The URL can be used to link to this page

Home My WebLink About00-04801 "~~~ - --' ~"--Jr_ -"-'~'" " .. Andrew C. Sheely, Esquire 1~? S. Market street p.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ROBERT A. GRIFFITHS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LORI M. GRIFFITHS, Defendant 00 - 4~D( CIVIL TERM 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 against you and a decree in 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 with your children. When the grounds 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 BY cUe Andrew C. Sheely, E PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff - , -~i .. Andrew C. Sheely, Esquire 127 S. Market Street P.'t>. Box 95 Mechanicsburg, PA 17055 FA 1D NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ROBERT A. GRIFFITHS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. CIVIL ACTION - LAW 00 - "frol CIVIL TERM LORI M. GRIFFITHS, Defendant IN DIVORCE COMPLAINT 1. Plaintiff is ROBERT A. GRIFFITHS, an adult individual who currently resides at 38 West Keller Street, Mechanicsburg, Cumberland County, pennsylvania. 2. Defendant is LORI M. GRIFFITHS, an adult individual who resides at 9 Raspberry Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 26, 1993 in Mechanicsburg, pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the united States of America. 7. plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. . - . 'M Q ~ 8. The marriage between the parties is irretrievably broken. 9. Plaintiff avers that he is the innocent and injured spouse, and that the Defendant has offered such indignities to Plaintiff so as to render his condition intolerable and life burdensome. 10. This action is not collusive. 11. The parties separated on February 28, 2000. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant absolutely. COUNT II. CLAIM FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 12. The allegations in paragraphs 1 through and 11 are incorporated herein and made a part hereof. 13. plaintiff and Defendant are the owners of various items of personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage. 14. Plaintiff and Defendant are the owners of real property acquired during their marriage. 15. Plaintiff and Defendant have acquired various marital debt during the period of their marriage. 2 ~ ... WHEREFORE, Plaintiff requests your Honorable Court equitably distribute the parties marital property, including marital debt and including any such further relief as the Court may determine equitable and just. Date: July 5 ' 2000 ed, drew C. Sheel quire Attorney for Pla1n iff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 3 '. . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: J'uly ~ 2000 ~~~ .~ . . Andrew C. Sheely, Esquire 127 S. Market Street P.o. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) ROBERT A. GRIFFITHS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LORI M. GRIFFITHS, Defendant 00 - CIVIL TERM IN DIVORCE AFFIDAVIT Robert A.Griffiths, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authoritie~~~ Robert A. ofiffi -,-. ,~- """liIIIiifiIIlIii..... --~~ -lIfi1Ij,~~~ ~~-inl,1'~bii"""-; ~~ ~. ~ ~ ~~ ~ ~~__~L~ - "- i\. "- ~ ~ ~ ~ ~ ~ a \ \ \ . ~ ~ ~~ ! - ,'= " >-'""",~~- '.- iiillIIlii'''''' . '-" . - ~.. . o 0 ~ "O~ 0 q nlC::-'- C'..- ZPT C :-;:i Z-... ,il!.- r- . 1 ;; ,t2] (/)2 I -< L-'" c~. : :'~ r.:n . !;::c5 ,~- , ~~ ; ;lj~ -j :,.) ',.' -< Vl Xi -< ,'a~' ""..' ~ '~', ,-" , ~ , '>"""":';;; ';:1 it1 f1-1 ~1 ::.1 to;' ~; ~.1 1:'1 ii' i" Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 9S Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) b': ROBERT A. GRIFFITHS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r., ~f ! [;.1 vs. CIVIL ACTION - LAW ~'; LORI M. GRIFFITHS, Defendant 00 - L./$IJ / CIVIL TERM 1.1.' ifi Ie ~; ~,I ~,j IN DIVORCE ACCEPTANCE OF SERVICE ,I,' ~'i Ii f;' r'l 'ft. I, Jane M. Alexander, Esquire, hereby accept service of the , U' t', I:; ~:, ~ 1 ~ : divorce complaint docketed to the above-captioned number on behalf h /dJ ;2AH! ii Ii i: u I' " Ii I: of Lori M. Griffiths, Defendant. I further certify that I am authorized to do so in accordance with PA. R.C.P No. 402 (b). 11 E: ]'^_ c'o_.>"_' _" d <','<" ~ ,~~ . "-- '.;. .;...--",,~~....~~....;: -,'," ul1Jf'rl1lilli ~-~"" o ~ -eCG nlrn Z:T.; ~~~ !<C: :1> _. "--;>>\, " 6('; >c: z. -OJ -<0 ?< ., C:,t C;J L" C::.: r'~.~' "':\---:,: ,--~ '":1 -~, (-1 .'::1,,(- ;~ Z~~ ,,~-.., " ~ :0 -< Q ...J