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Home My WebLink About08-4163, Crystal A. Griffith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- ?/IL3 CIVIL TERM Richard L. Griffith, Jr. 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 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, 1 Courthouse Square, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Crystal A. Griffith IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- CIVIL TERM Richard L. Griffith, Jr. Defendant IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff ism Y6:1& U ? ?FirW ,who currently resides at Cumberland County, Pennsylvania. 2. Defendant is fC h /=?? 1?0 who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on MY d if &>C6 _ at /o WC-j r WCI -)s-r 5 ? 1;q oAkhLsZy'RCx ?a ?'7Q57s 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. '?suol d jwsr a "I-e 44 0 . (",;6e-, Date Plaintiff, Pro Se me To1q,51AL g, Ga I ? i verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. COD Date: Pla ntiff, Pro Se Assisted by: Melissa P. Greevy, Esq. Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 (717) 761-4540 . , Crystal A. Griffith Plaintiff V. Richard L. Griffith, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- IN DIVORCE CIVIL TERM NOTICE OF AVAILABILITY OF COUNSELING 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(d) 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 (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. C7 K ' - r- n -1 Y 3 r ?t T >C? ' . (.: C) 4 Crystal A. Griffith Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- 41? > CIVIL TERM Richard L. Griffith, Jr. Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Crystal A. Griffith, Plaintiff, to proceed in forma ap uperis. I, Melissa P. Greevy, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Melissa P. Greevy, Esquire Attorney for Plaintiff Johnson, Duffle, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 (717) 761-4540 C g:: f r ' ? 2 r -° r r w Do CRYSTAL A. GRIFFITH, Plaintiff V. RICHARD L. GRIFFITH, JR., Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4163 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE TO REINSTATE Kindly reinstate the Divorce Complaint filed on July 14, 2008 in the above-captioned action. Date: D By: rystal A. Griffith ACV :341701 i . co ,v, CRYSTAL A. GRIFFITH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 08-4163 V. CIVIL ACTION - LAW RICHARD L. GRIFFITH, JR., JURY TRIAL DEMANDED Defendant ACCEPTANCE OF SERVICE I, RICHARD L. GRIFFITH, JR., hereby accept service and acknowledge receipt of the Complaint in Divorce filed on July 14, 2008 and reinstated on nt . o? by the Plaintiff in the above-captioned divorce action. Y BY: J?). 4 d I i tbb? A& .0 A_.? _ RICHARD . GRIFFiT R. Date: , 2008 :341695 ?? `-n "= ? ? i S,..a ?' f "'4 1 -? -^? ? '? CRYSTAL A. GRIFFITH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 08-4163 RICHARD L. GRIFFITH, JR. CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 14, 2008 and reinstated on September 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. 1 consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce with out notice. 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 above 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: 111,2/c)q CRY TAL A. GRIFFITH lfl ? ? ? ? ?r-' ? ? ? ? 5 ? ?? t P ? L". ..,- ?r', ?{ ? 4?^? ? {?'; [?a ..? N CRYSTAL A. GRIFFITH IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : vs. No. 08-4163 RICHARD L. GRIFFITH, JR. CIVIL ACTION - LAW IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 14, 2008 and reinstated on September 8, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. 1 consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 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 of Divorce with out notice. 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 above 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: lll Z) J RICHARD-L. RIFFI H, 73 Lpp [ . V CRYSTAL A. GRIFFITH, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . V. NO. 08-4163 RICHARD L. GRIFFITH, JR. CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of divorce decree: 1 • Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Acceptance of Service dated September 26, 2008, filed October 3, 2008. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff on January 12, 2009, by Defendant on January 12, 2009. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was signed on was January 12, 2009 and was filed with the Prothonotary on January 13, 2009. ry Date Defendant's Waiver of Notice in § 3301(c) Divorce was signed on was January 12, 2009 and was filed with the Prothonotary on January 13, 2009. Date: 4S Q 355518 By:dV YS AC TAL L A. GRIFFITH p -UC1 -- cp IN THE COURT OF COMMON PLEAS OF CRYSTAL A. GRIFFITH, CUMBERLAND COUNTY, PENNSYLVANIA V. RICHARD L. GRIFFITH, JR. NO. 08-4163 DIVORCE DECREE AND NOW, ? J% I , O?1 it is ordered and decreed that CRYSTAL A. GRIFFITH plaintiff, and RICHARD L. GRIFFITH JR. defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendent elite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None Attest: J. e2 Prothonotary , Ap i .; ?? ? 4k