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Home My WebLink About01-04721JUDITH A. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA v. :: NO. ~~_~f7=2~ CIVIL TERM GERALD A. GRYZMSKI .. 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 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 the CUMBERLAND COUNTY COURTHOUSE, CARLISLE. PENNSYLVANIA, 17013 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 ~~~~.~~ rances H. Del Duca 10 West High St. Carlisle, PA 17013 Dated: ~~~/~ ~' JUDITH A. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA v. :: NO. D/_y7a~ CIVIL TERM GERALD A. GRYZMSKI .. IN DIVORCE COMPLAINT UNDER SECTION 3301(Cl OF THE DIVORCE CODE COUNT I -DIVORCE 1. Plaintiff is Judith A. Gryzmski, who resides at 1513 Hemlock Avenue, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Gerald A. Gryzmski, who resides on East South Street, Carlisle, Cumberland County, Pennsylvania, 17013, with a mailing address of P.O. Box 1354, Carlisle, Pennsylvania, 17013. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married May 22, 1965 in Nanticoke, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. COUNT II -EQUITABLE DISTRIBUTION 7. Plaintiff and defendant are the joint owners as tenants by the entireties of real estate and various items of personal property, furniture and household furnishings acquired during the marriage which are subject to equitable distribution by this Court. COUNT III -ALIMONY, ALIMONY PENDENTE LITE 8. Plaintiff does not have sufficient funds to support herself. COUNT IV -COUNSEL FEES AND COSTS 9. Plaintiff does not have sufficient funds to pay counsel fees and expenses incidental to this action. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree: A. Dissolving the marriage between plaintiff and defendant; B. Equitably distributing all property owned by the parties hereto; C. Directing defendant to pay alimony, alimony pendente liter and D. Directing defendant to pay counsel fees and expenses of this proceeding. ~ ~~ Frances H. Del Duca Dated: ~ ~-D/ Attorney for Plaintiff ,.~_ . . 1 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 10 Pa.C.5. Sec. 4904 relating to unsworn falsification to authorities. Dated: ~ ~-Q~ ~~ /! .~.Pii dith A. Gryzmsk~~ ~ ~ ® ~ 0 ~~ ~~ ~ n ~ ~~ ~-~ ~~ 'il ~= ~ ,, `~ ~' ~ rnrr~ ~ z ~-~ ~ ;, rr o~- i ..n , ;7 ~t~ i -"~° , :~; Z_ ~ ~,~ ~y i7 i~rn -b ~~ :..w -; ~'~ .~ -• :,:..-r+ .r.. sew r-:~=sr ~a a .cune~., D Wr3/ NDITH A. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA v. :: NO. 01-4721 CIVIL TERM GERALD A. GRYZMSKI .. IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ~ day of August, 2001, I hereby acknowledge receiving a copy of the Complaint in Divorce filed to the above term and nurnber at the office of Richard P. Wagner, Esquire, 2233 North Front Street, Harrisburg, PA, 17110. SUBSCRIBED and sworn to before me this ~"d'ay of August, 2001. ` ~. Notary Public Emily q, ~~ rys~ arrisb otary Public MY ~anmissim~i' Dauphin Coumy ExP6es May 19, 2003 /~ ~ Gerald A. zmski c7 c - ~• n ,-. n-,: , -- :c- .. .~ ` 4~: 1'i`: C , !';= ~ _; C__, :. C.~ ~', f _ srt.a~o-~x as .® _:.. ... alF"~Y. ~.e ~tn:~s~ ai<N'W:as4Fk"h'f~a~' 1"~ r~ V`t3ir*~1 . JUDITH A. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA v. :: NO. 01-4721 CIVIL TERM GERALD ~. GRYZMSKI .. IN DIVORCE INVENTORY OF JUDITH A. GRYZMSHI Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was cc,~ixmienced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.5. Sec. 4904 relating to unsworn falsification to authorities. ~ Judith A. Gryzmsk'` MARITAL PROPERTY Real Estate 1513 Hemlock Avenue, Carlisle, PA 2. Pensions/Insurance Pennsylvania State Retirement System (Husband) -monthly gross Life Insurance -Provident Mutual Life -monthly premium $339.15 IRA - Orrstown (Wife) (total amount) 3. Vehicles 1995 BMW -wife 1996 Monte Carlo 4. Bank Accounts On•stown Bank -Joint "tax account" Joint Savings Cornerstone Federal Credit Union -Wife #5141 Husband #5548 Mellon Bank -192-422-2225 -Joint Checking Mellon stock (Wife) - 205-102-58551A10 - 52 shares 5. Household Furnishines and Personal Living Room Pearson traditional sofa/love seat Queen Anne chair Howard Miller floor clock $ 100,000.00 3,211.70 3,321.59 ~,. Thomasville oval coffee table, drop leaftable, commode table 2 Stiffel lamps Bombay table and lamp Secretary by Wells w/State Police memorabilia 1 oil painting 2 Baldwin brass sconces/4 Baldwin candle sticks 2 antique dishes Custom draperies Wall arrangement above fireplace Kitchen TV Toaster Coffee pot Breadbox Radio Dishes Pots Pans Cookie sheets Antique dishes Dining Area Dining room table, chairs, hutch w/china, crystal Antique smokestand/washstand Antique dishes on hutch Doiles made by grandmother Bedroom French Provincial chest of drawers Dresser w/mirror Commode table Nightstand Brass queen bed Queen Ann chair 3 lamps Television Den TV VCR Bombay television/VCR table Antique rocker Table 2 lamps 2 recliners Wall clock Pictures Dried arrangement Bedroom Desk and hutch Lamp Hall Table and minor Bombay Pictures ~ 5 Wreath ' Basement Washer and dryer 2 recliners 2 lamps Triple Dresser 6. Furnishings and nersonalty - In possession of husband from basement sitting room Sleeper sofa End table TV and stand Floor lamp Table and chairs Towels Dishes Silverware (his mother's) Dish towels Odds and ends Computer 7. Non-Marital Bedroom suite (bed, dresser, cedar chest, chest of drawers) Inheritance from Mother LIABILITIES 7.(a) Real Estate As of 5/20/03 credit line at Mellon 19,000.00 Instalhnent Sale 15,000.00 (b) Personal Bon Ton -joint Sears -joint Car insurance State Credit Card/PSECU PSECU loan VISA Capital One Fleet Bank (husband) Citibank (husband) Verizon (husband) 1,000.00 Pd. 220.00 Pd. 251.00 (3 mos.) 5,162.92 Husband as of 5/03 -1,800.00 as of 1/22/03 - 2,238. 1,212.00 Pd. Summer 2002 3,384.00 Wife as of 5/03 - 1,800. 8,467.00 2,500.00 309.00 The above joint liabilities were being paid by Wife from deposits in joint account from Husband's State pension. The monthly deposit is $2,845. MONTHLY 552.00 (21oans) (150.00 per month) (50.00 ) 150.00 " " (60.00 " ) :,.~ r ~ JUDITH A. GRZYMSHI LIVING EXPENSES AS OF MAY 2003 MONTHLY YEARLY Mortgage Loans 267.65 3,211.80 248.00 2,976.00 Pool 33.75 405.00 Awnings 4.00 48.00 Yard (flowers) 12.50 150.00 Furnace maintenance 12.50 150.00 Taxes 44.46- 533.52 100.40 1,204.80 Insurance 23.50 282.00 Propane 5.30 63.60 Phone 56.50 678.00 PP&L 67.00 804.00 Oil 51.09 613.00 Water & Sewer 26.33 315.96 Cable TV 42.00 504.00 Papers 25.00 300.00 Auto Insurance 64.75 777.00 Life Insurance 339.15 4,069.80 Car maintenance 29.16 350.00 Gas/Lunch 60.00 720.00 Medical 20.84 250.00 38.08 457.00 Prescriptions 8.33 100.00 Counseling 60.00 720.00 Clothing 208.00 2,496.00 Food 250.00 3,000.00 Haircut 50.00 600.00 Credit cards 300.00 3,600.00 Vacation 66.67 800.00 Health Club 20.83 250.00 Dog - Vet/Groom 45.00 540.00 Totals 2,580.79 30,969.48 JUDITH A. GRYZMSKI v. GERALD A. GRYZMSKI Gerald Gryzmski - W-2 :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-4721 CIVIL TERM .. IN DIVORCE INCOME REPORTED FOR 2002 H & R Block Carlisle Hospitality LP State Employees Retirement System Judy Gryzmski - W-2 Waypoint Bank YEARLY 13,443.05 16,190.95 38,723.00 17,664.06 ,,~» .,. G .~ Z7_ m -: ~ r: CS ~ C: ~ ~7rn - - i ~ JO -C' CD -G ~~ ~'v ,:. _. - .., sax ^n`°Ti r: ~~ ~'"~~'iVSwM&53