HomeMy WebLinkAbout01-04424IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Np, 01-4424 CIVIL ~:
DECREE IN
DIVORCE
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AND NOW, ~.{~~~":.. ~ ~ .... , ..... , it is ordered and
d@cr@@d thOt .G&RY..R.. GRANQ ................................ . plaintiff,
and ...JACQgE~~.N~.,~....GgANQ ................................ 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
.................................................................. a
GARY R. GRANO~
. ZN THE COURT OF COMMON PLEAS
Plaintiff _ CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL DIVISION
JACQUELINE J. GRAND, NO. 01-4424
Defendant IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
CIVIL TERM
Transmit the record, together with the following information to
the court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under 53301(c)
~~~~~~~~~ of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: July 26. 2001
Certified mail, restricted deliver
3. Complete either paragraph (a) o (b).
(a) Date of execution of the affidavit of consent required
by y3301(c) of the Uivorce Code: by plaintiff 12/10/01
by defendant X2/3/01 -
(b)(1) Date of execution of the affidavit required by y3301(d)
of the Divorce Code: _; (?.) Date cf filing and
service of the plaintiff's affidavit upon the respondent:
4. Related claims pending:
5. Complete either (a) or (b).
(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 53301(c) Divorce was
filed with the Prothonotary: ,(~ ~f'Grf~i<"p" ~~_ r~ Bd/
Date defendant's Waiver of Notice in §3301(c) Divorce was
filed with the Prothonotary: _~Ptvl~r~ ~r~ m2 ad/
Attorney f (Plaien~ti-fCP)~~~ p~~~
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GARY R. GRAND, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
VS. CNIL ACTION -LAW
NO. G1- `f=~~4- ~~
JACQUELINE J. GRAND,
Defendant : IN DNORCE
NnTTCF. TO DF.FRNn ANT) CT.ATM RTGHTS
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 maybe 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 Cumberland County Courthouse, Carlisle, Pennsylvania.
1F YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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
(717) 249-3166
Anthony L. DeLuca, Esquire
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
GARY R. GRAND, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
VS.
JACQUELINE J. GRAND,
Defendant
CIVIL ACTION -LAW
NO. o l- `f Ya Y CIVIL
IN DIVORCE
COMPLAINT UNDER SECTION 3301 (c)
OF THE DIVORCE CODE
1.
The Plaintiff is Gary R. Grano, who currently resides at 753 Dogwood Terrace, Boiling
Springs, Cumberland County, Pennsylvania, since March 6, 1992.
2.
The Defendant is Jacqueline J. Grano, who currently resides at 400 E. Randolph Ave., #42,
Mine Hill, New Jersey, since September 1, 2000.
3.
Plaintiff and/or Defendant have been a bona fide resident(s) in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4.
The Plaintiff and Defendant were married on July 11, 1992 in North Saco, Maine
5
There have been no prior actions of divorce or for annulment between the parties.
6.
The marriage is irretrievably broken.
7.
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.
8.
Plaintiff requests the court to enter a decree of divorce.
I verify that the statements made in this Complaint aze tme and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relafing to unswom
falsification to authorities.
Date: ~~ . ~
~-
Gary Grano, Plaintiff
Anthony L. uca, Esquire
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
(717)258-6844
Attorney for Plaintiff
GARY R. GRAND, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY', PENNSYLVANIA
VS.
JACQUELINE J. GRAND,
Defendant
CIVIL ACTION -LAW
NO. 01-4424 CIVIL
IN DIVORCE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says that he
mailed by certified mail, return receipt requested, a true and correct copy of the Complaint in
Divorce under Section 3301 (c) of the Divorce Code to the Defendant at her residence and that
Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A".
Anthony L. uca, Esquire ~"
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
(717)258-6844
Sworn to and sub,s~~nnbed
before me this ~`'i~a`y
of p~ec ~ , 2001. ~ ~
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1`~ ary Public
NOTARIAL SEAL
MARJORfEA. DeLUCA, Notarryy Public
South Middleton Twp., Cumberland Co. 1'
M Commission Ex ires_ Nov. t, 2008 ,~
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^ Complete items 1, 2, and 3. Also complete
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 Address~~eppd to:
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2. Article
PS Rorm 3811, July 19g9
~ry address tlifferent from kem 17 "I--I~Ye;
enter iielivery address below: ^ No
3. Serv Type
Certfietl Mail ^ F~cpress Mail
^ Registered ^ Retmn Receipt for Merchandise ;
^ Insured Mail ^ C.O.D.
4. Restricted Delivery? (Exfre Fee) es
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102595-00-M-0952,
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Domestic Return Receipt
GARY R. GRAND, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION -LAW
JACQUELINE J. GRAND,
Defendant
NO.Ol-4424 CIVIL
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY 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 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 aze true and correct. I understand that false
statements herein aze made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Date: ` 6o e _ f ~ ~ ~/h~-d"'~
Gary R. o, Plaintiff
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GARY R. GRAND, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
VS.
JACQUELINE J. GRAND,
Defendant
CIVIL ACTION -LAW
NO. 01- 4 4 2 4 CIVIL
IN DIVORCE
1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on
July 20, 2001.
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 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 understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom
falsification to authorities.
Date: 2 /e o 1~/ ~ N
Gary R. io
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GARY R. GRAND,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
JACQUELINE J. GRAND,
Defendant
NO.O1-4424
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY 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 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: ~ 3
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GARY R. GRANQ
Plaintiff
VS.
JACQUELINE J. GRAND,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. vr-yy.~y CIVIL
IN DIVORCE
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on
July 20, 2001.
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 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 understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
Date: ~2- 3 OI
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