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Home My WebLink About03-4311ALVIN J. GROFT, JR., PLAINTIFF V. TIERNA J. GROFT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 2003 - 431) CIVIL TERM 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ALVIN J. GROFT, JR., PLAINTIFF V. TIERNA J. GROFT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 431( CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Alvin J. Groft, Jr. who resides at 709 Elkwood Drive, New Cumberland, Pennsylvania 17070. 2. The Defendant is Tierna J. Groft who resides at 600 Bay Street, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 8, 2002 in Adams County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. There were no children born of this marriage. 9. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint 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: se?l 3 moo Alvin J. Grof / C7 r. ? ? yy i 1 r r P•-' _ r r r7 Q V q -ND .n O _\ i ALVIN J. GROFT, JR., PLAINTIFF V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 4311 CIVIL TERM TIERNA J. GROFT, IN DIVORCE DEFENDANT ACCEPTANCE OF SERVICE I, Tierna J. Groft, accept service of the Divorce Complaint in the above captioned matter. Dated: f?t? S 2oti3 ,47Yrz Tierna J.?Groft 600 Bay Street Mechanicsburg, PA 17050 DEFENDANT .? ... _., ?:,' ALVIN J. GROFT, JR., PLAINTIFF V. TIERNA J. GROFT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 4311 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: yl! ??OCI GC- ?c ?' SIlL_ TIERNA J GROFT } ALVIN J. GROFT, JR., IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2003 - 4311 CIVIL TERM TIERRA J. GROFT, IN DIVORCE DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 3, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ????oG L.vmr !r TIERNA64. GROF ALVIN J. GROFT, JR., PLAINTIFF V. TIERNA J. GROFT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 4311 CIVIL TERM IN DIVORCE WAIVER OF NOTIC E OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (8) OF THE DIVO RCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ele, / ALVIN . GROF JR. ?_> ;' ? ;> ? . _:, _ iy" .? ALVIN J. GROFT, JR., IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2003 - 4311 CIVIL TERM TIERNA J. GROFT, IN DIVORCE DEFENDANT AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 3, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: l L 3 O ^b ALVIN . GROF , JR ?? ALVIN J. GROFT, JR., PLAINTIFF V. TIERNA J. GROFT, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003 - 4311 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On September 5, 2003 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, April 13, 2006; By Defendant, April 18, 2006. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary on April 19, 2006. Date Defendant's Waiver of Notice in § 3301(c) divorce was filed with the Prothonotary on April 19, 2006. Thomas D. Gould, Esquire Attorney For Plaintiff ?? -, ?? ;` . ,? t....; •-? T -r1 ?"S T ('?.? ? -- d ' , i '"C:? ? ? i . N rr? y 4- -`? --C ..<„ .?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ALVIN J. GROFT, JR., Plaintiff VERSUS TIERNA J. GROFT, No. 2003-4311 Defendant DECREE IN DIVORCE CIVIL AND NOW, _?. IT IS ORDERED AND DECREED THAT ALVIN J. rRnP'P_ .'rn AND TIERNA J. GROFT ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; NONE BY T*,Iff?COURT: ATTEST: _ • ^ 1 J. PR*ftHONOTARY ,? a ?? ? ?o - ?? - ? ?QW ?i - ? .-.. f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA laintiff Vs Defendant File No02 dA3 - IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated .2,66 91. J hereby elects to resume the prior surname of and gives this written notice avowing his / her intention p4j?suant.to the pr visio of 54 P.S. 704. Qj- Date: - 02 D - .0 Za? Signa of name being res ed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF Cu dul?C) On the of day of , 200 S , before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. K_ ze& Protonotary or Notary Public myrmK "07HfNNOTARY,, N MY PUBUC CARLISLE OMBEi0 M =MW COURTHOUSE MY COMINSSiON WMES JANUARY 4, 2010 r ?s v r . ?r.w