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HomeMy WebLinkAbout99-073960 L-. r {?':?<?:Y,i;:?•;'{M:;tiA• .N":P;•_:A•: ?:?:•...:?}":?:•..:W• •-X::?i::•1:{i:?}:}A::iC:?•::•:?r' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Julie R. Gritton, 7396 of .................................................................... . ....... . [V<1. 1999 : ...... .Plaint.i_ff ................................. II ................ ...... Versus ji Mark A. Gritton,.._..._.....,., •:•+I ..Defendant DECREE IN DIVORCE AND NOW, .......... ??4 4.y... ZY Lp°°, • . it is ordered and Julie R. Gritton • • • • , . • .... , plaintiff, decreed that ............ . Mark A Gritton • ............ . 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 o been entered; lip, None. . . . . . ... ................................... . : ..................... . By T?tse Co urt Atlest: ;, Prothonotary a asc?? V •. mad 1% r IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Plaintiff V. Mark A. Gritton, Defendant Civil Action - Law : No. 1999- 7396 CIVIL In Divorce a v.m. PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: Code. Ground for divorce: Irretrievable breakdown under Section 3301(d) of the Divorce 2. Date and manner of service of the Complaint: January 7, 2000 by Defendant accepting service of said Complaint. See Affidavit of Acceptance of Service on file. 3. (a) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: November 30, 1999; (b) Date of service of the Plaintiffs Affidavit upon the Defendant: served upon Defendant on January 7, 2000 by Defendant accepting service of same; see on file Acceptance of Service on file. 4. Date and manner of service of the Notice of intention to File Praecipe to Transmit Record and Defendant's Counteraffidavit, a copy of which is attached: served copies of Defendant's Counteraffidavit under Section 3301(d) of the Divorce Code together with Notice of Intention to Request Entry of Divorce Decree to Defendant, by mailing copies of same to him by regular mail correct postage attached, to his last known address on January 27, 2000. See Verification of Service on file. Date: -LGZa2GG(, • QC?(? J ice M. Hawbaker, squire Attorney for Plaintiff ;`.r.Y IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Civil Action -Law Plaintiff v. 1999 - 7396 Civil Mark A. Gritton, Defendant : In Divorce a v.m, TO: Mark A. Gritton, Defendant You have been sued in an action for divorce. You have failed to answer the Complaint or file a counteraffidavit to the Plaintiffs Affidavit. Therefore, on or after February 17, 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. A COUNTERAFFIDAVIT 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Plaintiff V. Mark A. Gritton, Defendant Civil Action - Law 1999 - 7396 Civil In Divorce a v.m. DEFENDANT'S COUNTERAFFIDAVIT 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 verify that the statements made in this Counteraffldavit 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 falsification to authorities. Date: Mark A. Gritton, 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 Counteraffidavit. ?? r: • .. i ? i c?a l ?_ ..l `J -i. ? IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Plaintiff V. Mark A. Gritton, Defendant Civil Action - Law : =..1999- 739(. In Divorce a v.m. AFFIDAVIT OF ACCEPTANCE OF SERVICE 1, Mark A. Gritton, Defendant in the above-captioned action, do hereby accept service of the Notice To Defend and Claim Rights and Complaint in Divorce along with Notice to the Defendant and Plaintiff's Affidavit and an Affidavit of Nonmilitary Service filed in the above- captioned action. Date: Mark A. Gritton ?a r UtI "r J ti CD " IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Plaintiff V. Mark A. Gritton, Defendant : Civil Action -Law -?x 1999 - 739L tz?? In Divorce a v.m. 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. Ajudgment 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 Franklin County Courthouse, first floor, 157 Lincoln Way East, Chambersburg, 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 or 1 800 990 9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin 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 disabled 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. ---A IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Civil Action -Law Plaintiff V. F.R. 19 - 9S- 13 q(I fir.. s Mark A. Gritton, Defendant : In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff is Julie R. Gritton, a sui juris adult, who currently resides at 310 Shepherd Lane, Cumberland County, Shippensburg, Pennsylvania, 17257, since August, 1999. 2. The Defendant is Mark A. Gritton, a sui juris adult, whose last known address of Lot 15, Wardview Mandeville P.O., Manchester, Jamaica, WI and with a mailing address of c/o Paulette Gritton, Shop 42, 5 1/2 Caledonia Road, Mandeville P.O., Manchester, Jamaica, WI, since 1997. 3. Plaintiff has 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 on April 21, 1997 in St. Elizabeth, Waterloo, Jamaica. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff and Defendant have lived separate and apart for a period in excess of two (2) years, the last day of marital cohabitation having been on or about April 23, 1997. 8. Plaintiff has been advised that marital counseling may be requested and that a list of marriage counselors is available in the office of the Franklin County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff prays that a decree be made divorcing him and the Defendant from the bonds of matrimony now existing between them. I verify that the statements in this Complaint 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 falsification to authorities. Date: Iyt?6?? Julie Gritton, Plaintiff ice M. Hawbaker Esquire Attorney for Plaintiff Of Counsel: KAMINSKI & HAWBAKER 221 Lincoln Way East Chambersburg, PA 17201 C, L u. U of ? C.J v. IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Plaintiff V. Mark A. Gritton, Defendant Civil Action - Law F.R. 19--q9- In ?? Divorce a v.m. AFFIDAVIT OF NONMILITARY SERVICE -5., Lf U? Now comes Julie R. Gritton, Plaintiff in the above-captioned matter, and pursuant to the provisions of 18 Pa. C.S. Section 4904, deposes and says that the Defendant in this action, to wit, Mark A. Gritton, is, to the best of his knowledge, not a member of the United States Armed Services and, at such time as this action was filed and at all times thereafter, was serving neither in any active or inactive capacity with any branch of the United States Armed Forces. I verify that the statements made herein 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 falsification to authorities. Dale: II ?7?' 79 Julie Gritton t. 4 ? LLJ (? L ^J cri CJ Ch IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Civil Action -Law Plaintiff V. : F.R. 19 Q? "725-(v Mark A. Gritton, Defendant : In Divorce a v.m. NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counteraffidavit 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 April 23, 1997 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably 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 this Affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: //'??'Y7/? Julie p. Griffon L U.1C% yf Lq _ 7 C ?i • ? C { ' IN THE COURT OF COMMON PLEAS OF THE 39TH JUDICIAL DISTRICT OF PENNSYLVANIA - CUMBERLAND COUNTY BRANCH Julie R. Gritton, Plaintiff Civil Action - Law V. Mark A. Gritton, Defendant 1999 - 7396 Civil In Divorce a v.m. VERIFICATION OF SERVICE I, Janice M. Hawbaker, Esquire, hereby certify that I served a Notice of Intention to Request Entry of Divorce Decree together with Defendant's Counteraffidavit in the above- captioned matter upon the Defendant, Mark A. Gritton, at the last known address of the Defendant, P. 0. Box 360, Brooklyn, NY 11236, by mailing same by regular mail, correct postage attached, from the Chambersburg Post Office, Chambersburg, Pennsylvania, 17201, this date. I verify that the statements made in this verification 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 falsification to authorities. Date: January 27, 2000 J ice M. Hawbaker, Attomey for Plaintiff p