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HomeMy WebLinkAbout03-0458 SAIDIS SHUFF, FLOWER & LINDSAY ATrOP, I~YS*ATeLAW 26 W. High Street Carlisle, PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2003- q<~' : : IN DIVORCE CIVIL TERM 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, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 SAIDIS, SHUFF, FLOWER & LINDSAY Attorney for Plaintiff - v'~C'ar~l J'.,~6d~a¢ E~squire ID¢~.~4893 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATtORNeYS.AT.LAW 26 W. High Street Carlisle. PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW NO. 2003 - V ~'~' CIVIL TERM · IN DIVORCE COMPLAINT JOHN W. GRENOBLE, Plaintiff, by his attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is JOHN W. GRENOBLE, who currently resides at 61 North Middleton Road, Carlisle, Cumberland County, Pennsylvania, where he has resided since 1991. 2. The Defendant is SUSAN C. GRENOBLE, who currently resides at 26 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania, where she has resided since January 5, 2003. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 17, 1989, at Boiling Springs, Cumberland County, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY Attorney for Plaintiff Date: By: ID # 4469'~ 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY ATtORNeYS*AT.LAW 26 W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY ATfORNEY$~AT~LA..~_~=~W 26 W. High Street Carlisle, PA VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. John W. Grenoble Date: SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA PROPERTY SETTLEMENT AND SEPARATION AGREEMENT 2OO3, BETWEEN JOHN W. GRENOBLE, of 61 North~-rvliddleton Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband, AND SUSAN C. GRENOBLE, of 26 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Wife. RECITALS: R.I: The parties hereto are husband and wife, having been joined in marriage on December 17, 1989 in Boiling Springs, Cumberland County, Pennsylvania; and R.2: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. R3: The parties also desire to settle their issues of custody of their minor children, Olivia A. Grenoble, born August 2, 1994, and Zachary A. Grenoble, born July 2, 1991, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. NOW THEREFORE, in consideration o1' the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit.. free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or ,contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and the moving party shall move for the entry of the divorce decree at that time. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 61 North Middleton Road, Carlisle, Cumberland County, Pennsylvania. Wife waives any right, title and interest in the marital home in consideration of the marital debt which Husband is agreeing to pay. Husband will use best efforts to refinance the marital home and will accomplish such a refinance within two years of the date of this Agreement. At the time of refinance, Wife will transfer her interest in the marital home to Husband by SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA special warranty deed. Said deed shall be executed on the same day as the date of this Agreement and held in escrow by Carol J. Lindsay, Esquire until such time as the Affidavits of Consent have been executed and filed and the property refinanced. Husband shall pay for all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify her from any loss thereon. (4) DEBT: A. MARITAL DEBT: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: i. Honda Card ii. US Bank Visa iii. Circuit City iv. Home Depot v. Husband's Harley Davidson Loan vi. Web Card Visa vii. Capital Qne Visa viii. Providian/TBN VISA ix. Bon Ton x. Sprint 3 SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA xi. PP&L xii. Comcast xiii. Waste Management ~' xiv. Kough's Oil Company ~ ~ xv. Vehicle loan for the 200~ Astro Van xvi. First mortgage on the marital home 1: Providian TBN Visa, Bon Ton, Sprint, PPL, Waste Management, Comcast and (fuel oil) as well as the vehicle loans for the 200~ Astro Van and the Harley Davidson, and Second mortgage on the marital home Husband shall pay the obligations to Web Card Visa, Capital One Visa, the first and second mortgage by making timely monthly payments in at least the minimum amount required by the creditors until paid in full. 2: Wife shall pay the obligations on the Honda Card, US Bank Visa, Circuit City, and the Home Depot account by making timely monthly payments in at least the minimum amount required by the creditors until paid in full. Each party shall pay the outstanding joint debts as set forth herein and further agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on December 21, 2002, the party who incurred said debt shall be responsible for the payment thereof regardless of the SAIDIS SHUFF, FLOW-ER & LINDSAY 26 W. High Street name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the ,other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (5) MOTOR VEHICLES: The parties hereto agree that Wife, at her specific request, will receive the 1997 Truck which Husband has been driving and ~ X.~-'lc which carries with it no lien. Husband will accept the 200~Astro Van which Wife has been driving and which carries with it a lien. Within ten days of the date of this Agreement, each party will execute any and all documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. In particular, Wife will execute a Power of Attorney so that Husband can transfer the title of the Van when the Van is paid off. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Husband will retain the Harley Davidson Motorcycle and pay the outstanding obligation thereon, holding Wife harmless on account of any loss for that vehicle. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory dMsion of the furniture, household 5 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like. (8) CUSTODY OF CHILDREN: The parties agree that legal custody of their minor children, Olivia and Zachary Grenoble shall be joint, with both parties having the right to make major parenting decisions affecting the children's health, education and welfare. Wife shall have primary physical custody of the children subject to Husband's partial physical custody at the following times: (a) (b) (c) Every other weekend from Friday after work until Sunday evening; One evening per week; Alternating holidays as the parties shall arrange; SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA (d) (e) (f) (g) One-half of the Christmas holiday and Thanksgiving as the parties shall arrange. Provided, however, that Husband will have the children every Christmas Eve with the children staying with Husband overnight on alternating Christmas Eves; One-half of the Christmas break from school as the parties can agree. Provided, however, that Husband will have the children every Christmas Eve with the children staying with Husband overnight on alternating Christmas Eves; The summer vacation from school commencing five days from the day school ends until five days prior to the start of the following school year, subject, however, to alternating weekends from Friday after work until Sunday evening in Wife during the summer, and five days during the summer to be scheduled in advance and to be used to extend an alternating weekend into a full week of custody, or to attach to Wife's alternating weekends in the summer to make extended weekends; and At such additional times as the parties can agree. The parties agree and stipulate that neither one will remove the children from their present school or school districts without the agreement of the other, nor will either relocate more than 20 miles from the address of the marital home without the agreement of the other. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA (9) CHILD SUPPORT: Wife acknowle,dges that Husband has an initial burden of reorganizing and refinancing marital debt which he his accepting as a part of this Agreement. Therefore, Husband will pay to Wife, outside of the Office of Domestic Relations, child support in the amount of $550.00 per month commencing February 7, 2003 and continuing for the months of March and April 2003, one-half on the 7th of the month and one-half on the 21,t of tile month; and $700.00 per month commencing in May 2003, in two equal payments on the 7~h and 21~t of that month and every month thereafter. Provided, however, that Husband will pay one-half of his child support obligation in June and August, and be exempt from payment in July in consideration of his having the children in his custody for much of the summer. Husband's obligation shall decrease to $350 per month on Zachary's 18th birthday or graduation from his school, whichever comes later and will terminate on Olivia's graduation from school or her 18~h birthday, whichever is later. Additionally, Husband will provide health insurance for the children as provided by his employer at a reasonable cost to him. Such health insurance shall be provided at Husband's sole expense. The parties acknowledge that the amount set out in this Agreement may be less than a "guideline" amount of suppod:, but the agreed upon amount of support takes into consideration Husband's payment of debt which otherwise might be the obligation of Wife. The parties agree that in the event of a material change in circumstances of either party, or a change in the custody arrangements set forth SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street herein, the amount of support payments shall be subject to an appropriate adjustment by agreement or, if the parties are unable to agree, by order of a court of competent jurisdiction, and the amount ordered by any such court shall be deemed to be the amount due hereunder. (10) WAIVER OF ALIMONY: The padies acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (11) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Husband is represented by Carol J. Lindsay, Esquire and Wife has been advised that she may be represented by counsel of choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (12) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and SAIDIS SHUFF, FLOWER & LINDSAY 26 W, High Street Carlisle, PA effect to the provisions of this Agreement. (13) INCOME TAX: A: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. B: Wife agrees, upon the request of Husband, to join in the filing of a 2002 joint federal and Pennsylvania income tax return. In the event that a joint return is filed, the Wife's contribution for payment of any tax due shall be limited to a sum equal to the amount of tax liability that shE; would have had to pay on her separate return for that year had she filed a separate return. Husband will pay the balance of the tax due on the return. Husband will bear the expense of preparing all joint tax returns and of computing the estimated tax liability of Wife on the basis of her having filed a separate return. In the event of any refund, the parties will share the refund equally. (14) COMPLETE DISCLOSLIRE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and 10 SAIDIS SHUFF, FLOWER & LINDSAY 2& W. High Street ~rlisle, PA is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (15) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (16) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the previsions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (17) RELEASE OF ALL CLAIMS: Except: as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA (1) (2) (3) and (4) quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether' now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: to take against the other's will; under the laws of intestacy; to a family exemption or similar allowance; all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or' political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; 12 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. Ail rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (18) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (19) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (20) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 13 (21) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there, are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (22) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA WITNESS: John W. Grenoble Susan C.~en'~ble 3.4 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003- 458 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~;3301(c:) of the Divorce Code was filed on January 30, 2003. 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 in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904. relating to unsworn falsification to authorities. John W. Grenoble, Plaintiff Da e: SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003- 458 CIVILTERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF 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 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. John W. Grenoble, Plaintiff Date: ~- 2>"o3 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Streel Carlisle, PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2003- 458 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on January 30, 2003. 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 in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2003- 458 CIVILTERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(c) OF THE DIVORCE CODF 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 r ' p operty, lawyers 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904. relating to unsworn falsification to authorities. v V~.usan,~. G~enobl'e, 5e~ndant- Date: _~,~'q/O. '-2-, SAIDIS SHUFF, FLOWER & LINDSAY 26 W. Hlsh Street Carlisle, PA JOHN W. GRENOBLE, Plaintiff vs. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 2003- 458 CIVILTERM : : IN DIVORCE ACCEPTANCE OFSERVlC~ ' ' - D~te I accept service of the Complaint in Divorce in the above captioned matter. S~san C.~:~:enoble,' Defendant SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High SIreet Carlisle, PA JOHN W. GRENOBLE, Plaintiff VS. SUSAN C. GRENOBLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003- 458 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the coud for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service signed by Defendant, Susan C. Grenoble, January 31, 2003. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff June 27, 2003; by the Defendant June 30, 2003. 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a cop,./of which is attached: (b) Date Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: July ,2003 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: July , I 20,33 ~//~ Ca~01 ~. Lin-dsay, ~B'SqJ~ire - / Saidis, Shuff, Fl~v.,~c'& Lindsay I 26 West High Street Carlisle PA 17013 Phone: 717.243.6222 Attorney for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of .~. IF::'ENNA. JOHN W. GRENOBLE, Plaintiff VERSUS SUSAN C. GRENOBLE, Defendant NO. 2003-458 CIVIL TERM IN DIVORCE DECREE IN DIVORCE AND NOW, ¢!V~ {? DECREED THAT JOHN W. GP~NOBL~ AND SUSAN C. GRENOBLE ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE. The terms of the Property Settlement and Separation Agreement dated January 24, 2003 a~e incorporated but not merged into this Decree. By THE COURT: