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HomeMy WebLinkAbout01-0548 FXI' F JANET L. GRUSCHOW, Plaintiff VS. MATTHEW J. GRUSCHOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O!- 5'f? ACTION 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 (717) 249-3166 JANET L. GRUSCHOW, Plaintiff VS. MATTHEW J. GRUSCHOW, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O J - 5cfP C'?'j e.- ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Janet L. Gruschow, an individual sui juris, who has resided at 726 Colonial Court, Mechanicsburg, Cumberland County, Pennsylvania, since September 2000. 2. Defendant is Matthew J. Gruschow, an individual sui juris, who has resided at 31 Emlyn Lane, Mechanicsburg, Cumberland County, Pennsylvania, since July 1999. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 6, 1984 in Lackawanna County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have three (3) children together, namely, Brandon Gruschow, date of birth, 2/22/90, Jared Gruschow, date of birth, 5/29/91, and Alexa Gruschow, date of birth, 4/16/94. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. ,.W 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. li4?? - et L. Grus ow, Plaintiff Respectfully submitted, 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 unworn falsification to authorities. Date: % 9 J ie Adams, Esquire 9. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 0i ,i 14 N' 26 PM 2: 2R CUMBERLAND COUNlY PENNSYLVANA / ?..a 5-d Pd t?f't?. Q?Gms ?j? 00 / yo- , s`° ?k /05 y ?p JANET L. GRUSCHOW, Plaintiff VS. MATTHEW J. GRUSCHOW, Defendant 3 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 548 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT. AND NOW, this February 2, 2001, I, Jane Adams, Esquire, hereby certify that on February 1, 2001, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Matthew J. Gruschow 31 Emlyn Lane Mechanicsburg, Pa. 17055 DEFENDANT Respectfully Submitted: Ape Adams, Esquire I. P. No. 79465 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF i L7 01FF6-5 PH 1:[s6 ?L'?rL i =t;vu' 010-iNIY PFNNSYEVANIA ?4 2, ¦ Pdnt'you-r n3me'and address on the reverse C ' at so that WeTcan Mum the card to you. d . 0 Age"i1F'- ¦ Attach this car to the back of the mailpiece, - X 17 Addressee or on the front if space permits. _ 1. A rtic edto: le Addddress D. rvery different from item 17 f , ent r ery address below: ? Yes ? No , ' ? ; ? ? ?Wl/U llw`i Gro SADw` r Mejx ? 7T Service Type XdjjjMW Express Mail G i OS ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 2. Article Number (Copy from service labeq PO176nm 381 T, jwiy 1999, Domestic Return Receipt to25e5-9e-M-1789 In The Court of Common Pleas of Cumberland County, Pennsylvania File No. 2001-00548 GRUSCHOW JANET L VS GRUSCHOW MATTHEW J STATEMENT OF INTENTION TO PROCEED To the Court: MATTHEW J. GRUSCHOW Date: ®vd'(`1 intends to proceed with the above captioned matter. Attorney for Defendant Murrel R. Walters III 54 East Main Street Mechanicsburg, PA 17055 t?f ??I1n!\ Curtis R. Long Prothonotary Office of the Protbonotarp Cuntberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor e) / - Sy S CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573