Loading...
HomeMy WebLinkAbout00-07356 . ~~' ~'c~.'";,, ,~',~~;,', , . ,. . . . . . . ~ ~~~~~ ~ ~~~ ~ ~ ~~ ~ .. . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Deh-C.f. A. GnL bb Phtntiff No. 00-'3'5<0 . . . . . . . . VERSUS ~D~ T (';.\;..h'o 'bt~,n+ . . . . DECREE IN DIVORCE AND NOW'~ ).-) DECREED THAT Debv--c.. p\. (;.y-1A6b , PLAINTIFF, at cf~ 4iJPA , ?Do +rT IS ORDERED AND . . . . JefiJ-Ph T ('..,..l1Abh , DEFENDANT, AND . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . 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; . . . NOI\1 E. . . . . . . J. c:'Uh~ROTHONOTARY . . . . . . .. . Of. :F.;F. :Ii;!;'" . . .. . " ",-',; ~'- . ~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " R I' . I: . [i . II . ;, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~\'-l:l1M"";'';'"'' 'j ~ -^ "~",___~,~o'V ,~, ~ "'=~'''.'Yt<" ,-- ~ ' '<.I ~" .~. ,,' <, ,w,.'., , '/..:.' ....-'..,' -h.~~.~ ~r~-~n ,~ , .. ' e" ~ . . :~ \. ~.~- " .. I(J'$(>. C' /c?':8F{' - ,~~ , j",- ,,- ,-,', ",. .oo .~.. .C' ".-"" , ! - - ">J,,,,~,,~, aJ'h ~f5"" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE No.0073Slo vs. JOSEPH THOMAS GRUBB. Defendant. MARITAL PROPERTY SETTLEMENT AGREEMENT THIS MARITAL PROPERTY SETTLEMENT AGREEMENT, on this 2 day of Feb17101\./ , dJJ I ,made between Plaintiff, DEBRA ANN GRUBB, who I resides at 3810 BELLOWS DRIVE, CAMP HILL, PA 17011, and the Defendant, JOSEPH THOMAS GRUBB, who resides at 3810 BELLOWS DRIVE, CAMP HILL, PA 17011. WITNESSTH WHEREAS, the parties were married on AUG. 21,1992, at SCOTRUN, PA; WHEREAS, the parties filed for a 3301 (c) divorce on ICfOd()6""r , 2000; WHEREAS, the parties herein wish to distribute their property as agreed to in this Marital Property Settlement Agreement. Both parties hereto agree to relinquish any and all rights and claims which either may have on any property now owned or belonging to the other, or which may hereinafter be acquired by either of the parties by purchase, gifts, devise, bequests, inheritance, or otherwise, except as to the obligation, covenants and agreements contained in this Marital Property Settlement Agreement. WHEREAS, both parties each have had the opportunity to see the benefit of independent legal advice, which has been deemed competant. Page 1 of MARITAL PROPERTY SETTLEMENT AGREEMENT ~ " J, ~' '""'~i!&' , NOW THEREFORE, the Marital Property Settlement Agreement is filed as a part of this case and is made a part of this Decree in Divorce. The parties know that they are to obey all of its provision. 1. APPLICABLE LAW This Marital Property Settlement Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 2. DIVISION OF PROPERTY We divide our property as follows: 1. Husband transfers to wife as her sole and separate property the following: It is duly noted that the wife shall keep all of her personal belongings, such as clothing and effects, as well as the following: A. COMPLETE BEDROOM SUIT, MASTER BEDROOM; LIVING ROOM SUIT - COUCH, 3 CHAIRS, I FT. STOOL, 1 COFFEE TABLE; FAMILY ROOM - ENTERTAINMENT CENTER (TV, VCR, CABINET), COFFEE TABLE, 2 END TABLES, 2 LAMPS; WHIRLPOOL WASHER AND DRYER; 1 BED AND 1 WHITE DRESSER SET; WHIRLPOOL REFRIDGERA TOR; 1 GE MICROWAVE; 1 DINING ROOM TABLE WITH 4 CHAIRS; I DINETTE CABINET (GLASS) AND ALL ITEMS INSIDE; ALL PATIO FURNITURE AND GRILL; PERSONAL BELONGINGS AND CLOTHING; BASKETS; FREEZER; TOOLS IN GARAGE B. 3810 BELLOWS DRIVE, CAMP HILL, PA 17011 - SAID PROPERTY WILL BE SOLD. THE DEBTS WILL BE PAID OFF FROM THE SALE OF SAID REAL PROPERTY. IF THERE IS ANY PROCEEDS LEFT OVER, THE PROCEEDS WILL BE EQUALLY DIVIDED BETWEEN THE PARTIES. 2. Wife transfers to husband as his sole and separate property the following: It is duly noted that the husband shall keep all of his personal belongings, such as clothing and effects, as well as the following: A. 1 COUCH, 1 LOVE SEAT; 1 CHAIR AND FOOT STOOL (FAMILY ROOM); 1 19" MEMOREX (IN BEDROOM); ONE ROUND KITCHEN TABLE; FIVE CHAIRS; QUEEN SIZE BED; ALL DISHES; GLASSES; COOKWARE; COFFEE POT; ALL KITCHEN SMALL APPLIANCES; TOASTER; TOASTER OVEN; 1 REFRIGERATOR; LAWN MOWER. B. 3810 BELLOWS DRIVE, CAMP HILL, PA 17011 - SAID PROPERTY WILL BE SOLD. THE DEBTS WILL BE PAID OFF FROM THE SALE OF SAID REAL PROPERTY. IF THERE IS ANY PROCEEDS LEFTOVER. THE PROCEEDS WILL BE EQUALLY DIVIDED BETWEEN THE PARTIES. Page 2 of MARITAL PROPERTY SETTLEMENT AGREEMENT ,~~ ,.~ " I I. - ~."..;..," ~~" L ~"~,,' - . 3. DIVISION OF DEBTS 1. Husband shall pay the following debts and will not at any time hold Wife responsible for them: A. FIRST UNION, 1 ST MORTGAGE, $57000 B. NEW CUMBERLAND FEDERAL CREDIT UNION, HOME EQUITY, $26000 C. BENEFICIAL, PERSONAL HOME EQUITY, $10000 D. P A HOUSING FINANCE, EMERGENCY HOUSING, BAL. OWING. E. ALL OF HIS OWN PERSONAL DEBTS, INCLUDING BACK TAXES, PERSONAL AND SCHOOL LOANS. THE HUSBAND WILL NOT, AT ANY TIME, HOLD THE WIFE RESPONSIBLE FOR HIS DEBTS. 2. Wife shall pay the following debts and will not at any time hold Husband responsible for them: A. FIRST UNION, 1 ST MORTGAGE, $57000 B. NEW CUMBERLAND FEDERAL CREDIT UNION, HOME EQUITY, $26000 C. BENEFICIAL, PERSONAL HOME EQUITY, $10000 D. PA HOUSING FINANCE, EMERGENCY HOUSING, BAL. OWING. E. ALL OF HER OWN PERSONAL DEBTS. 4. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARTIAL RIGHTS xx Each of us forever gives up any rights to alimony, alimony pendente lite, spousal support that we may have now or in the future. _~ The Husband has agreed to pay alimony, or spousal support to the wife in the amount of $ every month, beginning on and continuing on this date IV J ;r or until the death or remarriage of the wife. 5. DIVORCE Both of the parties hereby agree that the marriage is irretrievably broken and will proceed with said Divorce action under 23 Pac C.A. Section 3301 (c). Page 3 of MARITAL PROPERTY SETTLEMENT AGREEMENT dli~",i"="=,, -~ ~~ ~"~.- ~~ - " I" 1 " "~_""~'.,~,~'~" ~.ill'tiW' . I certify that I have been trnthful in entering into this Marital Property Settlement Agreement. I am satisfied with said Property Settlement Agreement and agree to be bound by it. Dated: ~ f"e.b Clool x ~G.~ Wife SUBSCRIBED AND SWORN to before me, on the ~ day of -Et:bn)(]l(f, ,OW ,_ My commission expires: Not NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumbarland County My Comll)i$slon Expires Aug. 20, 2001. I certify that I have been truthful in entering into this Property Settlement Agre~ment. I am satisfied with said Property Settlement Agreement and agree to be bound by it. Dated: 7;:::- ~j, ~e ( SUBSCRIBED AND SWORN to before me, on the !1Hl day of _Ff:bnJt1 rZJ ,~ My commission expires: OlJ(~usJ rJIJ1dOO ( Not NOTARIAL SEAL \ SUZANNE M. DEDERER, Notary Public Camp HiR Boro, Cumberland County My Commission Expires Aug. 20, 2001 Page 4 of MARITAL PROPERTY SETTLEMENT AGREEMENT ~~;i!_~~li!>-,-"j%"",,,;;,,,,,",,j.i,:,,,,,~,."lJHili!ill~,-;;n0i'<f",\L,,ici;'~,i"'",,,,~'-I<i' """--"",,,,,,;;l;lt~,;,,;,,,,~~Jjgi~~~l~~t' ~~~.....",,"~. .' o C :?' -00':' f'HT'j Z=-p Z[~', (fl ~c,. ~L- ~C; :P.:O ~G::CI :Pc::: .~ ,j'(',LJ, "W, ,~..~_~~_,= ,~__ ,~, ",~__",,, ",fl, ~,~,.,,~",~N~,~,.,u ~ ,. ~,. {-;::, --" ~'.,., r:p (:r" -.~; '.::;s~. -v , ",."1 '~lM ...) ':.,,--! ::~ ~',-, =< -~ N '.n 1'0 , I I . --._h;,,;; ., 1.--. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. 00 - 7.35'," Co;l~ vs. JOSEPH THOMAS GRUBB. Defendant. 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 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. There is a list of counselers available at the Prothonatary's office, at S. HANOVER STREET, CARLISLE, PA 17013. 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 LA v,vYER 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. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 TELEPHONE: 717-240-6200 DEBRA ANN GRUBB, Plaintiff Address: 3810 BELLOWS DRIVE CAMP HILL, P A 17011 Telephone: 717-507-4958 ._.~ ~ l I ~ ."~'.' ~"~.,,'M~)~I', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. ~ -735<0 ~ J~ vs. JOSEPH THOMAS GRUBB. Defendant. COMPLAINT IN DIVORCE UNDER SECTION 3301 ( C) OF THE DIVORCE CODE AND NOW COMES, the Plaintiff, DEBRA ANN GRUBB, who by filing Pro Se, and who is filing this Complaint in Divorce, a statement of which is as follows: 1. The Plaintiff is DEBRA ANN GRUBB, an adult individual who presently resides at 3810 BELLOWS DRIVE, CAMP HILL, PA 17011, and Plaintiffs Social Security number is: 190-48-6627. 2. The Defendant is JOSEPH THOMAS GRUBB, an adult individual who, on information and belief, presently resides at 3810 BELLOWS DRIVE, CAMP HILL, PA 17011, and Defendant's Social Security number is : 169-44-5635. 3. DEBRA ANN GRUBB resided in the Commonwealth of Pennsylvania for at least six months immediately previous to the commencement ofthis action. 4. The parties were married on AUG. 21,1992, in SCOTRUN, PENNSYLVANIA. 5. The Plaintiff avers that: (a) The marriage between the parties is irretrievably broken. 6. No prior action for divorce or annulment has been filed in this or any other jurisdiction. 7. Plaintiff avers that this action is not collusive. Page 1 of Complaint in Divorce I _,~ "_~,_ - ::MiOiI~",' 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. The parties do not wish counseling. 9. There are no children born or adopted ofthis marriage. 10. WHEREFORE, Plaintiff requests this Honorable Court that the wife be allowed to restore her former or maiden name of MORAN. A Notice of Intention to Retake former or prior name will be filed in this action. 11. WHEREFORE, Plaintiff requests this Honorable Court the Petitioner, DEBRA ANN GRUBB, requests that this Honorable Court grant this Divorce pursuant to 330l(c) of the divorce code. Page 2 of Complaint in Divorce ~w~... , ~, " 1!I.!_liier 'c:;",oU!jj;~", . 12. WHEREFORE, Neither party is a member of any branch of the military service. 13. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. 14. WHEREFORE, Plaintiff requests a prayer for relief. (lQQJ-.\.Ma._~ Plaintiff I verify that the statements and averments made in this Complaint in Divorce herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pac C.S. Section 4904, relating to unsworn falsification to authorities. Dated \~ 00 CO ~G.~ Plaintiff My commission expires: NOTARIAL SEAL Christie L. Underkoffler. Notary Public Camp Hill Boro, Cumberland cour~ My Commission Expires June 24, 2 Page 3 of Complaint in Divorce ,,j~lllImlll,tt~M!!!l;iRi.:;(jM,..,;!i;\Hl;~iM&:\ili~~hR~;;}:,ijil,~il!';',,,Iii;$'cD'f[~,;.f."'~,'~'" .",",g;"<",,j",\i.q~k;;'.,;i""M'~~i,jl:i\<~~~ "'~Iim,,,-,,,,,;ihIiill~~il:i!I&1~~~t::~.,,, '" G C~ i~l ~ ~ ~ ~ '-~ -;, ;:1;:;- C) .__1 ~ t~}i';i" :"~ ~ -"- -I h Z;" (1"),:: tD , -.' a 0 d , lfr~:' -u - C ~-"'" () I ".c: '"' I Vj /..:: ~0 ___1 ...J (::J -<: (,0 (;; p::. ~ ~t ~,,"- ~ .. ~"'~,, , ,"~ . ," ........','; . w :O~_ !" J" ~ d ",~ ~. ,~ "I~""",~-io:" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. vs. JOSEPH THOMAS GRUBB. Defendant. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) Before me, the undersigned authority, a Notary Public in and for the Commonwealth of Pennsylvania and Cumberland County, appeared DEBRA ANN GRUBB, the Plaintiff, in the above entitled action, who being duly sworn according to the law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his or her knowledge, information and belief, and that he or she is authorized to make this Affidavit. _~G.~ Plaintiff ~RI~ED AND SWORN to before me on this /3 day of ~fur My commission expires: ClvwtuckUncWA~~ Notary Public NOTARIAL SEAL . Christie L. Underkoffler, Notary Public Camp Hut Boro, cumberland County My Commission Expires June 24, 2002 P'~ . .~~ ~" -~--'lllrl' M~i'i!lIfi<;tfW~l~;;' "'-, I _ ~,.. t''' 'It< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. Q:) - 7 3S~ vs. JOSEPH THOMAS GRUBB. Defendant. WAIVER, ACCEPTANCE OF SERVICE AND ENTRY OF GENERAL APPEARANCE Comes now the Defendant, JOSEPH THOMAS GRUBB, who is the Defendant in the above- captioned cause of action, who acknowledges receipt of a copy ofthe NOTICE TO DEFEND AND CLAIM RIGHTS, and the Complaint in Divorce and cause of action, and admits the allegations in said Complaint in Divorce, and consents to a final Decree in this matter without further notice to the Defendant, and waives all notice of disposition ofthis case. The Defendant hereby acknowledges that he/she has been advised of his /her right to counsel in this matter and knowingly and intelligently waives the same. Furthermore, Defendant hereby accepts and agrees with all the provisions and arrangements requested in the Complaint in the above-captionrd cause. c /15 rYao ~R1BED AND SWORN to before me on this ~daY of t::..eJ , ',>' My commission expires: ,J Cu--(~ &.. c:: , l>l>TARlAl.seAL l3ARBAAASTUMP,~ ' " c:= = Nov. 12, 2IlO?! ~~df(lndffiX~ Notary Public NOTARIAL SEAl. ~hlfstie ~. Undelkoffler, Notary P~bUc M amp H'~ B.oro, Cumbelfand County Y CommISSIon Expires June 24, 2002 L ~~~~ll!lM1;t,lJfi"!iIS~''''''''~:' .'.' u,", ,'"<",,,,;",.SiE,,"'i#"~' ;t1',';,h '''''_ 'ii-!,,,'--J ;'j,-,'",l',)",~,," ",',1',:);.' ..;;,.;"%H[.,\f,$i.Wifl~~~_!1lti!~~iIMlI-~~=~~M!&I~liAA\lI~IIill!NI'll11i:-I""",,,~'''' [L'B'trlt!hd;, , "" , ,:cilfw' ..,.,' 8 0 0 0 'n <;: C) -o5:j " mm -4 ~ Z:o ",...,h-l 63S:: w :',;]<.-;' -<~: :~~~~ ~G -U ~8 ::&: ~.~ <:"5 L-m >c r- S Z 55 :;:! 0 ,..;; :.,' " ",.( ',,',:,! '~ . \ " " . ~ ,- "",, , , ,..1 , ~ "jLtrM&' ELJ ________m.. _ _ ___._._______....._ .=fb~/..JbJJ.IrL..J.-~__(1d::e/CD~i.--. mm ... _...._ --m_7J~---T'u~ ... ...-...--- .........- . .... -- .---r- 'i'CL5.{!.:T.d:f._-b.h~lAl&1k:)<eq~m ... .ldl-thfu_);l@t2eli...ks.tltJ4_ 73&.~ .. 1hL1.) S..lLJd4ilL-eL._fl (.C.ep.-Iw.l~ .. ...._ m~~ _~.2ffid~r::.___.____.__ ..___ ................ ... <f}, in- " =~~;~J;~~....~.. --~~-~~~ci;t::1~_n .-. _n_n-j:Jt-ym~~ ..u___. .__ := f:i:t:j-~-~:_:-~::= --. _.~ _Cll~Ji.-I!-tJ/l~.s:.l."u____~ .____ ... C-r1A iJ.b..JL$..L;P&bJ2..__wn . }.~ . ~ '_"~J ~ " iIlklmN"""'-"""=~~ ~< "~"""""oJI,,-""",,-j,~,,,_, f'/l~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO.(':(:) 7 35(.9 vs. JOSEPH THOMAS GRUBB. Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under {Section} 3301 (c) of the Divorce Code was filed on JC1()(..+~OOO (date). 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. 1 consent to the entry of a final Decree of Divorce after service of Notice of Intention to request entry ofthe decree. ,., 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. 4904, relating to unsworn falsification to authorities. Date: S' feh 0 ( ~c. );hv.~ Plaintiff J";''l, liIL ~L"""~tbru;::N&-,' '.":~_H:_0li'Jj1J",-1ih",'!:-->BM1>4J1~i~J1ffki>l","'~-'l\'>H'''+",:'oN'''''' ,l,,,",,,,,,,,,ili.,,"-~i~'- ,,\ .1. -~ .~-, ,,",-~ ~ '--~""li~~fu'@A_;;g1Il!'k.~~~i!ll/l>O;llJ!~,~-",",~!JJ'- 0 c,;;; C~ C ~-l "'" ..., .._-, '"tl f.l.:': ,,'i m rTI ;.:::;0 Z '! ZC: CD ",'~' v' ---~..::.:. ~C .,:) ~(~) -"", ..:~.C' i):J S>c z Ui =< r-..:> - - 'j 11 . .' .1, . j 'm<J: "u,,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISON DEBRA ANN GRUBB, Plaintiff, CASE NO.D0735(." vs. JOSEPH THOMAS GRUBB, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under (Section) 3301 (c) of the Divorce Code was filed on [9, Q~ ~ooo (date). 2. The marriage of plaintiff and defendant is irretrievably broken anti 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 intbhis affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.C. 4904, relating to unsworn falsification to authorities. Date: fi'G ;?oo( rdf~ e en an <t.-...~i.r .,-. ~-" - -1l_~iiI.iUL~~~~i~'il\~M>i>"'(citI~~, " - ~-~~~ "~-~,,~, - -P , ,- ~<- "',,-- -~ "~'iOlJ''''= "~ '" - ~, I ~- ~ _........'- ,-" ....i ~ - - ill! ~ 0 C) C 7 ...,., ..:.~ --: -aU i'r1 mrn ~O Z::I: "-, ~~ v' :2 (/-1""-:,, ~L- :~;J <:C; -:;:J ,- ?~C) ~. ;:~27~~ "'-.,----- )>S::: N C) n, '--.. ~ -, U1 "'" ::u f"-..l -< .: t~ ,~L.._ _ d~ , r ~~~b''''i'''"'-'1i!':L_'".v''1 ,tte IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. bOt 3S Co vs. JOSEPH THOMAS GRUBB. Defendant. 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, lawyer's fees or expenses if{ 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:8f&o 0\ ~,~.bJo (Plaintiff) i,,' . ,- i1i :;,;i~~"''''~~r!_B.'''';'-"'J't I""~!IDli;",-;:jj-,-:J:j!-;,,-"\"_:Jk~-0l''';Hi0,:,y.;jl_',*,>;_.llitl-Hti'_,,,h,-''',2C-"d,;"'U"ii""'1i',~rll " ". ;,.. ~~= - J. i~~;_~'WI'1!A'l ~'iW:'L!~11I;:WUiiJ!_lRiii ~i ~ o C 2~ -Ot? 111,--. 2~~' If ~c_: c 2.:- .:< i;) :n r".,:, C} () ii '-" ",., co en - . UI L m"_."'-'~.__&~: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. 00 73':)fo vs. JOSEPH THOMAS GRUBB, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST EN~RY 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 pooperty, 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 thieCourt and that a copy of the decree will be seet 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: :; fiJ 0-1 . ., __ '"~~~~~~~~fi~~;;:~-'>:i'i.~,,"';,~'r ,-' .~ , ,-",' ~-~ ,- ~., ' -~ ... ~^ --- - 0 0 c ~: ..." -nee f"ll rnfT', CO- ~S;: - c' .' 59,./, ~;'~ \;;: ~-o ~-o (.5 -,~, -r""";;c' ~" (~ -'-""- 20 ~J (~;Tl 5c Z U1 ::c' =< r-..;: ~ ~ -;:1!iiliIii"~"",," ' -. "'"~-" -- ""> " L~~~#i, . . W' -p* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. 0073 SG:. vs. JOSEPH THOMAS GRUBB. Defendant. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: JOSEPH THOMAS GRUBB, (Defendant) DEBRA ANN GRUBB {Plaintiff} intends to file with the court the attached Praecipe to Transrnit Record on or after 5" F'eboAc,r'v ,(}()(){ ,requesting that a final decree in divorce be entered. t I~O.~ Plaintiff ~~~~M'i!i!;!i;1h!"_,~:i__j';'-"'~';'~d"i-i'k,i'N~h;-gt^,~-\,;_ff;jj,,,,,,;,,.;r~~"",;:,__, -,;;h;",-"",;Uiit-;..J-_"1y,ili'i~~I.!';;Mh_~<1iidi <, . t'",_\.,..,)'-- ,. ',.Ii. \~.:,; r~'''. ,~~ ~ .. -= r ~_, . __~_ . "c"," ,__, ~ - '- ~ ~ .1-""'" __c ~- - .~ -il,;j;'~'..ii.,o.iWJllIl; ~ i" "'1iml:1l'-~'1 0 0 0 c: 'j) s: ..,., -00:: ;-"tj nlp-f crJ .< LX' ZC (f) d.'. cr, --<L t<:Ci >C" '--;:';,) Z,-:., Pc 1'0 ,-~...., Z :...1"1 :~:; =< :.::0 f'V -< ~ -'v''! tdl ~" . - "~ . - ~~!!L;~#_' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA FAMILY DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. 00735 (0 vs. JOSEPH THOMAS GRUBB. Defendant. ACKNOWLEDGEMENT A C~II/-plaint in Divorce filed under Section 3301(c) of the Divorce Code was filed on \q Web<<- ,8000. I agree that the marriage between the Plaintiff and the Defendant is irretrievably broken and that ninety days has elapsed from the date of the filing of the Complaint in Divorce. All information contained herein is true and correct, to the best of my knowledge, information and belief. It is my wish to file with the Cumberland County Court of Common Pleas, the attached Marital Property Settlement Agreement, and both parties agree to be fully and completely bound by the terms and conditions as set forth with the Marital Property Settlement Agreement document. Date: .., r-eb C)ml ~a- Awbb Plaintiff SUBSCRIBED AND SWORN TO before me on this ~ day Of~, t91lo I . NOTARIAL SEAL SUZANNE M. DEDERER, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Aug. 20, 2001 ~~~~~~"'l-k-il''''i~~r."""iJW..riill>i<li;l!aM-$tj}'!'&'kS'l;o;''-'Ho''-;#''''-h-;'_t'Hf'' ,,,"'-",,_~*,i,;c.i..~_~~I~rIT:il.IiI,-'u'"'li'C. "~.",~~-,"" .~ " ~,' -~-'" ~~,~'" " ~~, ~- -~M:<-..i>llli/l__~~~~~'~t#.~o~,.~- o c-.:: < -ot1:j rnrr Z:r: ~~ <~- );::C ~g ~ -<. .I . ~;- ; 'il I II c.:') -C) -ro 01 CO C:-, ;:..'3 C'1 P0 ~i~ :v -:.: "" ,~- ~" ......_, - I ~,l, ~~"1C: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. OD 7350 vs. JOSEPH THOMAS GRUBB. Defendant. ACKNOWLEDGEMENT A Complaint in Divorce filed under Section 3301(c) of the Divorce Code was filed on lq Od-Ober ,'rlDOO. 1 agree that the marriage between the Plaintiff and the Defendant is irretrievably broken and that ninety days has elapsed from the date of the filing of the Complaint in Divorce. All information contained herein is true and correct, to the best of my knowledge, information and belief. It is my wish to file with the Cumberland County Court of Common Pleas, the attached Marital Property Settlement Agreement, and both parties agree to be fully and completely bound b the terms and conditions as set forth with the Marital Property Settlement Agre, nt doc /. . ~ Date: '7 rt- b ,;k9 e ( STJll~CRIBED AND SWORN TO before me on this ~ day of fe1rcnJ\5 -iIDL. NOTARIAL SEAL SUZANNE M. DEOERER. Notary Public Camp Hill Bo1o. Cumberland County My Commission Expires Aug. 20, 200j' ,- , ~~~I!~;;"~-o'!i'~i;;ni~",,.ML>!ili&'fM~"!;~_~ ","\,,",:-,,,~4,>&.g:Ll_,;;,,,,_,,,,,';,.-.,";,,1,,:t.;&fm~"" -, .'_0_,.' "_r^L~_",,_~o ~o ~~,,,~_=~,~"_,.'''~'',"~_ ,>>, _'1< ~ ",'~',,, ~', ,^,' ~, >~-~ ~'1=~~~'&rl.iiiI!:l~\tt;t-il!I~.liii!lijtiil1I.Ii!Mj~iliid~"l!d!~l ~ ",'", ~ ~, o ~ -rJc" rn6" ~e:'~ -< r-- !;:;; .)--'"'c 2: :< " .,-, I. ,-~ c:::> o ..." ill c:..? Ci, ~--c :co:- , \_u -:::-t--, r-...:.! ::.-~;' . i 55 -< :n .v I' "","'i!~"" ~ .- ~, .__J . 'JrIiilA.~JlIlIlii~'.!!iI!~,r~,!,"'_ , . .. .~ 6tJ1t itS" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. otJ735~ vs. JOSEPH THOMAS GRUBB. Defendant. TYPE OF PLEADING: PRAECIPE TO TRANSMIT RECORD CODE AND CLASSIFICATION: 3301 ( c) FILED ON BEHALF OF: DEBRA ANN GRUBB Plaintiff COUNSEL OF RECORD FOR THIS PARTY: NONE -,:-,~,~. ~ ~~ J " I;"''''~"$", ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB, Plaintiff, CASE NO. d Of 3S~ vs. JOSEPH THOMAS GRUBB. Defendant. PRAECIPE TO TRANSMIT RECORD To the Pronthonotary: Transmit the record, together with the following information, to the court for entry of a divorce code. 1. Grounds for divorce: Irretrievable breakdown under {Section} 3301 (c) (I) of the Divorce Code. 2. Date and Manner of service of the cornplaint: fq D(}dhe, doOO (by Personal Service or Certified Mail). 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by {Section} 3301(c) ofthe Divorce Code: by Plaintiff belorCAll;by Defendant. \..,Se.{lh" . (b) (I) Date of execution of the {plaintiffs} affidavit required by {Section} 3301 (d) of the Divorce Code: N/A; (b)(2) {date} Date of filing and service of the plaintiffs affidavit upon the {defendant} respondent: fzb lti Dc <('II d-OOO 4. Related claims pending: }JIll" 5. {Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301 (d) (1) (i) of the Divorce Code. } Page I of PRAECIPE TO TRANSMIT RECORD j;ijl~ill:-~.=-" , (Complete either (a) or (b). ) ,;, - ~ I "' ...Jh"'~"""'''h''C", (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the prothonotary: 1q Odvb"'; r1000 Date defendant's Waiver ofN~'(e in 3301 (c) Divorce was filed with the prothonotary: \q Duopw 8cco ~c.~ Plaintiff Page 2 of PRAECIPE TO TRANSMIT RECORD '5 F.vorvv..y doc I Date ~ ~e/; Date c?e9-e ( ~~t.rffuill;:~~iJ.t>)\l~H"#\;\~~llJ;.;~~h"~<MfMr~j:~<l"-k,i"'U;,1'ffl..~,ktl;;;c~~ >.,~-,-'" ~m__"'~~ "~, ~-- '"~'.'--~~,, .~ -~~-~ ~ " ," -~ --., - ~ ,'~' ~ !!MlRlw~'-" ~~d~~U.'~ n c-"':-: \]$'; rp",-. _____..'r. ~~:r 05' ~-~-~ --< r-' 19 -< - - UJ Iv -'j I , ,. C;;) -- -.., ;~;] -- G''-; - i).? -~.::)~~' S;~ :lJ -< . ,d".' " 1;;. i ,-I J. W -""'t~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F AMIL Y DIVISION DEBRA ANN GRUBB Plaintiff, CASE NO. 00"73510 Vs. JOSEPH THOMAS GRUBB Defendant NOTICE OF INTENTION TO RETAKE FORMER OR PRIOR NAME Notice is hereby given that the Plaintiff, DEBRA ANN GRUBB in the above entitled matter, having been granted a final Divorce Decree, on the ~ '3 day of.febr U O/'f-' 20a!., hereby elects to retake and will hereafter use her maiden or prior name of MORAN, and hereby gives this written notice avowing her intention to do so, in accordance with the provisions of 54 Pa C.S.A. 704. _~ Ckm A,bb Plaintiff WHO WILL NOW BE KNOWN AS: DEBRA ANN MORAN SUBSCRIBED AND SWORN to ~fore me, on the /J!"dayof fJ'nA Il.l'A , f)() I My cornmision expires: NOTARIAL SEAL . ER, Notary Public Borough of Carlisle, Cumberland County My Comm!sslon Expires April 26, 2004 ~ho'/ f. ~/1d.p~J Notary Public in and for {1rYlJ-fteJi J A1 ~ ~ tlM "-_...'- '1:&.1&~~Ii!Il,;;~Ilitr~~~~I:Wf:;~;!a;~~-"'"""'-'-il1l'" ''''--"'''~11 ~ - -~"""". ~ 'M';' ..-" ~,"" ~- . , (-~ ~ C> 0 -1:1 r FD ? 3: \~. = :::::i -'.' ) -UQ:l :s.> ;-'i-i :I1 ~lD ;:0 -'-' , ZC;:: .':Jm N -")? --...... ~:2: ,5 D ~ co ~u ~ :<00 :ell "'<""'I i :x ,::>.,-, z8 :'''.0 €'. L-m :i>~ S ~ z u:> ~ :::? "'" ~ J: ~