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Home My WebLink About02-5442CATHY L. GREENE, Plaintiff RAYMOND E. GREENE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02- ~qy ~ CIVIL TERM : IN DIVORCE NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 CATHY L. GREENE, Plaintiff RAYMOND E. GREENE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02-_ ,5 t~ ~ 2-- _ CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE. 1. Plaintiff is Cathy L. Greene, who currently resides at 1517 Terrace Avenue, Carlisle, Cumberland County, Pennsylvania, 17013, since August, 2002 2. Defendant is Raymond E. Greene, Jr., who currently resides in care of Joyce Greene, 438 First Street, College Park Apartments, Carlisle, Cumberland County, Pennsylvania since April, 2002. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 11, 1984 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. Defendant has prior military service. However, said service ended prior to 1984. 6. The marriage is irretrievably broken. 7. 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. 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 unsworn falsification to authorities. Cathy L. Greene, Plaintiff Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID #71786 CATHY L. GREENE, Plaintiff Vo RAYMOND E. GREENE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND cOUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO. 02-5442 - CIVIL TERM · IN DIVORCE AFFIDAVIT OF SERVICE_ COMMONWEALTH OF PENNSYLVANIA ) cOUNTY OF cUMBERLAND ) AND NOW, this 12th day of November, 2002, I, Paul Bradford Orr, Esquire, attorney for Cathy L. Greene, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Complaint, executed by the Plaintiff in the above-captioned matter, upon the Defendant on November 12, 2002, by depositing the same in the U.S. Mail, postage prepaid, certified, return effected, is marked Exhibit ,,A,,, attached hereto andmade apartbereof. [~0V {~i ~07_.. ~~. Dated: LAW OFFIC,Fi~OF PAUL BRA~iR Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 I.D. # 71786 · 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 permlts. 1. At,cie Acldmssed to: D. Is delive~j address different from item 17 I-] Yes If YES, enter delivery address below: [] No ~' ~ ' ~m ' ,~1~ J ~ R~ist~ g R~um R~eiptfor M~h~ol~ , ~ I '~-- ~ ~,nsu~Mail ~C.O.D. ~S Fo~ ~11, August 2~1 ~c Return R~,pt 1~595 EXHIBIT A CATHY L. GREENE, Plaintiff RAYMOND E. GREENE, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5442 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 12, 2002 2. The marriage of Plaintiff and Defendant is irretriewably broken and ninety (90) days have elapsed from the date of filing 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: R~i~ond E. Greene, Jr., De/f~ndant CATHY L. GREENE, Plaintiff V. RAYMOND E. GREENE, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5442 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 12, 2002 2. The marriage of Plaintiff and Defendant is irretriew~bly broken and ninety (90) days have elapsed from the date of filing 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 Wae 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: Cathy L. Greene, Plaintiff CATHY L. GREENE, Plaimiff V. RAYMOND E. GREENE, JR. De~am : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-5442 CIVIL TERM : IN 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 ifI 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: CATHY L. GREENE, Plaintiff RAYMOND E. GREENE, JR. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5442 CIVIL TERM IN 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 ora 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 oft,he 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: R"ayl~nd E.'~reene, Jr., Do~dant CATHY L. GREENE, Plaintiff RAYMOND E. GREENE, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5442 - CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: November 12, 2002, by U.S. Mail, postage prepaid, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff on May 27, 2003; by Defendant on May 24, 2003. 4. Related claims pending: NONE 5. Date Plaintiff's Waiver of Notice in {}3301 (c) Divorce, was filed with the Prothonotary. June 3, 2003 Prothonotary: 2O03 Date Defendant's Waiver of Notice in {}3301(c) Divorce was filed with the LA D ORR Paul Bradfo~r~ $0 East High Street ' Carlisle, PA 17013 (717) 258-8558 Supreme Court ID No. 71786 IN THE COURT Of COMMON PLEAS CATHY L. Plaintiff OF CUMBERLAND COUNTY STATE OF ~, PENNA. GREENE VERSUS Defendant DECREE IN DIVORCE , IT IS ORDERED AND DECREED THAT , PLAINTIFF, AND RAYMOND E. GREENE, JR. .,DEFENDANT, ARE DIVORCED FROM THE BONDS Of MATRIMONY. The COURT RETAINS JURISDICTION Of THE FOL!IOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; PROTHONOTARY