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HomeMy WebLinkAbout99-04655R a ;< V L V AC ) 11 a:. yr l.3N P e?M Ae?. 4 4 a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF LL PENNA. it!ny? k ROBIN A. GRAY, i Plaintiff !I NO VERSUS ROBERT C. GRAY, Defendant DECREE IN DIVORCE 99-4655 CIVIL TERM AND NOW, 2000 IT IS ORDERED AND DECREED THAT ROBIN A GRAY , PLAINTIFF, AND ROBERT C. GRAYDEFENDANT, 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; BY ATTEST: OTHONOTARY .. ? ???? ROBIN A. GRAY, 1 IN THE COURT OF COMMON Plaintiff 1 PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA VS. 1 1 CIVIL ACTION - LAW ROBERT C. GRAY, I NO. 99-4655 CIVIL TERM Defendant ) 1 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: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Acceotance of Servi indicating sery4gg on 1August 1999 noon D f ndant'c rennsel. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: N/A NZA by Defendant: (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: 22 September 2000 (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 27 September 2000 upon Defendant's counsel of record (Affidavit of Service filed). 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: 25 October 2000 (Affidavit of Service filed contemporaneously herewith). (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: N/A Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: N/A Date: 20 AL,. ZWo By Samuel . Andes Attorney for Plaintiff '- , n r ?,. ,': -? .L a L -s-, 0 t-I 0 _U M L s 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBIN A. GRAY, Plaintiff V. NO. 99 _ '7?aSS Ul ?'1 ROBERT C. GRAY, Defendant 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 Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 NO HAVE A OF ICE SET d T COPY FI In Testimo kOereaf, I and the seat o A C This__day _ LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue unto set my hand at Carlisle, Pa. 19 Carlisle, PA 17013 (717) 249-3166 NCTICIA Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado qua si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion do demanda. Usted puede perder dinero o sus propiedades o otros derechos importanates para usted. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disable individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBIN A. GRAY, Plaintiff V ROBERT C. GRAY, Defendant NO. 99. /&S y- C,„d --7?N«- IN DIVORCE AND NOW comes the Plaintiff, ROBIN A. GRAY, by and through her attorney, Maryann Murphy, Esquire, and respectfully avers as follows: 1. Plaintiff is ROBIN A. GRAY who currently resides at 105 East Allen Street, Apartment #114, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is ROBERT C. GRAY who currently resides at 380 Mt. Prospect Avenue, Apartment #14 A, Newark, New Jersey. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 7, 1996 in Dauphin County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. Defendant is not a member of the Armed Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such 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. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. 10. Plaintiff hereby incorporates by reference all the averments contained in Paragraphs 1-9 herein. 11. Plaintiff does not have sufficient funds to pay the counsel fees, costs and expenses incidental to this action. 12. Defendant is well able to pay Plaintiff's counsel fees, costs and expenses incidental to this matter. 13. Plaintiff requests this Court to grant her counsel fees, costs and expenses incidental to this action. COUNT III CLAIM FOR EMU g"LF DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 14. Plaintiff hereby incorporates by reference all of the averments contained in Paragraphs 1-13 herein. 15. Plaintiff and Defendant are the owners of motor vehicles, bank accounts, retirement benefits, and personal property acquired during the marriage which is subject to equitable distribution by this Court. 16. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 17. Plaintiff requests this Court to equitably distribute the parties' marital property. COUN'T' IV CLAIN FOR LINONY UNDER SECTION 3701 OF TEE DIVORCE COQF 18. Plaintiff hereby incorporates by reference all of the averments contained in Paragraphs 1-17 herein. 19. Plaintiff does not have a sufficient source of income or earning capacity at the present time to maintain the standard of living enjoyed by the parties during their marriage. 20. Defendant does have a sufficient source of income and earning capacity to aid Plaintiff in maintaining the standard of living enjoyed by the parties during their marriage. 21. Plaintiff requests this Court to grant her alimony. COUNT V CLAIM FOR ALIMONY PENDENT, LITE UNDER SECTION 3702 OF THE DIVORCE COD 22. Plaintiff hereby incorporates by reference all of the averments contained in Paragraphs 1-21 herein. 23. Plaintiff does not have sufficient funds to support herself during the pendency of this action. 24. Defendant is well able to pay support to Plaintiff. 25. Plaintiff requests this Court to grant her alimony pendente lite. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; and b. equitably distributing all property owned by the parties hereto; and c. directing Defendant to pay Plaintiff's counsel fees, costs and expenses incidental to this action; and d. granting alimony to Plaintiff; and e. directing Defendant to pay alimony pendente lite to Plaintiff; and f. for such further relief as the court may determine to be equitable and just. Respectfully submitted, 1A III I AA!Ai V Maryan Murphy, Esqu're Attorney for Plaintiff 845 Sir Thomas Court Suite 11 A Harrisburg, PA 17109 (717) 540-8600 Supreme Court I.D. # 61900 I verify that the statements made in this Complaint Under Section 3301(c) of the Divorce Code 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: 7 3 ?` 9 OBIN GRAY Sworn and subscribed before me this day of l , 1999. . 'tTjC? layl N ary Public NOTARIAL SEAL 9ATHM E A. NORWAK, Wwy Public IMM Poomn Twp., LbYPIio Cauery, PA Nq Off" bp6m W. 2, 2002 CERTIFICATE OF SMMI I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Complaint Under Section 3301(c) of the Divorce Code was mailed by first class U.S. mail, postage pre-paid, certified/restricted delivery, addressed as follows: Robert C. Gray 380 Mt. Prospect Avenue Apartment #14 A Newark, New Jersey 07104 Date: ROBIN A. GRAY, I IN THE COURT OF COMMON Plaintiff 1 PLEAS OF CUMBERLAND 1 COUNTY, PENNSYLVANIA 1 VS. 1 CIVIL ACTION - LAW 1 ROBERT C. GRAY, 1 NO. 99-4655 CIVIL TERM Defendant 1 IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT !Y-=.1.(D) OF THE DIVORCE CODE 1. Check e' er (a) or Ibl: (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 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. I verify that the statements made in this Counter-Affidavit are true and correct. I that false statements herein are made subject to the penalties of 18 Pa. C.S. on 4904 relating to unsworn falsification to authorities CJ ROBE C. GRAY NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO OT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS 0UNTER-AFFIDAVIT. l\ 1 I e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - LAW ROBIN A GRAY, Plaintiff : No. 99-4655 Civil Term V. ROBERT C. GRAY, : IN DIVORCE Defendant AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on August 13, 1999, I sent a true and correct copy of the Complaint In Divorce under Section 3301(c) of the Divorce Code to counsel for the Defendant, Elizabeth Stone, Esquire, by first class U.S. mail, postage pre-paid to the following address: Elizabeth Stone, Esquire 414 Bridge Street New Cumberland, PA 17070 3. That on August 16, 1999, counsel for the Defendant personally accepted service of this Complaint in Divorce on behalf of the Defendant. The Acceptance of Service is attached to this Affidavit. Respectfully submitted: Maryam Murphy, Esquire I P.O. Box 716 Mechanicsburg, PA 17055 (717) 737-8567 I.D. 4 61900 C ],j L, ?jLLJ cj ? j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBIN A. GRAY, Plaintiff V. ROBERT C. GRAY, Defendant I accept service of the Complaint in Divorce for the above matter on behalf of Robert C. Gray, and certify that I am authorized to do so. '8- le -51 Date NO. 99-4655 CIVIL TERM IN DIVORCE C?j L... f V> tl. `? p o c? >- ' ,__ „ ? ;; .? , ?,, =; ? ,,; _.. ': i ?_? ,, :? a F ? (fj W Q ? 6 ;G a '" z 6 `? ` ? ? .?i J % %? >. W N 0 Q F P 0. }' H O W ,? ? z ti N ? n ? a ROBIN A. GRAY, 1 IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA 1 vs. 1 CIVIL ACTION - LAW 1 1 NO. 99-4655 CIVIL TERM ROBERT C. GRAY, 1 Defendant ) IN DIVORCE AMY HARKINS, being duly sworn according to law, deposes and says as follows: 1. That she is an employee of Samuel L. Andes, attorney for the Plaintiff herein. 2. That on 26 September 2000, she delivered to the U.S. Postal Service in Lemoyne, Pennsylvania, as certified mail (Receipt No. 7099 3400 0006 0356 2967), return receipt equested, addressed to the Defendant's counsel of record herein, a true and correct copy of 11aintiff's Affidavit Under Section 3301(d) of the Divorce Code together with a copy of a :ounter-Affidavit. 3. Said return receipt card is attached hereto as Exhibit A showing a date of delivery the Defendant's counsel of 27 September 2000. Amy Har ns Sworn to and subscribed before me this 254A day of OCTb8e-2 2000. Public v SENDER: w O Complete Hems 1 .14,121or additional semces. q Complete Items 3.4a, and ab. O O Pont your name and address on the reverse at this torn so that we on return this card to you. O AOedt this form to the from of the malpiece, or on the back if space does not y peril. O Write 'Return Ramer Requested' on the mailpieca below the elide number. O t O The Return Receipt Ma show to whom the elide was delivered and the dale O L delivered. I also wish to receive the follow. ! Ing services (for an extra fee): 7. D Addressee's Address 2. D Restricted Delivery 151i?.-ZP-4 S?oNe EsL. 0 .4 3YOO 0006 0356 , 4b. Service Type 41Y Qf1?9G S a eJr 0 Registered XCertified 6 p D Express Mail D insured New Ca.vtG1I[vs`dL P14 a 17o70 D Return Receipt for Merchandise DCOD 1994 102595 99-e-0223 O i u A. i - 5. `y o. T, Id C Lm' F ? ROBIN A. GRAY, 1 IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND 1 COUNTY, PENNSYLVANIA 1 vs. 1 CIVIL ACTION - LAW 1 ROBERT C. GRAY, ) NO. 99-4655 CIVIL TERM Defendant 1 IN DIVORCE If you wish to deny any of the statements set forth in this affidavit, you must file a 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 on or about 31 July 1997 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, awyer'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 false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: dJ J ROBIN A. GRAY ' ROBIN A. GRAY, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND 1 COUNTY, PENNSYLVANIA 1 VS. 1 CIVIL ACTION - LAW ROBERT C. GRAY, ) 1 NO. 99-4655 CIVIL TERM Defendant ) IN DIVORCE DEFENDANT' O LATER AFFIDAVIT SINDER SECTION-23391(p) 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 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. I verify that the statements made in this Counter-Affidavit are true and correct. I nderstand that false statements herein are made subject to the penalties of IS Pa. C.S. ection 4904 relating to unsworn falsification to authorities. Date: ROBERT C. GRAY 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. n 7 O N ? W ? 6 Q a n i ? ? = r?7 a ,. ? o a r ? m 6 p s F 0. ? 6 y CI 0 ?: 4 G .i •. ? o ? ROBIN A. GRAY, Plaintiff Vs. ROBERT C. GRAY, Defendant 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA 1 1 CIVIL. ACTION - LAW 1 1 NO. 99-4655 CIVIL TERM 1 IN DIVORCE AFFIDAVIT OF SERVICE SAMUEL L. ANDES, being duly sworn according to law, deposes and says as follows: 1. That he is the attorney for the Plaintiff herein. 2. That on 25 October 2000, he caused to be delivered to the U.S. Postal Service in Lemoyne, Pennsylvania, first-class postage prepaid, a true and correct copy of Plaintiff's Notice of Intention to Request Entry of Divorce Decree together with a copy of a Counter-Affidavit addressed the Defendant's counsel of record herein, and to the Defendant himself, as follows: Elizabeth Stone, Esquire Robert C. Gray 414 Bridge Street 1435 Hillcrest Court, Apt. 112 New Cumberland, PA 17070 Camp Hill, PA 17011 3. The communication sent to Ms. Stone and Mr. Gray were not returned by the Post Office are presumed to have been delivered to them. 4. Attached hereto is a copy of the letter and documents served upon Ms. Stone and Mr in this fashion. Sam . Andes orn to and subscribed ore me this $4't day Nouem&EQ , 2000. r NOTARIAL SEAL . Public LYNN ENRENFEIA NOTARY M. lEMOYNE BORO. w,,R n8 CO. MY COMMISSION EMPIRES AUG. 11 SAMUEL L. ANbrs ATTORNEY AT LAW 525 NORTH TWETYTR STREET Y.O. BOX IOU LEMOYYL, PENNSYLVANIA 17043 25 October 2000 Elizabeth Stone, Esquire 414 Bridge Street New Cumberland, PA 17070 Mr. Robert Gray 1435 Hillcrest Court, Apt. 112 Camp Hill, PA 17011 Dear Ms. Stone and Mr. Gray: TE PHONL (1») 1W-5551 PAX (911) 151.1435 Enclosed is a Notice and Counter-Affidavit which I am required to serve upon you in the divorce action filed against Mr. Gray by his wife, Robin A. Gray, back in 1999. It is our intention to conclude the divorce within the next thirty days. Please contact my office if you have any questions. Sincerely, Samuel L. Andes le Enclosure cc: Mrs. Robin Gray F, ROBIN A. GRAY, 1 IN THE COURT OF COMMON Plaintiff I PLEAS OF CUMBERLAND COUNTY, I PENNSYLVANIA I VS. I CIVIL ACTION - LAW 1 ROBERT C. GRAY, I NO. 99-4655 CIVIL TERM 1 Defendant I IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY na DIVORCE n n TO: Elizabeth Stone, Esquire and Robert C. Gray 414 Bridge Street 1435 Hillcrest Court, Apt. 112 New Cumberland, PA 17070 Camp Hill, PA 17011 ATTORNEY FOR DEFENDANT DEFENDANT You have been sued in an action for divorce. You have been served with Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code and a Counter-Affidavit. Therefore, on or after 10 November 2000, the undersigned will file with the Court the attached Praecipe to Transmit the Record requesting that a final decree in divorce be entered. 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. You may lose rights concerning alimony, division of property, lawyer's fees or expenses if you do not claim them before a divorce is granted. 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 LEGAL HELP. COURT ADMINISTRATOR'S OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 TELEPHONE (717) 240-6200 Samuel-L. Andes Attorney for Plaintiff ROBIN A. GRAY, I IN THE COURT OF COMMON Plaintiff I PLEAS OF CUMBERLAND 1 COUNTY, PENNSYLVANIA I VS. I CIVIL ACTION - LAW I ROBERT C. GRAY, I NO. 99-4655 CIVIL TERM Defendant 1 IN DIVORCE DEFENDANT'S 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 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. f 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 relating to unsworn falsification to authorities. Date: ROBERT C. GRAY 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. ROBIN A. GRAY, Plaintiff VS. ROBERT C. GRAY, Defendant TO THE PROTHONOTARY: 1 IN THE COURT OF COMMON 1 PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA 1 CIVIL ACTION - LAW 1 1 NO. 99-4655 CIVIL TERM 1 IN DIVORCE 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 3301(c). 2. Date and manner of service of the Complaint: Acceptance of Service indicating service on 16 August 1999 upon Defendant's counsel 3. Complete either Paragraph (a) or (b): (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 Affidavit required by Section 3301(d) of the Divorce Code: 22 September 2000 (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 27 September 2000 upon Defendant's counsel of record (Affidavit of Service filed). 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: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Date: By Samuel L. Andes Attorney for Plaintiff ROBIN A. GRAY, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, 1 PENNSYLVANIA VS. 1 1 CIVIL ACTION - LAW 1 ROBERT C. GRAY, 1 NO. 99-4655 CIVIL TERM Defendant 1 IN DIVORCE THE PROTHONOTARY; Please withdraw Counts 11, III, IV and V (Counsel fees and expenses, equitable alimony and alimony pendente lite) from the divorce complaint previously filed in action. obin A. Gray Plaintiff 1 - ? e Sam 'MI L. Andes Attorney for Plaintiff 'o J ,, i :i _.. :i :. J ROBIN A. GRAY, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND j COUNTY, PENNSYLVANIA vs. ; CIVIL ACTION - LAW ROBERT C. GRAY, ) NO. 99-4655 CIVIL TERM Defendant ) IN DIVORCE N.OTLCRL0-3E,S UME-PRI9RS-URNAME NOTICE IS HEREBY GIVEN that ROBIN ANGELA GRAY, Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 27T" day of November 2000, hereby elects to resume the prior surname of ROBIN ANGELA KOHLER, and gives this written notice pursuant to the provisions of 54 P.S. § 704. Date: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND (SS.: On the -7 +i day of 5 T_ 2001, before me, the undersigned officer, personally appeared ROBIN ANGELA GRAY, known to me (or satisfactorily proven) to be the person whose name is signed to the within Notice to Resume Prior Surname and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Nota `Pe'. ? '- tc?"o?E"IP? FaA?irortar ??OMMISSIOM?pFpIR 3 AER(,Utp ?? UG. !! COI ROBIN ANGELA, OHLER j??- O rY ? ?