The URL can be used to link to this page

Home My WebLink About03-2424SCOTT W. GRISSINGER, Plaintiff : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. C)3 ---,,~.~,~,.~ VIVIAN GRISSINGER, Defendant CIVIL ACTION-LAW :IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAVVYER 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 SCOTT W. GRISSlNGER, Plaintiff VS. VIVIAN GRISSINGER, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA NO. 03--.. CIVIL ACTION-LAW · IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Scott W. Grissinger, by her attorneys, Purcell, Krug & Hailer, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Scott W. Grissinger, an adult individual whose current address is 4175 Mountain View Road, Apt. 107, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Vivian Grissinger, an adult individual whose current address is 1459 Washington Avenue, Severn, Maryland 21144. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married in 1999 in Washington, D.C. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties under the age of 18. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The Social Security Number of the Plaintiff is 167-66-6914 and the Social Security Number of the Defendant is unknown. 10. The marriage is irretrievably broken. 11. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Dated: May 20, 2003 Scott W. Grissinger SCOTT W. GRISSINGER, Plainitff VS. VIVIAN GRISSINGER, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · · CIVIL ACTION-LAW · IN DIVORCE NOTICE TO THE DEFENDANT: If you wish to deny any of the statements set forth in this Affidavit, you must file a counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in 1999 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: May 20, 2003 Scott W. Grissin~e~7¢ BY: ANTHONY D. DAMIANO, ESQ. ID NO. 49499 226 West Market Street West Chester PA 19382 610-692-6520 Amy Eisen VS. Attorney for Plaintiff This is an Arbitration Matter Court of Common Pleas Cumberland County, Pennsylvania CIVIL ACTION 2002-5397 James Fisher, : FEDEX Freight, East Inc., as successor to: American Freightways Corporation, : and/or American Freightways Corporation : Defendants : Magrielle Eisen : COSOLIDATED CASES Court of Common Pleas VS. · James Fisher, : FEDEX Freight, East Inc., as successor to: American Freightways Corporation, : and/or American Freightways Corporation Defendants : Cumberland County, Pennsylvania CIVIL ACTION 2002-2424 PETITION FOR APPOINTMENT OF ARBITRATORS Anthony D. Damiano, Esquire, counsel for Plaintiff, Amy Eisen in the above action respectfully represents that: 1. The above captioned actions are at issue. 2. The plaintiffs' claims in the actions are for within the statutory jurisdictional limits of arbitration. 3. Each attorney for the parties are from counties other than Cumberland County and thus, no attorney from Cumberland County should be disqualified. WHEREFORE, plaintiff respectfully requests your Honorable Court appoint three arbitrators to whom the case shall be submitted. BY: ANTHONY D. DAMIANO, ESQ. ID NO. 49499 226 West Market Street West Chester PA 19382 610-692-6520 Attorney fog' Plaintiff This is an Arbitration Matter Amy Eisen · VSo James Fisher, · FEDEX Freight, East Inc., as successor to: American Freightways Corporation, ' and/or American Freightways Corporation Defendants : Court of Common Pleas Cumberland County, Pennsylvania CIVIL ACTION 2002 - 5397 CONSOLIDATED CASES Magrielle Eisen : James Fisher, · FEDEX Freight, East Inc., as successor to: American Freightways Corporation, : and/or American Freightways Corporation : Defendants : Court of Common Pleas Cumberland County, Pennsylvania CIVIL ACTION 2002-2424 ORDER AND NOW thisa~0 day of for appointment of arbitrators, ~,o~ ~-A4/~~-,j ,Esquire, / are appointed arbitrators in the above consolidated actions. ,200t3, upon consideration of the Petition , Esquire SCOTT W. GRISSII~ VS. VlVIAN GRISSINGE TO THE PROTHON"I Please reinst~ Date: GER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2424 CIVIL TERM : CIVIL ACTION-LAW :IN DIVORCE PRAECIPE te the Divorce Complaint in the above captioned matter. PURCELL, KRUG & HALLER BY /,-'~hn/~N. ~.zrcell, Jr. // LJ~'~29955 t~/,¢719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAURA RICKABt Plaintiff RICHARD L. RICKABAUGH, Defendant AND NOW Petition To Bifurc~ being held due to Institution at Hunti: Sheriff's Office, the in Courtroom No. 1, v/~lichael J. Whare, E~ 155 S. Hanover Stree Carlisle, PA 17013 Attorney for Plaintiff ,,'Richard L. Rickabm SCI-Smithfield P.O. Box 999 Huntingdon, PA 16{ Defendant, Pro Se :rc 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2352 CIVIL TERM PLAINTIFF'S PETITION TO BIFURCATE ORDER OF COURT this 27th day of October, 2003, upon consideration of Plaintiff's e, and the hearing previously scheduled for October 27, 2003, not the Defendant not being transported from the State Correctional lgdon because no Writ was delivered to the Cumberland County hearing is rescheduled to Monday, November 24, 2003, at 1:30 p.m., Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, y Ol~r~'., ;2 DB-6288 SCOTT W. GRISSINGER, Plaintiff VS. VIVIAN GRISSINGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2424 CIVIL TERM : CIVIL ACTION-LAW :iN DIVORCE PHAECIPE TO THE PROTHONTARY: Please reinstate the Divorce Complaint in the above captioned matter. PURCELL, KRUG & HALLER ('~ I~'~ ~ 9~N~V~ 9~o[l~tJ~ir e et Harrisburg, PA 17102 (717) 234-4178 Date: December 3, 2003 AFFIDAV, IT OF SERVICE. County of CUMBERLAI~D Commonwealth of Pennsylvania Common Pleas Court Case Number: 03-2424. CIVIL TERM Plaintiff: SCOTT W. GRISSINGER vs. Defendant: VIV1AN GRISSINGER For: John W, Purcell Jr. PURCELL, KRUG & HAL[ER Received by CHOICE PROCESS - TAMPA on the 8th day of December, 2.003 at 4:05 pm to be sewed on VIVIANGRISSINGER, 1459 WASHINGTON AVE SEVERN, MD 21144 -,1. [, .gm~.v~.~ WHITEMAN , beinrj, duly sworn, depose and say that on the 1 1T[--[ day o,' DEc~J~mel~.20.~ at 8: 1 2 __: ~ .m., execu~:ec~ service ~y deliver[ng a true copy of the NOTICE TO DEFEND ANO CLAIM RIGHTS AND COMPLAINT IN DIVORCE AND PLAINTIFF'S AFFIDAVIT In accordance .with state statutes in the manner marked bclow: ~'()x!NDIVIDUAL SERVICE: Served the within-named person. (PERSONALLY) ( ) SUBSTITUTE SERVICE: By serving as () POSTED SERVICE: After attempting service on __ place on the property clescribe~ herein. / .nt and on .~./~ at to a conspicuous ( ) OTHER SERVICE: As descdbod In the Comments ~olow l}y serving () NON SERVICE: For the reason detailed In the Comments below. MARRIED: YES YES OR NO MILITARY STATUS: COMMENTS: NO NO AFFIDAVIT OF SERVICE for 03-2424 CIVIL TERM I certify that I have no interest in the above action, am of legal age a. nd have proper authority in the jurisdiction in which this service was made. ~ay o) ... ' F~/'-L/) ' 'g/~/by the ~ffiant who is /~em~ally ~own ~ me~ ' , //lq l I 'NOT~ PuBLIc ~ PROC~SERVER # Appoint[ed in a~'co~d~nce ' ' wl~ State Statutes CHOICE PROCESS. TAMPA P.O. Box 1215 Tampa, FL 33601 (813) 229-1 Our Job Serial Number':. 2003006599 SCOTT W. GRISSlNGER, Plaintiff VS. VIVIAN GRISSINGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA -NO. : CIVIL ACTION-LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 SCOTT W. GRISSINGER, Plaintiff VS. VIVIAN GRISSINGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. : CIVIL ACTION-LAW :IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Scott W. Grissinger, by her attorneys, Purcell, Krug & Hailer, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Scott W. Grissinger, an adult individual ~vhose current address is 4175 Mountain View Road, Apt. 107, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Vivian Grissinger, an adult individual whose current address is 1459 Washington Avenue, Severn, Maryland 21144. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Cornplaint. 4. Plaintiff and Defendant were married in 1999 in Washington, D.C. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties under the age of 18. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The Social Security Number of the Plaintiff is 167-66-6914 and the Social Security Number of the Defendant is unknown. 10. The marriage is irretrievably broken. 11. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 2 WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree: Dated: May 20, 2003 PURCELL, KRUG & HALLER ('"John~/. Pur'c'~ll, Jr., Esquir~ ~,.~D.~.~t, Z9955 J719 North Front Street Harrisburg, PA 17102 (717)234-4178 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements iherein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authotities. Dated: May 20, 2003 Scott W. Grissinger SCOTT W. GRISSINGER, Plainitff VS. VIVIAN GRISSINGER, Defendant : IN THE COURT' OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : IN DIVORCE NOTICE TO THE DEFENDANT: If you wish to deny any of the statements set forth in this Affidavit, you must file a counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in 1999 and have continued to live se~ra{l~an~ apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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: Nay 20, 2003 Scott W. GriSsinge~'Y SCOTT W GRISSINGER, Plaintiff VS. VIVIAN GRISSINGER, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-2424 CIVIL TERM : : CIVIL ACTION.-LAW : 1N DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN I, JOHN W. PURCELL, JR., Attorney for the Plaintiffin the above action, hereby swear and affirm that on the 31 st day of December, 2003, I sent, by first class mail, a Notice of Intention to Request Entry of Divorce Decree and Defendant's Counter-Affidavit under :Section 3301 (d) of the Divorce Code to Vivian Grissinger, the Defendant in the above action. A copy of the Notice of Intention with Defendant's Counter Affidavit is attached as Exhibit "A". Sworn and subscribed to before me this ~S~day of~, 2004. Notary Public SCOTT W. GRISSINGER, Plaintiff VS. VIVIAN GRISSINGER, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-2424 CIVIL TERM : CIVIL ACTION-LAW · IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECRFF TO: VIVIAN GRISSINGER, DEFENDANT 1459 Washington Avenue Severn, MD 21144 You have been sued in an action for Divorce. You have failed to answer the Complaint or file a Counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after January 26, 2004, the Plaintiff can request the Court to enter a final Decree in Divorce. If you do not file with the Prothonotary of the Court an Ar~swer with your signature notarized or verified or a Counteraffidavit by the above date, the Court can enter a final Decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the Divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 SCOT1~ W. GRISSlNGER, VS. VIVIAN GRISSINGER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERr,AND COUNTY, PENNSYLVANIA : : NO. 03-2424 CIVIL TERM : CIVIL ACTION-LAW : IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODF. 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. __ (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both): __ (i) The parties to this action have not lived separate a~xd apart for a period of at least two years. __ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): __ (a) I do not wish to make any claims for economic relief. 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. __ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counterafl~davit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a Divorce Decree and you do not wish to make any claim for economic relief, you need not file this Counteraffidavit. SCOTT W. GRISSINGER, Plaintiff VS. VIVIAN GRISS1NGER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-2424 CIVIL TERM : CIVIL ACTION..LAW : IN DIVORCE THEPROTHONOTARY: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section (1~) 3301(D) of the Divorce Code. 2. Date and manner of service of the Complaint: December 8, 2003 by personal service 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: by Defendant: (b) (1) Date of execution of the Plaintiffs Affidavit required ky Section 3301(d) of the Divorce Code: May 20, 2003 (2) Date of service of the Plaintiffs Affidavit upon the Defendant: December 8, 2003 by personal service 4. Related claims pending: No economic claims have been raised. 5. (a) Date and manner of service of the Notice of Intention to file Praecipe to transmit record, a copy of which is attached: First Class Mail on December 31, 2003 (b) Date of Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with Prothonotary: Date of Defendant's Waiver of Notice in 3301(c) Divorce, was filed with the Prothonotary: ~UR-~'LL, JR. ]-;SQ. IN THE COURT Of COMMON PLEAS OF CUMBERLANDCOUNTY STATE Of SCOTT W. GRISSINGER Plaintiff VERSUS VIVIAN GRISSINGER Defendant PENNA. 03-2424 Civil Term DECREE IN DIVORCE AND NOW,~ DECREED THAT Scott W. Grissinger 2004 AND Vivian Grissinger , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS Of MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOL.LOW[NG CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YEt bEEN ENTERED; A'~Y ~i~F~"S -7 ..... ~ -cpp~ ~_~_ J,~il l,=~=l.,,~ft~ ~- ~ .... ~ ~- BY THEi COURT:/a~/~ ATTESt' PROTHONOTARY