HomeMy WebLinkAbout07-0525
Michael A. Hynum, Esquire
Supreme Court ID #85692
Hynum Law
315 Bridge St., Lower Level
New Cumberland. PA 17070
(717) 774-1357
WILLIAM DARRYL GRABLE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0'7- S:6S (!~u;L '7-tI2...~
ANNE MARIE GRABLE,
Defendant
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 ant 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 and
visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Domestic Relations Office at the County Courthouse.
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
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
Michael A. Hynum, Esquire
Supreme Court 10 #85692
Hynum law
315 Bridge St., lower level
New Cumberland, PA 17070
(717) 774-1357
WILLIAM DARRYL GRABLE,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 6'1- S"::J.S {l,o~L,~
CIVIL ACTION - LAW
IN DIVORCE
ANNE MARIE GRABLE,
Defendant
COMPLAINT IN DIVORCE
1. Plaintiff is William Darryl Grable, an adult individual residing at 116 Holly
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant is Anne Marie Grable, an adult individual residing at 116 Holly
Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055.
3. Both Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on November 7,1998, in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There are no minor child born of this marriage.
6. There are no previous actions for divorce or annulment filed by either
party.
7. Neither Plaintiff nor Defendant is 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 the Congress of 1940 and its amendments.
,.
8. Plaintiff has been advised that counseling is available and that Plaintiff has
the right to request that the court require the parties to participate in counseling.
COUNT I . DIVORCE
NO FAULT
9. The averments in paragraphs 1 through 8, inclusive, of Plaintiffs
Complaint are incorporated herein by reference thereto.
10. The marriage is irretrievably broken and no possibility of reconciliation
exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in
accordance with 93301 of the Pennsylvania Divorce Code.
WHEREFORE, Plaintiff, WILLIAM DARRYL GRABLE, prays this Honorable
Court to enter judgment:
A. Awarding Plaintiff a decree in divorce; and
B. Awarding other relief as the Court deems just and reasonable.
Date: 11.1.1/07
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Michael A. Hynum, Esquire
Supreme Court 10 #85692
Hynum Law
315 Bridge St., Lower Level
New Cumberland, PA 17070
Attorney for Plaintiff
.
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I verify that the statements contained in the foregoing COMPLAINT are
true and correct to the best of my knowledge, information and belief. I
understand that false statements contained therein are made subject to the
penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: / /9.'2 / 0 7
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William Darryl Grabl
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Michael A. Hynum, Esquire
Supreme Court 10 #85692
151 Reno Ave., Suite 202
New Cumberland, PA 17070
(717) 774-1357
Attorney for Plaintiff
WILLIAM DARRYL GRABLE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 07-525 Civil Term
ANNE MARIE GRABLE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I, MICHAEL A. HYNUM, ESQUIRE, being duly affirmed according to law, depose
and say that:
1. On January 26, 2007, a copy of the Complaint in Divorce in the above-
captioned matter was mailed to the Defendant by certified mail, return receipt
requested, restricted delivery, at the Defendant's last known address, as indicated on
the attached mailing receipt.
2. That on or about January 27,2007, the Defendant received the aforesaid
Complaint in Divorce and the mailing receipt and return receipt card evidencing the
same are attached hereto and made a part hereof.
PENNSYLVANIA
NO ARlAL SEAL
VICTORIA y, CHAMBERS, Notary Public
New Cumberland Ioro" Cumbertlnd County
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. CompteteJlemS 1. 2. and 3, Also complete
Item 4 1f.f\8stricted Delivery Is desired.
. Print your' ~ and address on the reverse
10 that we can return the card to you.
. Attach this card to the back of the mallplece.
or on the front If space pennlts.
1. MIele Addres8ed to:
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R_b IcMd DelIwlry? (Ext1a Fee) ·
2. ArtIcle Number
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.. Form 3811. F*-'Y 2004
7004 2890 OD02 8467 8500
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CERTIFIED MAIL RECE,'
(Domestic Mail Only; No Insurance Coverage provided)
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In the Court of Common Pleas of
Cumberland County, Pennsylvania
VS.
No. -.Ct1. .5~h
Civil. 19
Anne Marie. ~~e..
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Attorney for Plaintiff
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