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HomeMy WebLinkAbout08-4166 Elizabeth G. Grimes IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- y/?G CIVIL TERM Thomas E. Grimes 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 Elizabeth G. Grimes IN THE COURT OF COMMON PLEAS;OF. Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- Y/4r4 CIVIL TERM Thomas E. Grimes Defendant IN DIVORCE COMPLAINT U^NDE/R+$3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is E aabP h who currently resides at s' r lAP& 65 r 'Fi Ca r %2)k ?a l ^I 013 -11"1 Cumberland County, Pennsylva?n!ia?., 2. Defendant is-1 I/10YY1Qg ?, l?(i q1C S , who currently resides at as P4brA,&?rILj ?r4t? 1? ?151©.?at a 1-1c? 1 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 R ?5V 1 r q9y at U A 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. MjU )q. aoox I , I I-A? - 4A- Date' Plai i , Pro Se L 8 ZLth& - lyn- TV-S , 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 authori'ti'es' `as provided in 18 Pa. C.S. §4904. -7?6 Date: Plaint'() Pro Se Assiste by: Melissa P. Greevy, Esq. Johnson, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 (717) 761-4540 Elizabeth G. Grimes IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- CIVIL TERM Thomas E. Grimes Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on,, V(Amodl 2-001 and continued to live separate and apart for a period of two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I, E ZQbe41 Cam. hn S , verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand't`hat false statements made herein are subject to the penalties for unsworn falsification to` authondes as provided in 18 P.S. Section 4904. Date Pla' t ff, Pro Se Elizabeth G. Grimes IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- CIVIL TERM Thomas E. Grimes Defendant IN DIVORCE 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 no ,r, 3 C0 CJi < Elizabeth G. Grimes Plaintiff V. Thomas E. Grimes Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- W& CIVEL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Elizabeth G. Grimes, Plaintiff, to proceed in forma au eris. I, Melissa P. Greevy, attorney for the party proceeding in forma au eris, 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, Duffie, Stewart & Weidner 301 Market Street Lemoyne, PA 17043 (717) 761-4540 (`3 "?' 4 ° ? ? ? ?.. ?-r,,, c.._ ? :? . r-~ :? G? "' ? ??_ ?? ?„ ??-: ? ,_ ? ,; ?? M.I ?? Elizabeth G. Grimes IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08-4 / b(g CIVIL TERM Thomas E. Grimes Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Thomas E. Grimes (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date writtep,below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4004, relating to unsworn falsification to authorities. Date Thomas E. Grimes, Defendant °? -s? . ? ?? ?? ?. ..-- = . ?_ ?- .{ "'?. .fit ? -S '?" ..?: :?4 ?.r ELIZABETH G. GRIMES, Plaintiff vs. THOMAS G. GRIMES, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-4166 CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF 4 3301(d) DIVORCE DECREE To: Thomas E. Grimes You have been sued in an action for divorce. You have failed to answer the Complaint or file a counter-affidavit to the § 3301(d) Affidavit. Therefore, on or after August 25, 2008, the other party can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court and answer with your signature notarized or verified, or a counter-affidavit by the above date, the Court can enter a final decree in divorce. A counter-affidavit, which you may file with the Prothonotary of the Court is attached to this Notice. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS ATA REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013 ti Date:U 2 O S By: ` Eliz eth G. Grimes Elizabeth G. Grimes Plaintiff V. Thomas E. Grimes Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA No. 48- 4t, b CrvILTERM IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ? (a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): ? (i) The parties to this action have not lived separate and apart for a period of at least two years. ? (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): ? (a) I do not wish to make any claims for economic relief. 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. ? (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.. §404 relating to unsworn falsification to authorities. DATE: Thomas E. Grimes NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. . f I4- CERTIFICATE OF SERVICE AND NOW, this ' day of , 2008, the undersigned does hereby certify that she did this date serve a copy o the Counter Affidavit Under Section 3301(d) of the Divorce Code and Notice of Intention To Request Entry Of § 3301(D) Divorce Decree upon the Defendant record by causing same to be deposited in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Thomas E. Grimes 20 North Chestnut Street Dillsburg, Pennsylvania 17019 By: F,W.a 144'111W Eliz th G. Grimes C? ? `__7 _Tl ?1 ?: r?} -r.? '• _',.. .rt_ I r,?Z .. ?.,.i r,....,J r ELIZABETH G. GRIMES, Plaintiff V. THOMAS G. GRIMES, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: NO. 2008-4166 CIVIL ACTION - LAW IN DIVORCE Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: July 15, 2008, via Acceptance of which return of service was filed on July 15, 2008. 3. Complete either Paragraph (a) or (b). (a). Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: (b) (1) Date of execution of the Plaintiff's affidavit required by § 3301(d) of the Divorce Code: July 14, 2008 (2) Date of filing and service of Plaintiff's affidavit upon the Defendant: Date of Filing: July 14, 2008; Date of service upon respondent: August 4, 2008, 2008. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 4. Related claims pending: No economic claims raised. 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: August 4, 2008 service via United States mail addressed to the Defendant at his home address Copies of the Notice of Intention to file Praecipe and Counter Affidavit sent to Defendant with certificate of service are attached hereto. Date: ?'( O By: Alka-? - E ' beth G. Grimes :343141 4 c*s P ?r C6- y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ELIZABETH G. GRIMES VERSUS THOMAS E. GRIMES NO. 08-x+166 Civil Term DECREE IN DIVORCE o- /: 01 ?f- . 01. AND NOW, 2008 , IT IS RDERED AND DECREED THAT ELIZABETH G. GRIMES AND THOMAS E. GRIMES 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 ATTEST: J. PROTHONOTARY ?? ?/ •6 00,