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HomeMy WebLinkAbout08-0546DARIN T. GRIFFIE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW , NO. - S-x DANIELLE M. GRIFFIE, Defendant IN DIVORCE NOTICE TO DEFEND 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 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER,& EiNDSAY FLOWER & LINDSAY 26 West High Street Carlisle, PA Carol J. I-odsa , Esquire Attorney 693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff DARIN T. GRIFFIE, Plaintiff V. DANIELLE M. GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. og_ S96 Cowl ??- - IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Darin T. Griffie, an adult individual, residing at 18 West Big Spring Avenue, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Danielle M. Griffie, an adult individual, residing at 63 Vine Street, Newville, Cumberland County, Pennsylvania 17241. 3. The Plaintiff and Defendant both have been bona fide residents in 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 May 6, 2006 in Newville, Cumberland County, Pennsylvania 17241. 5. There have been no prior actions of divorce or for annulment between the FLOWER & LINDSAY 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his/her favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, F OW 7SAY uire Carol J. Lm y, q Attorney Id. 446 26 West ' treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LEVDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. 'i r Darin T. Griffie Date: a lJ ! G g SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA ,- ,_ w `- ?_' ? ? ..? ?-a rp ,' J-, A-? t' a. ? \? ?? t...?' ? ; 41 DARIN T. GRIFFIE, Plaintiff V. DANIELLE M. GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0!' J? (p IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on January 28, 2008, 1 served a true and correct copy of the Complaint in Divorce upon Danielle M. Griffie, by mailing the document to her address at 63 Vine Street, Newville, PA 17241 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Danielle M. Griffie. Respectfully submitted, SAIDIS, FLOWER &SAY Carol J. Linds y, quire Attorney Id. 4693 26 West High Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LIlVDSAY 26 West High Street Carlisle, PA Dated: January 29, 2008 19 ¦ Complade iterns 1, 2, and 3. Also complete a ONYMM" ? ? item 4 it Restricted Delivery Is desired. X ¦ Print your name and.address on the reverse AU 0 ? Addressee so that we can return the card to you. by (PdnW Nsrm) Date of Delivery ¦ Attach this card to the heck of the mallPieoe, or on the front If space permits. D. Is delivery address dllh 1? ? Yes 1. Article Addressed to: H YES, enter dsl ad ?(jue-l (e- 1 I? • rr"7 to e ?C N \ ? a L )V I I' o f I ` E? 3. Service Type Wow~ Mal 6aLl ire/ ? Re*Wrad ? Return Receipt for Merchandise ? Insured Mall ? C.O.D. 4. Restricted Delivery? (Exits Fes) N(lbe 2. Article wwwsarr Marrslb. bvM rrr ssMc 7004 1350 0003 7284 7351 (n Ps Form 3611. February 2W4 =140418"R M IF- tares ss ttiro SAIDIS, F JV NV E& _ LEND nr •uw 26 West High Street Carlisle, PA r rn r, I (Domestic 1t For delivery , a -- l OFFICIA L USE ru r?- Postage $ M p Certified Fee M C3 Return RecI Fee Postmark Here (Endorsement Required) C3 Restricted Delivery Fee rt7 (Endorsement Required) M ra Total Postage & Fees s p C3 Sent o 0 or ---------°- - ---------- ate,ZP+ city, -- ----- / Ta .i - r? ?a -Tt ?1§. ? ?_ ...? kyr } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c; o 6n-E' L Plaintiff Vs File No. C )00 c? 00 5 q (o IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] X prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of Z 0, GVn , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. \ Date: -H -19 -!RD VY 6k 4?? Signature l? Signature of name being r s ed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF &,be.rlc) On the )44k day of Agri 1 , 200 b , 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. tR. &Z 1)n4. NOTARIAL. SEAL pROMNOTARY, NOTARY MA Prothonotary or Notary Pub c C MY COSLE MMISSION SIRES COUMY JANUARC Y 4? 20 r ]SE r p Oil .?.ti ,rwr? ?G>} r C.'? ,T%' Y y 1 ' y ? 1 DARIN T. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND, COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-546 DANIELLE M. GRIFFIE, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed January 24, 2008. 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. 1 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 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: 14/,, Darin T. Griffie PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. FWVVER SAMIS, LINDSAY 26 West High Street Carlisle, PA 2. 1 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. 1 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 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 unswom falsification to authorities. Date: Akj' Darin T. Grifhe MAY 0 8 2008 2 -DO .: rrr A t co r ` DARIN T. GRIFFIE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-546 DANIELLE M. GRIFFIE, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed January 24, 2008. 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. 1 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 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: ?- 9 - O Ale le M. Griffie DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER$ 3301 (c1 OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. SAWIS, FI NVER & LIlVDSM 26 West High Street Carlisle, PA 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if i do not clairn them before a- divorce is granted. 3. 1 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 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 unswom falsification to authorities. Date: 5-9-to Y v, Ile ?MGriffie b -? a"' c? ? f -: ?? ?. -.,. ,;?. '.?'s .t to t.?: ?. t} ?? r tV <;.j r'rr '? Gr1 a ?? :gip DARIN T. GRIFFIE, Plaintiff V. DANIELLE M. GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-546 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on January 28, 2008, via certified mail. Proof of service was filed with the Court on February 5, 2008. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: May 6, 2008 and filed with Prothonotary on May 8, 2008. By Defendant: May 9, 2008 and filed with Prothonotary contemporaneously herewith. 4. Related claims pending: None 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: May 6, 2008 and filed with Prothonotary on May 8, 2008. By Defendant: May 9, 2008 and filed with Prothonotary contemporaneously herewith. SAMIS, LENDSM 26 West High Street Carlisle, PA SAIDIS, FLOWER-&, LI D Y Carol J. Linds , E ire Supreme Couift No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 C ??a C) - p Ph -- - 3 C-n 777 . ? -J3 ..Ic IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DARIN T. GRIFFIE No. 08-546 VERSUS DANIELLE M. GRIFFIE DECREE IN DIVORCE AND NOW, /n .Z0- , -2--* a, IT IS ORDERED AND DARIN T. GRIFFIE DECREED THAT AND DANIELLE M. GRIFFIE 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; N/A p By THE COURT: ?. F _