllh
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, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT REOTAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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The Marriaae Settlement Agreement entered into hy tne
above-captioned parties is hereby incorporated into this divorce
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AT E T:
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ROTHONOTARY
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this J d
day of J< ne..
2000, by and
il between DOROTHY M. GRUB, of Enola, Cumberland County, Pennsylvania, hereinafter
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'i hereinafter referred to as "Husband."
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WITNESSETH;
WHEREAS, Husband and Wife were lawfully married on June I, 1991;
and
WHEREAS, differences have arisen between Husband and Wife in consequence of
which they intend to live separate and apart of each other; and
WHEREAS, Husband and Wife have made a full disclosure of their assets to each other;
and
WHEREAS, Husband and Wife desire to settle and determine their rights and obligations
with respect to each other, including the disposition and distribution of property rights and
interests between them.
NOW, THEREFORE, in consideration ofthe mutual promises, covenants and
undertakings hereinafter set forth and for other good and valuable consideration, receipt of which
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is hereby acknowledged by each of the Parties hereto, Wife and Husband, each intending to be
legally bound hereby, covenant and agree as follows:
I. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect
have been fully explained to the Parties, by their respective counsel, Gerald S. Robinson, Esquire,
for Wife, and Husband was afforded ample opportunity to have counsel review this document on
his behalf. The Parties acknowledge that they have received independent legal advice from
counsel of their selection and that they fully understand the facts and have been informed as to
their legal rights and obligations and they acknowledge and accept that this Agreement is, in the
circumstances, fair and equitable and that it is being entered into freely and voluntarily, after
having received such advice and with such knowledge and that execution of this Agreement is
not the result of any duress or undue influence and that it is not the result of any collusion or
improper or illegal agreement or agreements.
2. SEPARATION. It shall be lawful for each Party at all times hereafter to continue
to live separate and apart from the other Party at such places as he or she may from time to time
choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of
either Party of the lawfulness or unlawfulness of the causes leading to their living apart.
3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The Parties
agree that the terms of this Agreement shall be incorporated into any Divorce Decree, which may
be entered with respect to them at the request of either Party. The Parties agree that the Court of
Common Pleas of Dauphin County, Pennsylvania, shall retain continuing jurisdiction over the
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Parties and the Agreement for the purposes of enforcement of any of the provisions thereof. The
Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing
the Parties, although this Agreement shall be incorporated into said Decree, this Agreement shall
not merge with, but shall continue in full force and effect after such time as a Final Decree in
Divorce may be entered with respect to the Parties and may be enforced in an action independent
of the Divorce Decree. The Parties agree and it is the intent of each of them that even though
this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code
or in an action independent of the Divorce Decree in accordance with Section 3502 of the
Pennsylvania Divorce Code, the provisions of this Agreement regarding the disposition of
existing property rights and interests between the Parties, alimony, alimony pendente lite,
counsel fees and expenses shall not be subject to modification by any Court.
4. SUBSEQUENT DIVORCE. The Parties hereby acknowledge and express their
agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any
necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section 3301(c) of the
Pennsylvania Divorce Code.
5. INTERFERENCE. Each Party shall be free from interference, authority, and
contact by the other, as fully as ifhe or she were single and unmarried, except as may be
necessary to carry out the provisions of this Agreement. Neither Party shall molest the other or
attempt to molest the other, nor compel the other to cohabit with the other, or in any way harass
or malign the other, nor in any way interfere with the peaceful existence, separate and apart from
the other.
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6. WIFE'S DEBTS. Wife represents and warrants to Husband that she will not
contract or incur any debt or liability for which Husband or his estate might be responsible and
she shall indemnify and save harmless Husband from any and all claims or demands made
against him by reason of debts or obligations incurred by her.
7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that he will not
contract or incur any debts or liability for which Wife or her estate might be responsible, and he
shall indemnifY and save harmless Wife from any and all claims or demands made against her by
reason of debts or obligations incurred by him.
8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party
has released and discharged, and by this Agreement, does for himself or herself, and his or her
heirs, legal representatives, executors, administrators and assigns, release and discharge the other
of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which
either of the Parties had or now has against the other, except for any and all causes of action for
divorce and except for any and all causes of action for breach of any provisions ofthis
Agreement.
9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that
they have made a full and complete disclosure to the other of all information pertaining to the
Parties' separate and marital property owned, possessed and/or controlled by the other at the time
of the separation of the Parties and, further, that the Husband and Wife voluntarily and
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intelligently agree to waive any rights which they may have to receive an Inventory and
Appraisement of all property owned or possessed by them, either jointly or individually, at the
time of the delivery of this Agreement or of the commeucement of any action of divorce.
10. EQUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
separate property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors that have been taken into consideration by the Parties.
a. REAL PROPER TV. Wife relinquishes any and all interest she may have
in the marital residence situated at 9 Louis Lane, Enola, Pennsylvania. Husband
shall assume sole financial responsibility for the costs associated with the home,
including but not limited to mortgages, taxes, insurance, utilities, repairs and
improvements associated with the upkeep and shall indemnifY Wife and hold her
harmless for any claim made against her relative to the martial residence. Wife
shall draft a new deed transferring ownership solely to Husband upon Husband
paying the VISA, Money Store, and Allfirst debt in full or Husband refinancing
the debt.
b. Husband shall be responsible for having Wife's name removed from the
existing mortgage by June 30, 2005. If Husband is unable to remove Wife's name
from the mortgage by that date, Husband shall list the marital residence for sale
and said home shall be sold. In the event that the marital residence is sold after
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June 30, 2005, because of Husband's inability and/or failure to remove Wife's
name from the mortgage, Wife shall be entitled to fifty (50%) percent of the net
proceeds realized from the sale. Nothing in this paragraph shall restrict
Husband's rights to sell the home prior to June 30, 2005.
c. PERSONAL PROPERTY. The Parties have divided between themselves,
to their mutual satisfaction, all items oftangible, personal property previously
used by them in the marital home. Specifically, Wife shall be entitled to some of
the furnishings as the parties mutually agree. Wife shall be entitled to retrieve
personal items from the marital resident. Neither Party shall make any claim to
any such item of tangible personal property; whether said items are marital
property or said items are separate personal property of either Party.
d. MOTOR VEHICLES. With respect to the vehicles owned by the Parties,
the Pontiac Grand Am shall become the sole and exclusive property of Wife,
which title shall be transferred to her by Husband contemporaneously with the
signing ofthis Agreement. The Chevy Cameo shall become the sole and exclusive
property of Husband, which title shall be transferred to him by Wife
contemporaneously with the signing ofthis Agreement. Each party shall be
responsible for the costs associated with their vehicle including but not limited to
loans, insurance, registration, maintenance and repair, and shall hold the other
harmless for any claim made against the other relative to the vehicle.
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e. EMPLOYMENT -RELATED BENEFITS. Wife relinquishes all interest
she may have in Husband's retirement benefits.
f. CHECKING AND SAVINGS ACCOUNTS. With regard to checking and
savings accounts, the Parties agree to close their joint accounts and divide the
balance equally between them.
g. MARITAL DEBTS. The Parties acknowledge that the parties have
incurred debt during the marriage. Husband agrees to assume sole liability for all
charges incurred on the VISA credit card. Husband also agrees to assume the sole
liability for the loans through the Money Store and Allfirst Bank. Husband shall
indemnify Wife and hold her hannless for any claim made against her relative to
the martial debt.
h. Both Parties hereby accept the provisions of this Agreement with respect
to division of property in lieu of and in full and final settlement and satisfaction of
all claims and demands that they may now have or hereafter have against the
other for the equitable distribution of their property by any Court of competent
jurisdiction pursuant to Section 3502 ofthe Divorce Code or any other laws.
Husband and Wife voluntarily and intelligently waive and relinquish any rights to
seek a Court ordered determination and distribution of marital property, but
nothing herein shall constitute a waiver by either Party of any rights to seek their
relief of any Court for the purpose of enforcing the provisions of this Agreement.
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11. ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES.
Both Parties accept the provisions of this Agreement in lieu of and as full and final settlement
and satisfaction of all claims and demands that they may now or hereafter have against the other
for alimony, alimony pendente lite, counsel fees or expenses, or for any other provision for
support and maintenance before, during or after the commencement of any proceedings for the
divorce or annulment between the Parties.
14. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise
provided, each Party may dispose of his or her property in any way, and each Party hereby
waives and relinquishes any and all rights he or she may now or hereafter acquire, under the
present or future laws of any jurisdiction, to share in the property or the estate of the other as a
result of the marital relationship, including, without limitation, dower, courtesy, statutory
allowance, widow's allowance, right to take property under equitable distribution, right to take
in intestacy, right to take against the will of the other's estate, and who will, at the request of the
other, execute, acknowledge and deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights
and claims.
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15. BREACH. If either Party breaches any provision of this Agreement, the other
Party shall have the right, at his or her election, to sue for damages for such breach or seek such
other remedies or relief as may be advisable to him or her. The Party breaching this Contract
should be responsible for payment oflegal fees and costs incurred by the other in enforcing their
rights under this Agreement.
16. ENTIRE AGREEMENT. This Agreement contains the entire understanding of
the Parties and there are no representations, warranties, covenants or undertakings other than
those expressly set forth herein.
17. MODIFICATION AND WAIVER. The modification or waiver of any of the
provisions of this Agreement shall be effective only if made in writing and executed with the
same formality as this Agreement. The failure of either Party to insist upon strict performance of
any of the provisions of this Agreement shall not be construed as a waiver of any subsequent
default of the same or similar nature.
18. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or obligations
of the Parties.
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19. INDEPENDENT SEPARATE COVENANT. It is specifically understood and
agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a
separate and independent covenant and agreement.
20. APPLICABLE LAW. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
21. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent
that the provisions of this Agreement are fully understood by both Parties and each Party
acknowledges that this Agreement is in all respects fair and equitable, that it is being entered into
voluntarily and knowingly, and that it is not the result of any duress, undue influence, collusion
or improper or illegal agreement or agreements.
IN WITNESS WHEREOF, the Parties have hereunto set their hands and seals the day
and year first above written.
WITNESS;
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Dennis J. Grub
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DOROTHY M. GRUB,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO.
00-2274
DENNIS J. GRUB,
Defendant.
: CIVIL ACTION--LA W IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for the entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under section3301 (c) of the Divorce
Code.
2. Date and Manner of service of the Complaint: certified mail, return receipt
requested, restricted delivery to addressee only on or about April 13, 2000.
3. Date of execution of the affidavit required by section 3301 (c) of the Divorce
Code: by Plaintiff on July 24, 2000 and by Defendant on July 24, 2000.
4. Related claims pending. The economic claims have been settled by agreement.
5. Date the Plaintiff's waiver of Notice in section 3301 (c) of the Divorce was filed
with the Prothonotary: on or about July 24, 2000.
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6. Date the Defendant's Waiver of Notice in section 3301 (c) of the Divorce was
filed with the Prothonotary: on or about July 24, 2000.
Respectfully submitted,
ROBINSON & GERALDO
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By
Gerald S. Robinson, Esquire
Attorney LD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110
(717) 232-8525
Attorney for Plaintiff.
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00 - d.~'71
Ciul.L 'r-~
DENNIS J. GRUB,
Defendant
CIVIL ACTION--LA W 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. Your 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 counseling. A list of marriage counselors is available in the Office of the
Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS' 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 OF CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Lawyer Referral Service
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
DENNIS J. GRUB,
Defendant.
CIVIL ACTION--LA W IN DIVORCE
A VISO
USTED HA smo DEMANDADO/A EN CORTE. Si usted desea defenderse de las
demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de
los proximos veinte (20) dias despues de la notificacion de esta Demanda y A viso radicando
personalmente 0 por medio de un abogado una comparecencia escrita y radicano en la Corte por
escrito sus defensas de, y objecciones a , las demandas presentadas aqui en contra suya. Se Ie
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 caulquier
otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos
importances para used.
SED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE.
SI USTED NO TIENE UN ABOGADO 0 NO PUEDE P AGARLE A UNO, LLAME 0 VA Y A
A LA SIGUlENTE OFICINA PARA A VERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Court Administrator
4111 Floor, Cumberland County Courthouse
Carlisle, P A 17013
(717) 240-6200
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 6-0- -;2..21'-1 ~
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DENNIS J. GRUB,
Defendant.
CIVIL ACTIONnLA W IN DIVORCE
COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE
COUNT I
I. Plaintiff is DOROTHY M. GRUB, who currently resides at 17 Givler Avenue,
Enola, Cumberland County, Pennsylvania.
2. Defendant is DENNIS 1. GRUB, who currently resides at 9 Louis Lane, Enola,
Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6)
months immedialely previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June I, 1991 in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the Parties.
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6. The marriage is irretrievably broken.
7. Neither Party is a member of the Armed Forces of the United States or any of its
allies.
8. The Plaintiff has been advised of the availability of counseling and that either
Party may compel the other by Order of Court to attend counseling sessions.
WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree
in Divorce under Section 330 I (c) of the Divorce Code.
COUNT II EQUITABLE DISTRIBUTION
9. The Plaintiff incorporates by reference Paragraphs 1 through 8 of the Complaint
for Divorce as fully set forth herein.
10. During the marriage, Plaintiff and Defendant have acquired various items of
marital property, which are subject to equitable distribution under Section 3502 of the
Pennsylvania Divorce Code of 1980, as will be fully set forth in the Plaintiff's Inventory and
Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure.
11. Plaintiff and Defendant have been unable to agree as to an equitable division of
marital property.
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WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property.
Respectfully submitted,
ROBINSON & GERALDO
Date: 4/lo/ro
By:k~
Gerald S. Robinson, Esquire
Attorney J.D. #27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney for Plaintiff
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VERIFICATION
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. Section 4904, relating to
unsworn falsification to authorities.
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Dorothy Mrub
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CERTIFICATE OF SERVICE
I, Gerald S. Robinson, Esquire, do hereby certify that on the 10lh day of April, 2000, I
caused a true and correct copy of the Complaint to be served upon the following individual by
certified mail, return receipt requested, restricted delivery to addressee only by depositing same
in the United States mail, postage prepaid, in Harrisburg, Pennsylvania.
Dennis J. Grub
9 Louis Lane
Enola, P A 17028
Respectfully submitted,
By:
Gerald S. Robinson, Esquire
Attorney LD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, P A 17110
(717) 232-8525
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2274 Civil Term
DENNIS J. GRUB,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
PROOF OF SERVICE
The undersigned makes the following return of service: the Complaint in Divorce was
served upon Dennis 1. Grub, the Defendant, on April 13, 2000 at 9 Louis Lane, Enola,
Cumberland County, Pennsylvania. The signed receipt is attached as Exhibit I.
SIGNATURE AND AFFIDAVIT
I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this
action.
I verify that the statements made in this affidavit and return of service are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. g4904 relating to unsworn falsfication to authorities.
Respectfully submitted,
ROBINSON & GERALDO
Dated: t ~! Db
By: !La~
Gerald S. Robinson, Esquire
Attorney J.D. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney for Plaintiff
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permit~
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3. Service Type
1tI Certified Mail
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Domestic Return Receipt
102595-99-M-1789
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2274 Civil Term
DENNIS 1. GRUB,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
PROOF OF SERVICE
The undersigned makes the following return of service: the Complaint in Divorce was
served upon Dennis J. Grub, the Defendant, on April 13, 2000 at 9 Louis Lane, Enola,
Cumberland County, Pennsylvania. The signed receipt is attached as Exhibit I.
SIGNATURE AND AFFIDAVIT
I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this
action.
I verify that the statements made in this affidavit and return of service are true and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. g4904 relating to unsworn falsfication to authorities.
Respectfully submitted,
ROBINSON & GERALDO
Dated: 4' ~o I ()()
By; !La~
Gerald S. Robinson, Esquire
Attorney LD. No. 27423
4407 North Front Street
P.O. Box 5320
Harrisburg, Pennsylvania 17110-5320
(717) 232-8525
Attorney for Plaintiff
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SENDER: COMPLETE THIS SECTION
Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space pennits \
1. Article Addressed to: ~ ~
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COMPLETE THIS SECTJON ON DELIVERY
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D. Is delivery address different from item 1?
If YES, enter delivery address below:
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o Agent
o Addressee
DYes
~No
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.
.
.
.
.
.
.
.
.
.
.
.
,
,
.
.
.
I
.
.
.
3. Service Type
\tI Certified Mail
o Registered
o Insured Mail
o Express Mail
Kl Return Receipt for Merchandise
OC.Q,D,
4. Restricted Delivery? (Extra Fee)
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Domestic Return Receipt
- Exhibit ,',
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2274 Civil Term
DENNIS J. GRUB,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under 9 330 I ( c) of the Divorce code was filed on
April 12, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed fron1 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. 94904 relating to unsworn
falsification to authorities.
Date: 7 r 6)1-1 ) OtJ
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orothy M b, PlamtIff
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2274 Civil Term
\
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DENNIS J. GRUB,
Defendant
CML ACTION - LAW IN DNORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER &3301 (c) OF THE DIVORCE CODE
I. 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,
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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: 1 [Q'Y)cP
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Dorothy. b, Plaintiff
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. '00-2274 Civil Term
DENNIS J. GRUB,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~ 3301 (c) of the Divorce code was filed on
April 12, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 unsworn
falsification to authorities.
Date:":} )f)LJ J(JJ
L;7~C <
Dennis 1. Grub, Defendant
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DOROTHY M. GRUB,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-2274 Civil Term
DENNIS J. GRUB,
Defendant.
CIVIL ACTION - LAW IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER !l3301 (el 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 in 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.
1 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. 94904 relating to unsworn
falsification to authorities.
Date: l/fJl./ /00
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DennisJ.Chub,Dewndant
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