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HomeMy WebLinkAbout01-04424IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Np, 01-4424 CIVIL ~: DECREE IN DIVORCE ~l 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~~~ ~5 ~o 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. ~ ~ 'l wLe.r`. ~ oC~=4-OC~.e-~~~ 1`~ ary Public NOTARIAL SEAL MARJORfEA. DeLUCA, Notarryy Public South Middleton Twp., Cumberland Co. 1' M Commission Ex ires_ Nov. t, 2008 ,~ c9 is No cc' '~ i ---- '-- rr: _ : t v~ _,_ - ~.i ~ ~_ ~r -~. - _ .. c = ~~ ._ = ~ .. ~S ~~G .i d+ ^ 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: ~, ~/'~, . ~3 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 ~.~(~~ S.. ,. 102595-00-M-0952, ~ / : ~~"~" 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 - -- - __ , .,- :: 5 a d n f 0 v~ a ~~ c; -_ = , ; -_ ^, ~_P _- ~_. C_ r (- - , y;c .-. i c,.~ ~_ - -- .- --~ ._. _ _ ias,e_ _ ._ ~~~"s+ ~. .. ewnN~f; acs ,~ seen ~~~., r~Ta._, .. 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 Q C~ n n ,J O (^ ~- G. _... '-? ` C:: i R Ci:i" ~i'i .-. ,- ~~ ~Q 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 ~v n t ,~ `rC ~``~ `a f`i L_. ^r r (--~_ ~~ _ x ~ _J -_ ~ (+ - . ... '~: . agp.«s~~i ~xs a nsssw r ~* o-.~.-sz~,?s~ ranwn'~fi#5-:rya ~,var~?fiR , 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 a c~~ --, - ~ - ..~ ~ ~, _~ d ri r~`. '; -_ - ,,. _ _ ~_ '~" ..y - -~ f~ i ~~ ~~ fo ~~,. syaws,,wu-e+~ea ,;:_x ^~ 4=:~w~~ti,Mdst~,wa,F0.3=xia~~~~Y~394~;a?", a