HomeMy WebLinkAbout07-1435ELLEN L. GRIFFIE,
VS.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
: No. 6? - ly3S' Civil Term
JEFFREY L. GRIFFIE,
Defendant
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
ELLEN L. GRIFFIE,
vs.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY L. GRIFFIE,
Defendant
: No. 07 - /A.3.? Civil Term
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Ellen L. Griffie, a competent adult individual, who resides at 3211 Enola
Road, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Jeffrey L. Griffie, a competent adult individual, who resides at 550
Burnheisel Bridge Road, Carlisle, Cumberland County, Pennsylvania, 17013.
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 February 16, 1986 in Cumberland
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 one minor child together, namely, Trisha Griffie, date of
birth, May 25, 1994.
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.
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10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
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 unsworn
falsification to authorities.
Ellen L. ' ie, PlaintkDU
Respectfully
Date:
Adams, Esquire
No. 79465
A.l
South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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ELLEN L. GRIFFIE,
vs.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY L. GRIFFIE,
Defendant
No. 07 - 1435 Civil Term
ACTION IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this March 26, 2007, I, Jane Adams, Esquire, hereby certify that
on March 20, 2007, a certified true copy of the NOTICE TO DEFEND AND DIVORCE
COMPLAINT were served upon the Defendant, via certified mail, restricted delivery, return
receipt requested at the following address:
Jeffrey Lee Griffie
550 Burnheisel Bridge Roa
Carlisle, Pa. 17013 ¦ Complete items 1,and 3. Also complete
DEFENDANT item 4 if Restricted Delivery is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
JEFFREY LEE G?2IFFIE
550 'SURNHEISEL BRIDGE RD
CARLISLE PA 17713
A.
D. is deli Tess different from em 1? ? Yes
If YES, enter delivery address below: ? No
3.
yvice Type
Mail ? Express Mail
? Rraplalered ? Return Receipt for Merchandise
? k>orxed Mail ? C.O.D.
4. RNhIrl D~ gFift fie)
2. Article Number
(/l 70'06 081 0000 7884 133
WOW from sendce laben
Ps Form 3811, February 2004 Domestic Return Receipt 10e5"-M-1540
Respectfully Submitted:
V ams, Esquire
. 79465
64 South Pitt Street
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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ELLEN L. GRIFFIE,
VS.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
No. 07 - 1435 Civil Term
JEFFREY L. GRIFFIE,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 14, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the 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 of
the decree.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date:
C
Ellen L. Groie, ai ntif
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301(c) AND 63301(d) OF THE DIVORCE CODE
1. 1 consent to 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. 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:
Ellen L. Gr ffie Plainti
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ELLEN L. GRIFFIE,
VS.
IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY L. GRIFFIE,
Defendant
No. 07 - 1435 Civil Term
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on March 14, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the 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 of
the decree.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
Date: O? I I G? Jefftdy rif efe n
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER 43301(c) AND §3301(d) OF THE DIVORCE CODE
1. I consent to 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. 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:
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MARRIAGE SETTLEMENT AGREEMENT BETWEEN
ELLEN L. GRIFFIE AND JEFFREY L. GRIFFIE
THIS AGREEMENT, made this day of , 2006, by and
between, ELLEN L. GRIFFIE, of Carlisle, Cumberland County, Pennsylvania, hereinafter
referred to as "WIFE", and JEFFREY L. GRIFFIE, of Carlisle, Cumberland County,
Pennsylvania, hereinafter referred to as "HUSBAND".
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on February 16, 1986, in
Cumberland County, Pennsylvania, and;
WHEREAS, there were two children born of this marriage;
WHEREAS, differences, disputes, and difficulties have arisen between the parties and it
is the intention of Husband and Wife to live separate and apart for the rest of their natural lives,
and the parties desire to settle their respective financial property rights and obligations as
between each other, including the settling of all matters between them relating to ownership and
equitable distribution of real and personal property; the settling of all matters between them
relating to the past, present, and future support, alimony, and/or maintenance of Husband or
Wife; and in general, the settling of any and all possible claims by one against the other or
against their respective estates;
NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby
covenant and agree as follows:
1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a
full and fair disclosure of income, assets, and their valuation prior to the execution of this
Agreement as well as any other fact relating in any way to the subject matter of this agreement.
These disclosures are part of the consideration made by each party for entering into this
agreement.
2. ADVICE OF COUNSEL. The Husband is PRO SE. The Wife has employed and
had the benefit or counsel of Jane Adams, Esquire, as her attorney. Each parry has carefully and
completely read this agreement and has been advised and is completely aware not only of its
contents but of its legal effect. Husband has been advised of his right to counsel, voluntarily
elected to forego representation, and understands that Jane Adams, Esquire is only representing
Wife.
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3. SEPARATION. The parties intend to maintain separate and permanent domiciles
and to live apart from each other. It is the intention and purpose of this agreement to set forth
their respective rights and duties while they continue to live apart from each other. Neither party
shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment,
or disposition of any property now owned and not specified herein or property hereafter acquired
by the other.
4. SUBSEQUENT DIVORCE. Should a subsequent divorce be filed, the parties hereby
waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of
this Agreement relating to equitable distribution of property of the parties are accepted by each
party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania
Divorce Code.
Should a decree, judgment, or order of separation or divorce be obtained by either of the
parties in this or any other state, country or jurisdiction, each of the parties hereby consents and
agrees that this Agreement and all of its covenants shall not be affected in any way by any such
separation or divorce or reconciliation; and that nothing in any such decree, judgment, order, or
further modification or revision thereof shall alter, amend, or vary any term of this Agreement,
whether or not either or both of the parties shall remarry or reconcile. It is specifically agreed
that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by
reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a
merger, it being the specific intent of the parties to permit this Agreement to survive any
judgment and to be forever binding and conclusive upon the parties.
5. DATE OF EXECUTION. The "date of execution" or "execution date" of this
agreement shall be defined as the date upon which it is executed by the parties if they have each
executed the Agreement on the same date. Otherwise, the "date of execution" or "execution
date" of this Agreement shall be defined as the date of execution by the party last executing this
Agreement. All provisions of this agreement shall be effectuated by the parties within thirty
(30) days of the execution date of this agreement unless otherwise specified within this
agreement.
6. MUTUAL RELEASE OF ALL CLAIMS. Other than as provided in this
agreement, each party may dispose his or her property in any way and each party hereby waives
and relinquishes any and all rights he or she may now have or hereafter acquire under the present
or future laws of any jurisdiction to share in the property or the estate of the other as a result of
the marital relationship, including without limitation, statutory allowance, widow's allowance,
right of intestacy, right to take against the will of the other, and right to act as administrator or
executor in the other's estate. Each will at the request of the other, execute, acknowledge, and
deliver any and all instruments which may be necessary or a able to carry into effect this
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mutual waiver and relinquishment of all such interest, rights, and claims.
7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each parry warrants
that they have not contracted any debt or liability for the other or which the estate of the other
party may be responsible or liable, and except only for the rights arising out of this agreement,
neither party will hereafter incur any liability whatsoever for which the other party or the estate
of the other parry, will be liable. Each parry agrees to indemnify or hold harmless from the other
and against all future obligations of every kind incurred by them, including those for necessities.
8. OUTSTANDING JOINT DEBTS.
(a) Wife agrees that the following debts are her own personal responsibility and therefore
agrees to completely and finally pay on the following debts and obligations.
(b) Husband agrees that the following debts are his own personal responsibility and
therefore agrees to completely and finally pay on the following debts and obligations.
9. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have
attempted to distribute their marital property in a manner which conforms to the criteria set forth
in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of
the marriage, the age, health, station, amount, and sources of income, vocational skills,
employability, estate, liabilities, and needs of each of the parties, the contribution of each parry to
the education, training, or increased earning power of the other parry; the opportunity for each
party for future acquisitions of capital assets and income; the sources of income of both parties,
including but not limited to medical, retirement, insurance or other benefits; the contribution or
dissipation of each parry in the acquisition, preservation, depreciation, or appreciation of the
marital property, including the contribution of each spouse as a homemaker; the value of the
property set apart to each party; the standard of living the parties established during the marriage;
and the economic circumstances of each party at the time the division of property is to become
effective.
The division of existing marital property is not intended by the parties to constitute in any
way a sale or exchange of assets, and the division is being effected without the introduction of
outside funds or other property not constituting marital property. The division of property under
this Agreement shall be in full satisfaction of all the marital rights of the parties.
' bligation to make the
As such, the parties acknowledge that Husband or TE6;Ay
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payments defined in this agreement shall not be subject to termination, discharge, or
discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should
Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his
obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she
shall immediately be obligated to pay alimony to the other party in an amount equal to the
monthly obligation on such debts that he or she otherwise had assumed and for which he had
taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration
of the tax consequences associated with receipt of alimony. At the time of the implementation of
this alimony award, which may be made through the appropriate Domestic Relations of support
office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may
select, such party shall then be responsible for any such debts extinguished through the other
party's bankruptcy as described herein.
10. PERSONAL PROPERTY. Other than as provided in this agreement, Husband and
Wife do hereby acknowledge that they have previously divided all their tangible personal
property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the
property of Husband or in his possession shall be the sole and separate property of Husband; and
Husband agrees that all of the property of Wife or in her possession shall be the sole and separate
property of Wife. The parties do hereby specifically waive, release, renounce, and forever
abandon whatever claim, if any, he or she may have with respect to the above items which shall
become the sole and separate property of the other.
Husband may retrieve his personal possessions in the garage within six months of
this agreement provided he gives twenty-four hours notice of the time and date he
wishes to retrieve such items to Wife, and Wife agrees that such time is convenient.
11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both
of the parties, they agree as follows:
Husband shall receive the Chevy Blazer, provided he can obtain his own insurance
for the vehicle.
Wife shall retain all other vehicles. The BMW shall remain with Emily Griffie.
The titles to the said motor vehicles shall be executed by the parties, if appropriate for
effecting transfer as herein provided, within thirty days of the execution date of this Agreement,
and said executed titles shall be delivered to the proper parties on the distribution date. Each
party agrees to be solely responsible for the amounts presently due and owing against his or her
respective automobiles.
12. REAL ESTATE. HUSBAND and WIFE hold title as Tenants by the Entireties to
the premises identified 3211 Enola Road, Carlisle, Cumberland County, Pennsylvania. The
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parties agree as follows with respect to the marital residence:
(a) Husband relinquishes all right, title and interest in the marital home to Wife, Wife
shall retain the marital home and shall have sole and exclusive possession of the marital
home immediately upon signing this agreement. Within ninety-days of the signing of this
agreement, Wife shall make arrangements to refinance the mortgage obligation on the
marital home in her name alone. At least thirty days before refinancing, Husband will
execute a Deed relinquishing all right, title, and interest to the marital home to Wife.
Upon the date of refinancing, Wife shall pay Husband the sum of $20,000.00 in
exchange for relinquishing his right, title and interest in the marital home. Wife shall
pay all expenses to effectuate the transfer of the Deed and Wife will pay the filing fee for
the Deed.
(b) As of the date of this agreement, and without regard to when bills for such items are
incurred, received or due, WIFE shall be solely responsible for all past, present, and
future costs or liabilities associated with or attributable to maintaining the marital
residence (except as provided herein), including but not limited to, all real estate taxes,
water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and
gardening expenses and repairs, and WIFE shall keep HUSBAND and his successors,
assigns, heirs, executors, and administrators indemnified and held harmless from any
liability, cost or expense, including attorney's fees, which are incurred in connection with
such maintenance, costs, and expense.
(c) Cabin. Husband and Wife currently own a Cabin and are stockholder in an
association in Dillsburg, Pennsylvania. Husband hereby relinquishes all right, title and
interest in such cabin and will cooperate in executing any documents required to
relinquish the cabin or his membership. As of the date of this agreement, Wife shall have
sole and exclusive possession of the cabin, and shall be responsible for all fees or
expenses associated with the cabin.
13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to
waive any and all rights they have in and to each other's employment benefits, including but not
limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties
agree never to assume any claim to such benefits of the other at any time in the future.
14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each parry
hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party
agrees to be responsible for his or her own legal fees and expenses. The parties herein
acknowledge that by this Agreement, they have respectively secured and maintained a substantial
and adequate fund with which to provide for themselves sufficient financial resources to provide
for their comfort, maintenance, and support in the station of life to which they are accustomed.
Wife and Husband do hereby waive, release, and give up any rights they may respectively have
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against the other for alimony, support, or maintenance. It shall be from the execution of this
Agreement the sole responsibility of each of the respective parties to sustain themselves without
seeking any support from the other party. All alimony to be paid under this agreement shall
terminate upon the recipient's remarriage or cohabitation with a person of the opposite sex.
15. INCOME TAX RETURNS. Husband and wife represent to each other that to the
best of their knowledge all federal, state, and local taxes required to paid with during the
marriage and during the periods covered by such tax returns have been paid. Husband and Wife
further represent that there are no tax deficiencies proposed or assessed against Husband and/or
Wife for such periods, and neither Husband nor Wife executed any waiver of the Statute of
limitations oil the assessment or collection of any tax for such periods. If any deficiency in
federal, state, or local income taxes is proposed, or any assessment of any such tax is made
against the other party by reason of his or her having joined in the filing of joint federal, state or
local income tax returns, Husband and Wife shall indemnify and hold harmless the other against
and from any and all tax, interest, penalty, or expense relating from any such tax deficiency,
including reasonable counsel and accounting fees, and such tax, interest, and penalties or
expenses shall be paid solely and entirely by the responsible party as determined to be
attributable to that party on account of misrepresentation or failure to disclose relevant
information of income on the aforesaid joint returns.
16. CUSTODY. The parties are the natural parents of two children, namely Emily
Griffie, who is a competent adult and is nineteen (19) years of age, and Trisha Griffie, date of
birth (5/25/94), who is age twelve (12). The parties agree that they shall have joint legal
custody of Trisha Griffie. Mother shall retain primary physical custody of the child and Father
shall have liberal periods of partial custody with Trisha Griffie as agreed by the parties. This
agreement may be modified by subsequent mutual agreement of the parties or further Order of
Court.
17. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or
waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and
no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent
default of the same or similar nature.
18. MUTUAL COOPERATION. Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and
all further instruments and/or documents that the other party may reasonably require for the
purpose of giving full force and effect to the provisions of this Agreement.
19. APPLICABLE LAW. The Agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this
Agreement.
20. INTEGRATION. This Agreement constitutes ntire understanding of the
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parties and supersedes any and all prior agreements or negotiations between them. There are no
representations or warranties other than those expressly set forth herein.
21. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they
will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds,
notes, or such other writings as may be necessary or desirable for the proper effectuation of this
Agreement.
22. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect
unless and until terminated under and pursuant to the terms of this Agreement. The failure of
either parry to insist upon strict performance of any of the provisions of this Agreement shall in
no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any
default or breach of any provision hereof by construed as a waiver of any subsequent default or
breach of the same or similar nature, not shall it be construed as a waiver or strict performance of
any other obligations herein.
23. SEVERABILITY. If any term, condition, clause, or provision of this Agreement
shall be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause, or provisions shall be stricken from this Agreement; and in all other respects,
this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the
failure of any parry to meet his or her obligations under any one or more of the paragraphs herein,
with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter
the remaining obligations of the parties.
24. BREACH. If either party breaches any provisions of this agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach, or seek other
remedies or relief as may be available to him or her, and the party breaching this contract should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this agreement.
25. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement
acknowledges that he or she is fully informed as to the facts relating to the subject matter of this
agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion
or duress of any kind, has given careful thought to the making of this agreement, has carefully
read each provision of this agreement, and fully and completely understands each provision of
this agreement.
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IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and
year first above written:
WITNESS:
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Date: el I L/b
EE G F 4*, Husband
COMMONWEALTH OF PENNSYLVANIA
):ss
COUNTY OF CUMBERLAND )
On this, the P day,of 2006, before me, the undersigned officer,
personally appeared JEFFREY LEE GRIFFIE known to me, (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that he/she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
itn ss
Date: q1) /OL
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COMMONWEALTH OF PENNSYLVANIA )
):SS
COUNTY OF CUMBERLAND )
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On this, the I q day of 1-"Psttle? , 2006, before me, the undersigned officer,
personally appeared ELLEN L. GRIFFIE known to me, (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that he/she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand official seal.
Ndtarv Public
y commission expires:
SEAL
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Jane Adams, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Sept. 6, 2008
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ELLEN L. GRIFFIE, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 07 - 1435 Civil Term
JEFFREY L. GRIFFIE, ACTION IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY: Please transmit the record, together with the following
information to the Court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under 3301 c of the Divorce Code.
2. Date and manner of the service of the Complaint: Served via certified mail, restricted
delivery, return receipt requested on: March 20, 2007.
3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code:
By Plaintiff:
By Defendant:
June 21, 2007.
June 21, 2007.
4. Related claims pending: None; the marriage settlement agreement should be
incorporated and not merged into the decree as provided in the agreement
5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: June 25, 2007.
Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: June 25, 2007.
Respectfully Submi
Date: ° D7
J Adams, Esquire
No. 79465
4 S. Pitt Street
V
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Ellen L. Griffie, Plaintiff
No. No. 07 - 1435 Civil Term
VERSUS
Jeffrey L. Griffie, Defendant
DECREE IN
DIVORCE
AND NOW, Vw4. I17? Zoo? IT IS ORDERED AND
DECREED THAT Ellen L. Griffie , PLAINTIFF,
AND Jeffrey L.Griffie DEFENDANT,
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;
None; The marriage settlement agreement which was signed by the parties on
on August 17, 2006 shall be incorporated and not merged into this Decree.
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