The URL can be used to link to this page

Home My WebLink About01-0314 FXSHANNON GRTFFIE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. :CIVIL ACTION -LAW NO. b+ ,1- 3~ ~ CIVIL TERM RANDY GRIFFIE, 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Cazlisle, 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 Telephone (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 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. James J. Kayer, Esquire Attorney for Plaintiff 4 East Liberty Avenue Carlisle, PA 17013 (717)243-7922 t SHANNON GRIFFIE, Plaintiff vs. RANDY GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.: U/- 3 i `P CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(cl OF THE DIVORCE CODE COMES NOW, Plaintiff SHANNON GRIFFIE, through her attorney, James J. Kayer, Esquire and avers as follows: COUNT I -DIVORCE 1. Plaintiff is SHANNON GRIFFIE, an adult individual who resides at 52 Mt. View Terrace, Newville, Cumberland County, Pennsylvania, 17241 2. Defendant is RANDY GRIFFIE, an adult individual whose address is 190 Pine School Road, Gardners, Cumberland County, Pennsylvania 17324. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 24, 1997 in Mt. Holly, PA. 5. Plaintiff and Defendant are not active members of the United States Armed Forces. 6. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements aze that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein aze made subject to the penalties of 18 PA. C.S. § 4904, relating to unsworn falsification to authorities. Date: ~~C~°~"'~_- . y t SHANNON GRIFFIE, Plaintiff V. RANDY GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-314 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this Z~~'day of , 200„ having reviewed the record in this matter, and the Stipulation of the parties, it is ORDERED and DECREED that: 1. The attached Stipulation and Agreement for Custody and Partial Custody is hereby adopted and ihcorporated as part of the divorce decree entered in this matter. .,° BY THE COURT: F'~ ~'llAa~Fii',l~`,r~l~~~~; n ~ ~ °1 ',;:J ~~ ~~ d'~f ,;. i ' ` ' _ ~. ~a._ ~~,a~~~ s , f 4 SHANNON GRIFFIE, Plaintiff V. RANDY GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-314 CIVIL TERM IN DIVORCE STIPULATION AND AGREEMENT FOR CUSTODY AND PARTIAL CUSTODY 1. RANDY GRIFFIE and SHANNON GRIFFIE are the natural parents of one minor child, HUNTER M. GRIFFIE, born August, 1997. ~~ ~~ ~ 7 ~ 2. Primary physical custody of the minor child, HUNTER M. GRIFFIE, shall be placed in the mother, SHANNON GRIFFIE. 3. The parties shad have shared legal custody of the minor child, HUNTER M. GRIFFIE. 4. The father, RANDY GRIFFIE, shall have certain rights of partial physical custody of the minor child. 5. Father shall have partial physical custody of the minor child on such weekends, weeknights, holidays, and for such vacation periods as may be mutually agreed upon between the parties. 6. Mother shall not unreasonably withhold rights of visitation or temporary physical custody. 7. Transportation shall be shared with the receiving party picking up the child, unless otherwise mutually agreed upon by mother and father. 8. Father works swing shift and the parties recognize that the dates and times of Mother's periods of physical custody and the custody transfers will need to be arranged around the particular shift he works on any given week. B e l 9. The parties agree and anticipate that this Agreement for Custody and Visitation may be entered as an Order of Court in the Court of Common Pleas of Cumberland County, Pennsylvania. 10. The Defendant shall provide health insurance for the Plaintiff and child. Upon the parties' divorce, the Defendant shall continue to provide health insurance for the child without interruption as available through his employer. 11. The parties do hereby stipulate and agree that they waive their respective rights to be present in court at the time an order is made pursuant to this Agreement for Custody and Visitation. IN WITNESS WHEREOF, the parties hereto and each of them have hereunto set their hands and seals intending to be legally bound hereby this ,y ~ day of 2001. ~~ '"` SHANNON GRIFFI - Plaintiff RAND GRIFFIE Defendant f '.. ~!` r I 1 ~ I l~T In ~~yy ~s °° Pd ~~8~t~, ~~ S~fh ~~i~cy. P. ~, SHANNON GRIFFIE, Plaintiff vs. RANDY GRiFFIE, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2001-314 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920.4(al(11(iil COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaintiff, SHANNON GRIFFIE, and that he did serve a true and connect copy of the Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, RANDY GRIFFIE, on January 20, 2001. The receipt form is attached hereto. J. Sw rn to and n scribed efore me this 20TH day of otary Public gggg' f m ~ . o. s- aervicea. NOTARIAL SEAL Vickie J. Group, Notary Public Borough of Carlisle, Couniy of Cumberland My Commission Expires Aug. 30, 2004 •/itldclF ~t9 bran tithe koid arther~tpiece, oron Me detlc@epaoe dose not 1..^ Adtlressee'B Abrlress ppeenna: ~NMre'HeWrn Reoelpt Nequeated'on the meilplece babes the eNde number. 2es 6ted Dellyery delivered. eoelpt wW show to whomflre eNtle was tlalivaretl end Ma date ~~ ~ Consult postmaster for tee. 3. Artlcle Addressed tq: 4a. Attlcle Ntunber Ra~~~ ~~E ~ z_ ~s ~ ~~a l0.a {~~ n e ScYl~\ 1~ct~ ab. sense Type ~`-p~~S ~ 1 O Registered L~1-CerpRed p fitc~[aea•Mail ^ (neared ~{~m Reoetpt for M1Aerohend(~ ^ COD ZO wngenn n' ~~~ F"ti FCU'I1707lr DeCel/79er 7994/x! 102595-g7-9.pt79 L~t~t; ""'"-' -~