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HomeMy WebLinkAbout03-3227PERRY D. GRIMES, Plaintiff VS. TRACY I GRIMES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 3. 3 ,~ ,/'7 CIVIL TERM CIVIL ACTION--LAW IN DIVORCE NOTICE TO DIr, FEND AND CI,AIM 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 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 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, High and Hanover Streets, 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, PA 17013 (717) 249-3166 PERRY D. GRIMES, Plaintiff VS. TRACY I. GRIMES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 05 d?~7 CIVIL TERM : : CIVIL ACTION--LAW IN DIVORCE COMPLAINT 1N DIVORCE 1. Plaintiff is Perry D. Grimes, who currently resides at 3 Joan Lane, Shippensburg, Cumberland County, PA 17257. 2. Defendant is Tracy I. Grimes, who currently resides at 45 Leeds Road, Newville, Cumberland County, PA 17241. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on April 6, 1985 at Newville, Cumberland County, PA. 5. Them have been no prior actions of divome 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 require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Law Office of James K. Jones, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my knowledge and belief. I understand that false sCtements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Perry D.Grimes PERRY D. GRIMES, Plaintiff VS. TRACY I. GRIMES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION--LAW IN DIVORCE CERTIFICATE OF SERVICE I, Dirk E. Berry, Esquire, do hereby certify that on this day Plaintiff's Complaint in Divorce was served by Certified Mail, return receipt requested, and First Class Mail upon the following persons: Tracy I. Grimes 45 Leeds Road Newville, PA 17241 Date: ~-~ ~D ~ Dirk E. Berry, Esquire Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 PERRY D. GRIMES, Plaintiff TRACY I. GRIMES, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 03-3227 CIVIL TERM : : CIVIL ACTION--LAW . : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under {}3301 (c) of the Divorce Code was filed on July 9, 2003. 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 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 PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Pe~/y D. Grimes PERRY D. GRIMES, Plaintiff Vo TRACY I. GRIMES, Defendant IN THE COURT OF COMMONPLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 03-3227 CIVIL TERM CIVIL ACTION--LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO I~EQUEST ENTRY OF A DIVORCE DECREE UNDER 83301 ¢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. Perry D. Grimes PERRY D. GRIMES, Plaintiff Vo TRACY I. GRIMES, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 03-3227 CIVIL TERM : : CIVIL ACTION--LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A coml~laint in divorce under §3301(c) of the Divome Code was filed on July 9, 2003. 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 a final decree in 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. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: [[-,~:~3 ~¢~ ..~ ~ PERRY D. GRIMES, Plaintiff TRACY I. GRIMES, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 03-3227 CIVIL TERM : : CIVIL ACTION--LAW : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 83301 (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. ~T~¢y I. ~r~es ~) PERRY D. GRIMES, Plaintiff TRACY I. GRIMES, Defendant : IN THE COURT OF COMMONPLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 03-3227 CIVIL TERM : : CIVIL ACTION--LAW : : : IN DIVORCE · 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, · &ttach this card to the back of the malll:~ece, fron the front if space permits. 1. ~tlcle Addressed to: 2. Article Number ~ (Transfer from se~'ice label) O~iV~y ~ dl~re~t l~om ~ 1 ? OYe~ If YES, e~iter delivery address below: [] No ice Type [] Registered [] Insured Mell j 4. Restricted Delivery? (Extra 7002 2410 0007 8509 9538 [] Express Mail [] Rstunl Receipt for Merchandise [] C.O.D. ~Yes -- 102595-01 -M-i~-~ PS Form 3811, Mamh 2001 Domestic Return Receipt PERRY D. GRIMES Plaintiff VS. TRACY I. GRIMES Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 03-3227 CIVIL TERM PRAEClPE TO TRANSMIT RECORD 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 §3301(c) (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mai]-, restricted delivery served on July 10, 2003. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: byplaintiff.November 20, 2003 ; by defendant ~-",~_o_v_e,~er 2,0~ 2003 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Related claims pending: Separation The parties incorporate: bu~: d~ n~ m~g~: ~h~r and Property Settlement Agreement dated September 11 20u3. 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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: , Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: /~¢.,~,¢,---' ,/~ Attorney for Plaintiff / IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PERRY D. GRIMES Plaintiff VERSUS TRACY I. GRIMES Defendant PENNA. 03-3227 Civil'Term DECREE IN DIVORCE AND NOW, DECREED THAT PERRY D. GRIMES , ~O-q , IT IS ORDERED AND , PLAINTIFF, AND TRACY I. GRIMES , 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; The Parties incorporate, but do not merge, their Separation and Property Settlement Agreement dated September 11, 2003. BY THE COURT: / A T/~/~~~' / a. PROTHONOTARY