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Home My WebLink About99-04950". ED 1::?6t h t t?3 F I?j 0 h 7 c? a- l y i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF -, PENNA. .Kimberly K..Graser NU, 9950 ..... ............... l?P9 ... .. .... _ Plaintiff...... Versus i , ..Roger .L.. Gr.aser._ Defendant DECREE IN DI V 0 R C E AND NOW, ......... /.41 19.71... it is ordered and s i decreed that .................Kiraherly..K.. Graser............ plaintiff, and .......................... Roger..1„ . G.rasex............. , defendant, are divorced from the bonds of matrimony. ....... None 411 ....................................................... i 0 By Th Cour Attest: .?. __ ... J ri t? Prothonotary ?O 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 0 been entered; ao,/ e??v KIMBERLY K. GRASER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW ROGER L. GRASER, JR., 99 - 4950 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information to the Court for entry of a Divorce Decree: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (C) of the Pennsylvania Divorce Code. 2. Date and Manner of service of the complaint: Certified mail, restricted delivery, on August 18, 1999. 3. Complete either paragraph (a) or (b). (a) Date of execution of affidavit of consent required by Section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on November 17, 1999 and by Defendant on November 17, 1999. (b) (1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: Not applicable: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Not applicable. 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: Not applicable (b) Date Plaintiff's Waiver of Notice in Section 3301 (C) was filed with the Prothonotary. November 18, 1999. Date Defendant's Waiver of Notice in Section 3301 (C) Divorce was filed with the Prothonotary. November 18, 1999. November 18, 1999 Andrew C. Sheely, squire Attorney for Plaintiff } ` ?U L ? ? r- jL -? u-: '? C_ is 1?' ._ ___? C?i Ll '- _?_', : - C ?. ? ?? Andrew O. Shealy, Esquire ,127 S. Market street ., P.O, Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW ROGER L. GRASER, JR. 99 - v 9So CIVIL TERM 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 against you and a decree in 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 with your children. When the grounds 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. 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, PENNSYLVANIA 17013, (717) 249-3166 BY /7Z??Nw? J#,q Andrew C. Sheely, EsgCe PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Shealy, Esquire 127• S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 SJ CIVIL TERM IN DIVORCE COMPLAINT 1. Plaintiff is Kimberly K. Graser, an adult individual who currently resides at 551 Lexington Avenue, Mechanicsburg Cumberland County, Pennsylvania. 2. Defendant is Roger L. Graser, Jr., an adult individual who resides at 720 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fida residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 17, 1997 in Camp Hill, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. 8. The marriage between the parties is irretrievably broken. 9. This action is not collusive. 10. The parties separated on June 10, 1999. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce divorcing Plaintiff and Defendant, absolutely. Respectfully submitted, Date: August'( , 1999 Aj du?' Andrew C. Sheely, E qui Attorney for Plaints. PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 697-7050 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: August /6' 1999 K' erly K. G a e 2 Andrew C. Sheely, Esquire 177 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR. Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - CIVIL TERM IN DIVORCE AFFIDAVIT Kimberly K. Graser, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Kimberly K. Gr e a s ? n ? a b M 1 N r n ? >? p4 J 3 G ?.r r d lo- Y. ? U 'Andrew C. Shealy, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 4950 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 16, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Divorce Complaint. 3. I consent to the entry of a 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: I I ` '7- 99 +mYY \,f. A) U` O A Ki: ern ly K. Graser, laintiff .i 1 Andrew C. Shealy, Esquire 127 S. Market street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 4950 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 16, 1999. I acknowledge receiving a certified copy of the Divorce Complaint, said copy being served upon me by certified mail on August 18, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Divorce Complaint. 3. I consent to the entry of a 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE : Ro L. , J , Defendant C L.. ci 1 C.l lJ 'Andrew C. Shealy, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID N0. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 4950 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301 (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 decree 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.A. Section 4904 relating to unsworn alsification to the authorities. DATE: II' IT7' f 99 Jnn K' erly K. Gr ser, laintiff Y Vr? r.- _, :.i` 'i. -- t . i _ _i ??;i :J _ pi` _ ?'J 1 ?' .., fj Andrew C. Sheely, Esquire 177 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 67469 717-697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 4950 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301 (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 decree is granted. 3. 1 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.A. Section 4904 relating to unsworn falsification to the authorities. DATE: //-/7 / Ro . L. G Jr efendant ti L PD J Andrew C. Shealy, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717:697-7050 (Phone) 717-697-7065 (Fax) KIMBERLY K. GRASER, Plaintiff VS. ROGER L. GRASER, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99 - 4950 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that he caused a true and correct copy of the Divorce complaint in the above-captioned matter to be served upon Roger L. Graser, Jr., by Certified Mail, Restricted Delivery, Return Receipt Requested, as indicated by the attached receipt cards, on August 18, 1999. ANDREW C. SHE SWORN to and subscribed before me this d_h day of September, 1999. !c &e'-/() /J Notary Public My Commission Expires: NOTARIAL SEAt KATHLEEN A. SHEELY, Haft" KOAe Mods. "' 1, p Sour C.umbdond CaunLLr W Com"M &on AupM 45, MW r.: ?- -- ?. >- ?.-: ???-.. c ? ?.., -- -. ??j '? ;_ ?_,? :, - `? a_ ,if(i I?, C` .? U'. U .44 . h rar4 S , I andbre foretkldonel services. I also wish to receive the 3.4a. end 0b. following services (for an Ord ed*M m 1110 renrea of Of form n Nun we an return We extra fee): to the Went of er maephoe, ar mar tick a pea don not 1. 17 Addressee's Address "pt Rowmisrmtlr rnWlMap bN anfole nmehar. 2. W Restricted Delivery Iipl licit eW0wfo 11110111 ete 0rod0M and titre dale Consult postmaster for fee. Roger L. Graser, Jr, Z d89 580 674 RESTRICTED DELIVERY 4b. service Type FOR ADDRESSEE ONLY 0 Registered 13 Certified 720 Cumberland Point Circl 0 E.xpressMell 0 Insured Mechanicsburg, PA 17055 ? RR>cepfWrf4ede dae 0 COD PS Form8811, Decal Z 489 580 674 l1skv'al Sirvice Receipt for Certified Mail No Insurance Coverage Provided. Sentto ?y ?" ??? rian {?eSff iC?Lt K L. 6 r ?r Slre^e^ NNu, b r %-1/ CwMWr IcAa POL,17L e,fCje- Post Office. State, & ZIP Code PR 55' Mec ant b 110 Postage SS Certified Fee NO Special Delivery Fee Restrided Delivery Fee a.7 Retum Receipt Showing to i Whem BD Rehm Date, ea' TO / ostag ees ) rA S .? Po orD ' 9 o t/SPS N W `o O O to 0 LL a T CV R . f ,