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Home My WebLink About08-1532KRISTY GREEN, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL GREEN, : CIVIL ACTION - LAW Defendant :NO. Q8- 1532 : IN DIVORCE CIVIL TERM NOTICE 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 Courthouse, High and Hanover 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone 717 249-3166 r KRISTY GREEN, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION PAUL GREEN, :NO. 0 J?- J-53 z CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Kristy Green, who currently resides at 3 Barry Circle, Shippensburg, PA 17257. 2. Defendant is Paul Green, who currently resides at 32 East Main Street, Apt 1, Newville Pa 17241. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to filing this Complaint. 4. Plaintiff and Defendant were married on August 25, 2004. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been advised that counseling is available, and that either may have the right to request that the Court order the parties to participate in counseling. 8. There was one child born during this relationship, namely Kaylee N. Green whose Date of Birth is August 22, 1992. 9. Neither of the parties in this action is presently a member of the armed forces. 10. The plaintiff and Defendant are both citizens of the United States. COUNT I-DIVORCE 11. The Plaintiff avers that the grounds on which the action is based are as follows; a. That the marriage is irretrievably broken. b. The parties have irreconcilable differences which cannot be corrected. WHEREFORE, Plaintiff requests this honorable court: 1. Enter a decree of divorce. 2. Grant such further relief as the Court may deem equitable and just. Respectfully Submitted, Gan Law Group c iar . Gan, Esquire Attorney I.D. 68721 64 South Pitt Street Carlisle, Pennsylvania, 17013 717-241-430 717-243-5175 ?j?d8 VERIFICATION I, Kristy Green, hereby certify that the facts set forth in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information and belief, t I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unworn falsification to authorities. Date: 3? 0 Document #: 163765.1 C) rv rb -4L s' ao KRISTY GREEN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V. NO. PAUL GREEN, Defendant IN DIVORCE ACKNOWLEDGEMENT OF SERVICE I, PAUL GREEN, do hereby certify that on-A I was served BY FIRST CLASS ..Ax- MAIL with a copy of the Complaint for Divorce by Gan Law Group, 64 South Pitt Street, Carlisle, Pa 17013. f, Paul Acknowledged By: Dated: Richard R. Gan, Esquire Attorney I.D. No. 68721 64 South Pitt Street Carlisle, PA 17013 (717) 241-4300 243-5175 Attorneys for Plaintiff Document #: 181832.1 C'; t;;?- '?? -,.; 4q -, ?? ?y ` ?' t\.y ?? t ' '% ?' --,. ,' . i {. ? . ,. ?? ?t w --'J KRISTY GREEN, Plaintiff VS. PAUL GREEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION - LAW DIVORCE NO. 08-01532 AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on March 7, 2008, and served on Defendant March 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and the parties have lived continuously apart for in excess of two years. 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 are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 1 -. :ZJ t Y° KRISTY GREEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE PAUL GREEN, Defendant NO.08-01532 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER 43301(C) AND 4 3301(D) 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 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Dater r.a ,...-. ? ?_?' -_-, ? ?? r? !.. j?f ?? . ? ,.., i.. ....,,. t. . ... .. +•=a . . f';:.? .. ? 1 9 ? ,,.j P',#"j :,y ?... . .. KRISTY GREEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA VS. CIVIL ACTION - LAW DIVORCE PAUL GREEN, Defendant NO. 08- 01532 AFFIDAVIT OF CONSENT A Complaint in divorce under §3301(d) of the Divorce Code was filed on March 7, 2008, and served on Defendant March 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and the parties have lived continuously apart for in excess of two years. 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 are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: "/5 "6g r-,a r-- e:; :_.?,E -,.? •? .?:? ??._ ??? _ . ;? ` ,'r- ? ?, ,. ?, . KRISTY GREEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE PAUL GREEN, Defendant NO. 08- 01532 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER 43301(C) AND & 3301(D) OF THE DIVORCE CODE 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 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: ' ?-??' J. KRISTY GREEN, JN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE PAUL GREEN, : Defendant NO. 08 01532 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under §3301(d)(1) of the Divorce Code. 2. Date and manner of service of Complaint: Served upon Defendant: acknowledgment of service 3/08/08. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to Pa.R.C.P. 1920.42(e) (1): Plaintiff- -1111.5-109 Defendant - 7?:5--o e, r 1%. (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: ; (2) Date of filing and service of Plaintiffs affidavit upon the respondent: 4. Complete the appropriate paragraphs: (a) Related claims pending: All claims have been resolved by a signed Marital Settlement Agreement. 5. (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: By first class mail on: y/y y/ 'O . (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary:/Zellk (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: /7 L Yl c9 GAN LAW GROUP OQ Date I.D. No. 68721 64 South Pitt Street Carlisle, PA 17013 (717) 241-4300 Attorney for Plaintiff I . CERTIFICATE OF SERVICE AND NOW, this 24 th day of April, 2008 I, Richard R. Gan, Esquire, Attorney for Plaintiff, hereby certify that I served a copy of the Praecipe to Transmit Record on Defendant Paul Green and Plaintiff Kristy Green this day by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: Paul Green 32 East Main Street Apt 1 Newville, Pa 17241 Kristy Green 3 Barry Circle Shippensburg, Pa 17257 GAN LAW GROUP ?'^? r^. ?_? r.. ?? spa F? '` t i ::? .-,. r;7r i.1"1 -? K:_ ?. .. KRISTY GREEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL GREEN, DEFENDANT 08-1532 CIVIL TERM ORDER OF COURT AND NOW, this 2C day of April, 2008, the request for the entry of a final decree in divorce, IS DENIED AT THIS TIME.' ichard R. Gan, Esquire For Plaintiff Paul Green 32 East Main Street Apt. 1 Newville, PA 17241 sal l:o P F-5, en?l< LC-CC, y/?9?d8 ?ir7 i ' The complaint was filed on March 7, 2008, containing a single count under Section 3301(c) of the Divorce Code. A mutual consent decree under Section 3301(c) cannot be entered until 90 days have elapsed from the date of commencement of the action. That has not occurred in this action. LLI CNJ C3_ LU <C L1 ?y E?J ? r7 KRISTY GREEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL GREEN, : DEFENDANT 08-1532 CIVIL TERM ORDER OF COURT AND NOW, this IrL day of June, 2008, on the praecipe to transmit the record filed on June 11, 2008, the request for the entry of a decree in divorce, IS DENIED AT THIS TIME. ? Richard R. Gan Esquire For Plaintiff ? Paul Green 32 East Main Street Apt. 1 Newville, PA 17241 :sal P ?-` ' ?? . ?;e ? .. a 7 ?^ ?--. t? ?- "? t} ?? ,,?„? ?ca.. N KRISTY GREEN, :IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE PAUL GREEN, Defendant NO. 08 01532 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c)(1) of the Divorce Code. 2. Date and manner of service of Complaint: Served upon Defendant: acknowledgment of service 3/08/08. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent 4. required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to Pa.R.C.P. 1920.42(e) (1): Plaintiff- 4/15/08 Defendant - 4/15/08 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(c) of the Divorce Code: (2) Date of filing and service of Plaintiff's affidavit upon the respondent: NA 4. Complete the appropriate paragraphs: (a) Related claims pending: All claims have been resolved by a signed Marital Settlement Agreement. 5. (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: By first class mail on: 7/14/08 (latest). (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: 4/25/08 (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 4/25/08 GAN LAW GROUP 108 - -7 A/ Date I.D. No. 68721 64 South Pitt Street Carlisle, PA 17013 (717) 241-4300 Attorney for Plaintiff CERTIFICATE OF SERVICE AND NOW, this 14 day of July, 2008 I, Richard R. Gan, Esquire, hereby certify that I served a copy of the Praecipe to Transmit Record on Paul Green and Kristy Green this day by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: Paul Green 32 East Main Street Apt 1 Newville, PA 17241 Kristy Green 3 Barry Circle Shippensburg, PA 17257 GAN LAW GROUP 64 South Pitt Street Carlisle, Pa 17013 ID 68721 717-241-4300 C ? -n f - C T . ..4 M1. _? _ ,y C - < - czs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KR ISTY GREEN Plaintiff NO. 2008 - 1532 CIVIL TERM VERSUS PAUL GREEN Defendant DECREE IN DIVORCE AND NOW,_ ,A %j t%Ak ! b , IT 1S ORDERED AND DECREED THAT KRISTY GREEN , PLAINTIFF, PAUL GREEN AND 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 BEEN ENTERED; NONE ,?? 0. ?/ -Z- 4 ?~' Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 61 Plaintiff Vs File No. IN DIVORCE pa Go--ey) Defendant 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 3 "J y « j too Er hereby elects to resume the prior surname of oy <Ae (- , and gives this written notice avowing iris! her intention pursuan to the provi 54 P.S. 704. .%' I \ -FS 10-%-- aim - - -P-Z? Date: Q I 1 0" Sign e 4Siat?j of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF C -*t tr1Qiftd On the I S day of 0 C? 0o tr , 20A 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 1 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. NOTARIAL SEAL Prothonotary or otary Pu lic PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 A* /N w