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HomeMy WebLinkAbout99-04565 •:..• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF $ WtPENNA. i i i i .LORL.P.._GREEN,_ Plaintiff ?tt..99.-..4565.... 19 99 ............ Versus PAUL. J. GREEN, ... ...... ......... Defendant DECREE IN DIVORCE AND NOW . ............. egrfh!.... j!!... 1-91 ....... it is ordered and decreed that .....Lori P. Green plaintiff, and ..... Paul„J.. Green ..................................... . defendant, are divorced from the bonds of matrimony. J The court retains jurisdiction of the following claims which have e been raised of record in this action for which a final order has not yet A, been entered; • ? - N ys+? %,I ............................ By Th Court F A v Attest: J. Prothonotary >!J( • r_._._._.___._.,._.... _.. .. _ ?i. ter., rw. IN. mow. • CV? -W.- ;W.• `W• • ?:• :? • •;e:• W, :*% M. <e• •a; •v:• :e:• •:?:• te: •:e:• •;e • `.:e; to •a:• s . . . R i is i 0 i i i i i ?o?/ oD ? icta? 7° ?cWr LORI P. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PAUL J. GREEN, NO. 99-4565 CIVIL TERM Defendant IN DIVORCE To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Service of the reinstated Divorce Complaint was made on July 30, 2000, by personal service. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: by Defendant: (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: Execution: 3/13/00 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filing: 3/14/00 Service: 7/20/00 4. Related claims pending: none 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: July 30, 2000, by personal service (b) Date of plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: N/A Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: N/A ?. Br if squire GRIPF SSOCIATES Attorney for Plaintiff ?; CV •1/ LI c L? ? U LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW PAUL J. GREEN, NO. 45cp5CIVIL 1999 Defendant : IN DIVORCE NOTICF TO DFF ND 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. CIVIL 1999 PAUL J. GREEN, Defendant IN DIVORCE I. Plaintiff is Lori P. Green, an adult individual currently residing at 142 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Paul J. Green, an adult individual whose current residential address is unknown but who is believed to be present in Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 16, 1997, in Newville, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Goddard nsen, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: 7- ? 3- cl'7 C` (?u_. //) 2"" LORI P. GREEN, Plaintiff !• .................................. LAINT EIN4T TED ... < ...a.... N...... ..3 .................... PROTHONOTARY 1Meh.....13.?'........ aax, COMPLAINT REINST? ED .................... PROTHONOTARY "'CpMp INT REINSTAT Y.....:.. ....... ...r•. PROTHONOTARX ' O N ri LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW PAUL J. GREEN, NO. 4565 CIVIL 1999 Defendant IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this Lg day of ' ef* ''t berl999, comes Kristen Goddard Donsen, V Esquire, attorney for Plaintiff, Lori P. Green, and states that the Defendant, Paul J. Green, was served with a true and attested copy of the Complaint in Divorce by certified mail, restricted delivery on September 24, 1999. Respectfully submitted, GRIFFIE & ASSOCIATES t? ? ?I t I ? _ Kristen GoddhAbonsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 Sworn and subscribed to this '281 day of ral; ter , 1991. 121a? Notary Public I Notarial Sent Kansa J. LaMwn, Notary Pudic rarl'd0 noro, CumL ".and Coumy My commission Expires Aug. 25, 2005 V m e S cn cn fi a P 433 109 360 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mall fSee reverse) S "40 C1 Y Sl 6 Number n. a =33 st ce, Stet ZIP Cod e Z 2 1 T postage 55 m 9-0 Certified Fee I AO :r- C/) Special Dewery Fee C/7 G Flandded Delivery Fee 1 S C D Fallen Rao M I, Defivemd Whm `r' ibesn re ' .. 2S ' Dare, s Addeet?. . , Tor L'P mge3Fees Qq? ,$ i {V PoslmpR;w?lale eM1 S 4 •COmptels aan 1 WW*`z W addltlorN services. L2. wish to receive the the •CM,gata ? s, p, ?,b. g aervkea (for a •PpM you, ms aM gd ms on tlM rowna of ads form so sun we esn rMUm aMwtlrardmltNSiamtoaNaonofftmslIpI w.or an Vwbbadspmdmnol p?rese6e'S Addreee g •w haft n awwaRoquee 0•m an Malplua below M. ankr twnfb.r. .Re?tllcted DeI •The Rasum Receipt w Addpostmaster for lee. lN show to whom ar snide M delivered and the data rY delivered. . pa ? 5 C reetn 1 LA) S? Slvne Ind. ?}iwtovc) M ZIZZ I, .2 X rS.R eefved By. (P n ??enre) t3. ig r or Agent) PS Form 3811D 19 .4 ? Registered --a ? Express Mall p Irns;u ? RetureReceipilorrtlla m ? COD 7. Date of De Y !. Addfeals Address(Ontyffnequestger B1W lee is paid) 102595.91.8-01]9 ,: e _ v: - U :;? U LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PAUL J. GREEN, NO. 99-4565 CIVIL TERM Defendant : IN DIVORCE If you wish to deny any of the statements set forth in the attached affidavit, you must file a counter-affidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. 1. The parties to this action separated in March 1998 and have continued to live separate and apart since that time. 2. The marriage is irretrievable broken. 3. 1 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 the foregoing document 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 unswom falsifications to authorities. DATE: -3 - / 3 - O 0 ?SGk_ P ?(J Ll ent LORI P. GREEN, Plaintiff } W l C Cam: [.. ?' to rcz t x U3 Cl- J O U LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PAUL J. GREEN, : NO. 99 - 4565 CIVIL TERM Defendant : IN DIVORCE 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was tiled on July 28, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed since the Complaint was filed on July 28, 1999, and served on September 24, 1999. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decrees. I VERITY THAT THE STATEMENTS MADE IN THE FOREGOING 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: % of - 8 5 % x/16- L / LORI P. GREEN, Plaintiff L? .1 '. (1 : 1: ? ?? .__ '.1 i ?_, i LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PAUL J. GREEN, : NO. 99 - 4565 CIVIL TERM Defendant : IN DIVORCE I consent to the entry of a final decree in divorce without notice. 2. 1 understand that I may lose rights concerning alim^ny, 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 divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: /a- a 8 - `j 9 r?atc ? .C1.1 U_e-rte. LORI P. GREEN, Plaintiff ti ? _,: -. r= - „_,?_ _ 07-31-2000 09:43AM FROM GRIFFIE 8 ASSOCIATES TO 14107831248 P.02 LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW PAUL J. GREEN, : NO. 99-4565 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I confirm that I did this day of ? j l/ 17 2000, hand deliver a certified and true copy of a reinstated Complaint in Divorce, Affidavit Under Section 3301(d) of the Divorce Code, Counter-Affidavit Under Section 3301(d) of the Divorce Code, and Notice of Intention to Request Entry of Divorce Decree to the i i Sworn and subscribed to before me this 30th day of July 2000. g. Ua-'4 &':? .? tary Public MY :Commission Expires 08/22/01. Z4 ?f Ca Sich, III TOTAL P.02 v LORI P. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW : N0: 451,5 CIVIL 1999 PAUL J. GREEN, Defendant : IN DIVORCE NOTICE TO DEFEND . ND CLAIM T HT 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 will proceed without you and a decree of divorce or annulment may be entered against you for any claim or relief requested in these papers by the Plaintiff. You may iose 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, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 in 1 `arG _rtto sat tSy nano inu l+t°_ ;w2i C' :Zie (,'*,"4.;.-z al canis.;e, Pa. D:15 2840 ijy ., \.?j .1: 10 Prothonotary LORI P. GREEN, : N THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW : NO: CIV1I, 1999 PAUL J. GREEN, Defendant N DNORCE CONIPL.AiNT IN DNOR F NO FAULT 1. Plaintiff is Lori P. Green, an adult individual currently residing at 142 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Paul J. Green, an adult individual whose current residential address is unknown but who is believed to be present in Cumberland County, Pennsylvania. 3. Plaintiff is a bonafrde resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 16, 1997, in Newville, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Kasten Goddard en, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. DATE: LORI P. GREEN, Plaintiff 0 z i Q 0 d i? 4E i p ?. Q N a C. LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNtSy Te V. c CM CIVIL ACTION - LAW T } Z PAUL J. GREEN, i L -- ; : NO. 99-4565 CIVIL TERM Defendant : IN DIVORCE " L`1C.i.LlrcE ti If you wish to deny any of the statements set forth in the attached affidavit, you must file a counter-affidavit within twenty days after this Affidavit has been served on you-or the -- statements will be admitted -- - - ':.lr1 J Uf .. AFFIDAVIT UNDER § 3301(d) OF THE DIVORCE CODE is L The parties to this action separated in March 1998 and have continued to live separate:: and apart since that time. 2. 3. The marriage is irretrievable broken. I understand that I may lose rights concerting 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 the foregoing document 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 unswom falsifications to authorities. DATE: 3-t 3- O G LORI P, GREEN, Plaintiff q. i SEt;:r' il8ttt7 --jay oiaia:lcli. _ t r Prothonot M LORI P. GREEN, Plaintiff vs. PAUL J. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-4565 CIVIL TERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 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 and 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 understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth in the Notice of Intention to Request Divorce Decree, the Divorce Decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relative to unswom falsification to authorities. DATE: PAUL J. GREEN, 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 COUNTER-AFFIDAVIT. LORI P. GREEN, Plaintiff vs. PAUL J. GREEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 994565 CIVIL TERM IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: PAUL J. GREEN, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or before August 21, 2000, 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 answer with your signature notarized or verified or a counter-affidavit 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. The filing of the form Counter-Affidavit alone does not protect your economic claims. A COUNTER-AFFIDAVIT 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 L1J ?? C 7 m c, .J zu? .- ? -nom `. CO C7 U LORI P. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 4565 CIVIL 1999 PAUL J. GREEN, Defendant : IN DIVORCE I confirm that I did this 04day of 2000, hand deliver a certified and true copy of a Complaint in Div ce and related Notice to Defend and Claim Rights, Affidavit Under §3301(d) of the Divorce Code, and Counter Affidavit Under §3301(d) upon Defendant, Paul J. Green, at u Sheriff of Baltimore County 401 Bosley Avenue Towson, MD 21204 Sworn and subscribed to before me this Z'/ r day of - / 2000. NOTARY PUBLIC C4L'PY- /60s T ?.rn": o!. .iS l?F -TA npl tiC)TT? F. TO PFFF M a- >D ti AfN1 R.[r-RTS r,. ,+ ,nairct the claims Sei `orth in the t111 t0 QO 4O. the otir,.v.n? ongr . rr,u ??st _ gainst r ^.rm:lment may "e ntered a ? x:150 'M,II 7L0!'pr L( Plth ri It vn„ ,n I - - 1, F "?nue$r21 ? '??• i r?Y; '' .h,g n!altttl? "'?- may lose money or you `or ?7r4DPrI? Or )ME. ,?.}lti Imor?f ail! r •r i 7fiC 1?..Q C'let ,r'v 1f l(lm of JOTS Children. cr,' '.h, .. r.r!i'*jat'v,; ;* ...• ?0.rn}1t0 nreakdown 02 he .•7 it i? ;?aT ane ;?Ur5el0!5 !5 available in ma, .'tor !s' _ - Cumberland p? flc P'Otnr,n,ntaY'/ i[ the C)_t r.- Counrl, Pcr, , i. nr.r<I. IF y?1T' DO \,O, F'L A rp -LD/V)"^ ;R Si?\ jF O ?T r1 ?_S 3-rORc ?N?! OF PROPER"Cy, LAN!'fcR'? r -JC ?IrIy (H P4 'i o T jti?c. IF iGU DO S. l1. y()[1 prltf(D t_A''.E r,r ;r) OR T-Lcam VOi E(PVE A LA'?'!'rtP.': R = ,PI GF LLGAL ELP. If IIFF(rr-`F f !r!p([!R?I!iJ, li i':ii._ .F! '?r r?.,,„ti•••t2m.l':??ut:r,i F3v \,;nrs?riun t.. Lic. ? "rl'h vl?.acia I'tl_ rrills <p(; -. rag jt; t - • ` Mthnr.ctary i LORI P. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. 4.5 CIVIL 1999 PAUL J. GREEN, Defendant IN DIVORCE 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 cast will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Est of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 Iltly. ???i q?•j t.l.'h r t? °?othonctary LORI P. GREEN, N THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NO. CIVIL 1999 PAUL J. GREEN, Defendant N DIVORCE COMPLAINT IN DIVOR . . NO FA(a.T 1. Plaintiff is Lori P. Green, an adult individual currently residing at 142 North Middlesex Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Paul J. Green, an adult individual whose current residential address is unknown but who is believed to be present in Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 16, 1997, in Newville, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Goddard en, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. DATE: _7' a 3 - IF 9 c't P LORI P. GREEN, Plaintiff LORI P. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW n co C. O T • 1T = H PAUL J. GREEN, NO. 994565 CIVIL TERM z - a ; Defendant IN DIVORCE - '? Vie, r J \Li O T NOTICES o SC r O If you wish to deny any of the statements set forth in the attached affidavit, j?u miast & a counter-affidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. The parties to this action separated in March 1998 and have continued to live separate and apart since that time. 2. The marriage is irretrievable 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 the foregoing document 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 unworn falsifications to authorities. n c i rlti l Lk tom'`' DATE: 3-13-00 LORI P. GREEN, Plaintiff TRUE COPY FROM REOORD in Testimony a;nereoi, I hem unto set rtrf hang .i,, 1 the w! of said Coen at Carlisle, Pa This r`r day gj(PaAsh , r Prothonotary LORI P. GREEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW PAUL J. GREEN, NO. 994565 CIVIL TERM Defendant : IN DIVORCE 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. (Check either (i), (ii), or both) (i) The patties to the action have not lived separate an apart for a period of at least two (2) 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. 1 understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth in the notice of intention to request divorce decree, the divorce decree may be entered without further delay. I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: PAUL J. GREEN, Defendant 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 SHOULD NOT FILE THIS COUNTER AFFIDAVIT. r ?i c r= N r 7 ? 7 cA o U LORI P. GREEN, Plaintiff vs. PAUL ?. GREEN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 4565 CIVIL 1999 IN DIVORCE PRA ECI PE Please reinstate the Complaint in Divorce filed in the above captioned action. DATE: ;?/t OO e<? Brgdley ri Esquire Attorn y for antiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ! :? CC l n' -' _) LORI P. GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL]. GREEN, Defendant TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 99-4565 CIVIL TERM IN DIVORCE Please reinstate the Complaint in Divorce filed in the above-captioned matter on behalf of the Plaintiff, Lori P. Green. Date: 3 g 0O Respectfully submitted, 4ttomey 1 fie, Esquire for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 r. R s ? A_ 1 ?!j CID LORI P. GREEN, Plaintiff V. PAUL J. GREEN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 4565 CIVIL 1999 IN DIVORCE Please reinstate the Complaint in Divorce tiled in the above captioned action. Respectfully submitted, Date: `! (j v or Plaintiff FIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 <, 1 Q," QJ ? i ? ' S;! 0 0° ?4?