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HomeMy WebLinkAbout07-5448 KRISTINA L. GRIFFY PLAINTIFF vs. MICHAEL R. GRIFFY DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAI~TIA NO: d'~'- S'Sl~il~ ~lu~C~ l . -- l CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YO U HAVE BEEN S UED IN COURT. If you wish to defend against the clauns set forth rn the following pages, you must take prompt action. You are warned that lf'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 reliefreguested in these papers by the Plaintiff' You may lose money or property or other rights important to you, including custody or visitation ofyour children. When the ground for 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DNORCE 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. CUMBERI~iND CO UNTY BAR ASSOCIAT70N LAtYIYER REFERRAT "SERVICE 32 South Bedford Street Carlisle, PA 17013 TEL.EPHONF.: 717-249-31 G6 OM ~' LITLILAKIS Kara W. Haggerty, Esquire Attorney I.D. No.: 86914 36 South Hanover Street Cazlisle, Pennsylvania 17013 (717) 249-0900 KRISTINA L. GRIFFY PLAINTIFF vs. MICHAEL R. GRIFFY DEFENDANT : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO: Q~'_ S'~S/~ L:~u~~ • ~ l CIVIL ACTION -LAW : IN DIVORCE 1. Plaintiff is Krishna L. Griffy, who currently resides at 4719 Spring Road, Shermans Dale, Perry Cumberland County, Pennsylvania. 2. Defendant is, Michael R. Griffy, who currently resides at 104 6~' Street, Apt. E, Boonville, Missouri 65233. 3. The Plaintiff has been bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 20, 2003, in Carlisle, Pennsylvania.. COUNT I -DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. Divorce is sought pursuant to the provisions of the Divorce Code, ~ 3301 (c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since November, 2004, and continue to do so. 8. 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 such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. I~HEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II -EQUITABLE DISTRIBUTION 10. Paragraphs one (1) through nine (9) of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their ma+~*+age from May 20, 2003 through November, 2004, the date of their separation, which property is "marital propert~'. 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. [THEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. Da'rE D~ 13 b Respectfully submitted, Kara W. Haggerty Supreme Court ID 86 1 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint ABO~rrRtSuTUZa~s, L.L.P. VERIFICATION I, KRISTINA L. GRIFFY, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information, and belief. 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 ~ ~ ~ O "` - KRISTINA L. GRIFFY .CERTIFICATE OF SERVICE D NOW this ~~J da of Se tember, 2007, I, Kara W. Haggerty, Esquire, of Abom & AN y p Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Divorce Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First-class mail, postage prepaid addressed to the following: Michael R. Griffy 104 6`h Street, Apt. E Boonville, MO 65233 Respectfully submitted, Aao~-r& Suruza~s, L.L.P. Kara W. Haggerty, Esq Supreme Court ID 869 4 36 South Hanover Stree Carlisle, PA 17013 (717) 249-0900 Attorney for Plainti~ (, '~1 ;C '`0 a ~ ,~2. n ~o r' ~ ~ ~ ~ c ~. w °~ C C'a C s m Z`? ~.:~ ~~~... rte- C~ rs t~'t r z ~~ ,~ OM ~' LILAKIS Kara W. Haggerty, Esquire Attorney I.D. No.: 869]4 36 South Hanover Street Carlisle, Pennsylvania 17013 (717)249-0900 KRISTINA L. GRIFFY PLAINTIFF vs. MICHAEL R. GRIFFY DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNNSYLVANIA :NO: U~ " 5~~ C(v~ ( fi-~ /M CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Kara W. Haggerty, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301(c) and 3301(d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on September 14, 2007, at Carlisle, Pennsylvania, addressed as follows: Michael R. Grif1`y 104 6`h Street, Apartment E Boonville, MO 65233 Return card acknowledging receipt on September 24, 2007, is attached as Exhibit "A". ABOM c~ KUTULAKIS, LLP L~~~rn~ ~~ // / 1 Date. r~ ~" ~/ l_G(/(r'~ ~ G(IG (.~- Kara W. Haggerty, Esq ~ e 36 South Hanover Stree Carlisle, PA 17013 (717)249-0900 Attorney for Plaint I.D. No: 86914 .. t ^ 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. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article to: J .~©ov - ~ 11~ M D ~5z •I~ a7-a A Signature X y~ r" ^ Agent / 6 ^ Addressee B. Received C. Datggf Delivery _ / ~/~ D. !s rasa dr rent from item 1? ^ Yes If YES, enter delivery address below: O No s. Service Type l~cercined Mail ^ Expmss Mail D Registered ^ Return Receipt for Merchandise D Insured Mail ^ C.O.D. 4. Restricted Delivery?(Extra Fee) O Yes 2. Article Number 7005 2570 00~~ 384 X667 (Trar-sfer Iron service label PS Form 38'11, February 2004 Domestic Return Receipt iozsss-o2-M-~sao Exhibit ~~A" r' ~ N ~ ~. - -,.., rr +~yy rL ~ riZ J j y~ ` ~ C fU ~ ~' ~ r' C_,k `._~ ~ ~" , ...~ _ .~BOM ~' uTULAKIs Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 KRISTINA L. GRIFFY, Plaintiff v. MICHAEL R. GRIFFY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07-5448 CNIL TERM CNIL ACTION -LAW IN DNORCE 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: 1. Ground(s) for Divorce: a. Irretrievable Breakdown under ~3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: a. September 14, 2007. Certified Mail, Restricted Delivery 3. Date of execution of the Affidavit of Consent required by ~53301(c) of the Divorce Code: a. by Plaintiff January 4, 2008; by Defendant: January 3, 2008. 4. Related claims pending: a. None. 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: a. N/A r 6. Date Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: a. by Plaintiff January 7, 2008; by Defendant: January 7, 2008 Respectfully submitted, Aao~r & KUTULAxIS, L.L.P D~'rE D I D 7 I~~cc~ N~~ u ~i_ Kara W. Haggerty, Esq~S~`• Supreme Court ID #8 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint N C ~ C7 -- .,~.. ' ~ -n _ "I,~r ~ ' - ~j ___ r c_: _ /, _", _ ,, j`\ :: ~ . .- , <''= ~- `~ Sri - .-..~ CJ1 t C.:. --C ABOM ~' ICuru~is Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KRISTINA L. GRIFFY, Plaintiff v. MICHAEL R GRIFFY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07-5448 CIVIL TERM CIVLI. ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW Please withdraw Plaintiffs Count II -Equitable Distribution, in the Complaint for Divorce in the above-captioned matter. Date: ( 1 Kara W. Haggerty, E q Supreme Court I.D. 6 36 South Hanover Street Carlisle, Pennsylvania 17013 (717)249-0900 Attorney for Plaintiff ABOM c$ KUTULAKIS, L.L.P. ~ Q - ~ ~ r~ Q-~~~Y~ ~„ -~r ~ - ~:' ~ - _ _ ~- , ....w~ ..X t•' ..~ ABOM CS2' ICuTUr~is Kara W. Haggerty, Esquire Attorney I.D. #: 86914 3b South Hanover Street Carlisle, PA 17013 (717)249-0900 KRISTINA L. GRIFFY, Plaintiff v. MICHAEL R. GRIFFY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA N0.07-5448 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 September 14, 2007. 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 Complaint. 3. I consent to the entry of a final decree of divarce 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. X4904 relating to unsworn falsification to authorities. Date: ~ t ~/ V' MICHAEL R. GRIFFY ~ ~ ~ ~ ~~ ;,~;; , ~ a~ ~ ~~ f-- " 1 s7 cr' _ ; rs ` ~- ~ _.,a ~-: ~_- ~ sv OM ~' KuTUL~Is Kara W. Haggerty, Esquire Attorney I.D. No.: 86914 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 KRISTINA L. GRIFFY PLAINTIFF vs. MICHAEL R. GRIFFY DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-5448 CIVIL TEIt114 CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(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 1$ Pa. C.S. X4904 relating to unsworn falsification to authorities. Date: / ~~ O STINA L. GRIFFY ~ ~ ~ ~ ~ -rr a'T ~ ~ C.._ 4 ..•` d h, " ~ ~ ~~ ~ ~~ y~ Lt ~ ~~ \.._ , ~! .~ V S 0 ABOM cSZ' I~LITLILAKIS Kara W. Haggerty, Esquire Attorney I,D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 KRISTINA L. GRIFFY, Plaintiff v. MICHAEL R. GRIFFY, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA N0.07-5448 CIVIL TERM CNIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on September 14, 2007. 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 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 axe made subject to the penalties of 18 Pa. C.S. X4904 relating to unsworn falsification to authorities. r _O~ Date: '" _ ~ ~ O STINA L. GRIFFY c"] ~ ~ ~ -rt c~ ~; ~- ,, c_ ~ 4"~" ~ ~ "',v 'l'i ~ rr ~~ ~ !V . ~h ,,,~ ABOM ~' ICurur_nxis Kara W. Haggerty, Esquire Attorney I.D. No.: 86914 36 South Hanover Street Cazlisle, Pennsylvania 17013 (717)249-0900 KRISTINA L. GRIFFY PLAINTIFF vs. MICHAEL R. GRIFFY DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-5448 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(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. 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. X4904 relating to unsworn falsification to authorities. Date: ~~1~``/~ ~ D r MICHAEL R. GRIFFY ~~~ .,~ ~ p ~ -c~ c.- ~~ ;~ n~ r ~r . ~ ~ 4 r i ~r Y.. +.~ •' ~ am? ~` _ =a- ~ L ~~ ,~. I N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KRISTINA L. GRTFFY, °~ Plaintiff VERSUS AdT('~T A RT ~-~~~~, No. DECREE IN DIVORCE 07-5448 CNIL AND NOW, C/Q,..~~f.-, L3~ Z°~ IT IS ORDERED AND DECREED THAT KRISTINA L. GRIFFY PLAINTIFF, AND MICHAEL R GRIFFY ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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. PROTHONOTARY .. ..