The URL can be used to link to this page

Home My WebLink About01-4721FRANCES H. DE1 DUCA ATTORNEY AT LAW TEN WEST HIGH STREET CARLISLE. PENNSYLVANIA '17013 JUDITH A. GRYZMSKI V. GERALD A. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. ~9/./_tr~j// CIVILTERM :: :: 1N 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 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, CARLISLE, PENNSYLVANIA, 17013 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 717-249-3166 Frances H. Del Duca 10 West High St. Carlisle, PA 17013 Dated: JUDITH A. GRYZM§KI V. GERALD A. GRYZMSKI :: IN THE COURT OF COMMON PLEA§ :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. ZSy/._z/7~/ CIVIL TERM :: 1N DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE COUNT I - DIVORCE 1. Plaintiff is Judith A. Gryzmski, who resides at 1513 Hemlock Avenue, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Gerald A. Gryzmski, who resides on East South Street, Carlisle, Cumberland County, Pennsylvania, 17013, with a mailing address of P.O. Box 1354, Carlisle, Pennsylvania, 17013. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. The plaintiff and defendant were married May 22, 1965 in Nanticoke, PA. There have been no prior actions of divorce or for annulment between the 5. parties. 6. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. COUNT II - EQUITABLE DISTRIBUTION 7. Plaintiff and defendant are the joint owners as tenants by the entireties of real estate and various items of personal property, furniture and household furnishings acquired during the marriage which are subject to equitable distribution by this Court. COUNT III - ALIMONY, ALIMONY PENDENTE LITE 8. Plaintiff does not have sufficient funds to support herself. COUNT IV - COUN~II~L FEE~g AND CO~gT§ 9. Plaintiff does not have sufficient funds to pay counsel fees and expenses incidental to this action. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree: B. C. D. Dissolving the marriage between plaintiff and defendant; Equitably distributing all property owned by the parties hereto; Directing defendant to pay alimony, alimony pendente lite; and Directing defendant to pay counsel fees and expenses of this proceeding. Dated: Frances H. Del Duca Attorney for Plaintiff 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 10 Pa.C.S. Sec. 4904 relating to unsworu falsification to authorities. Dated: c'"'~dith A. Gry~rhsl<i /?' - JUDITH A. GRYZMSKI V. GERALD A. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 01-4721 CIVIL TERM :: :: 1N DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ] ~q day of August, 2001, I hereby acknowledge receiving a copy of the Complaint in Divorce filed to the above term and number at the office of Richard P. Wagner, Esquire, 2233 North Front Street, Harrisburg, PA, 17110. "Gerala A. Gvfzm-sk~J/ ' SUBSCRIBED and sworn to before me this _l~2~'d~y of Augnst, 2001. Notary Public (/- I Notarial $~ Emily A. Wl~e, I~ Pub#c Ha .rr~.rg, Dauphin County ~My CemmJsa~o~ Expires May ~9, 2OO,3 r~e.~ber, PennsyNanla Assoc/atlon of Notarfes ~. GRYZMSKI .rUDITH , Vo GER_NLD/~ .~. GRYZMSKI :: IN THE COURT OF COMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA · . NO. 01-4721 CIVIL TERM oo .. IN DIVORCE INVENTORY OF JUDITH A. GRYZMSKI Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was ccramenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Defendant understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. ~/~ Judith A. £iryzms~cr MARITAL PROPERTX o Real Estate 1513 Hemlock Avenue, Carlisle, PA Pensions/Insurance- p--ennsylvania State Retirement System (Husband) - monthly gross Life Insurance - Provident Mutual Life - monthly premium $339.15 IRA- Orrstown (Wife) (total amount) Vehicles 1995 BMW - wife 1996 Monte Carlo Bank Accounts Orrstown Bank - Joint "tax account" Joint Savings Cornerstone Federal Credit Union - Wife//5141 Husband//5548 Mellon Bank - 192-422-2225 - Joint Checking Mellon stock (Wife) - 205-102-58551Al0 - 52 shares Household Furnishings and Personalt~ Pearson traditional sofa/love seat Queen Anne chair Howard Miller floor clock $ 100,000.00 3,211.70 3,321.59 Thomasville oval coffee table,.dr0p le.af table, commode table 2 Stiffel lamps Bombay table and lamp Secretary by Wells w/State Police memorabilia 1 oil painting 2 Baldwin brass sconces/4 Baldwin candle sticks 2 antique dishes Custom draperies Wall arrangement above fireplace Kitchen TV Toaster Coffee pot Breadbox Radio Dishes Pots Pans Cookie sheets Antique dishes Dining Area Dining room table, chairs, hutch w/china, crystal Antique smokestand/washstand Antique dishes on hutch Doiles made by grandmother Bedroom French Provincial chest of drawers Dresser w/mirror Commode table Nightstand Brass queen bed Queen Ann chair 3 lamps Television Den TV VCR Bombay television/VCR table Antique rocker Table 2 lamps 2 recliners Wall clock Pictures Dried arrangement Bedroom Desk and hutch Lamp Hall Table and mirror Bombay Pictures 7.(a) Wreath ' Basement Washer and dryer 2 recliners 2 lamps Triple Dresser Furnishings and personalty - In possession of husband from basement sitting room Sleeper sofa End table TV and stand Floor lamp Table and chairs Towels Dishes Silverware (his mother's) Dish towels Odds and ends Computer Non-Marital Bedroom suite (bed, dresser, cedar chest, chest of drawers) Inheritance from Mother LIABILITIES Real Estate As of 5/20/03 credit line at Mellon Installment Sale 19,000.00 15,000.00 (b) Personal Bon Ton - joint Sears - joint Car insurance State Credit Card/PSECU PSECU loan VISA Capital One 1,000.00 Pd. 220.00 Pd. 251.00 5,162.92 1,212.00 3,384.00 (3 mos.) Husband as of 5/03 - 1,800.00 as of 1/22/03 - 2,238. Pd. Summer 2002 Wife as of 5/03 - 1,800. Fleet Bank (husband) Citibank (husband) Verizon (husband) 8,467.00 2,500.00 309.00 The above joint liabilities were being paid by Wife from deposits in joint account from Husband's State pension. The monthly deposit is $2,845. MONTHLY 552.00 (2 loans) (150.00 per month) (50.00 .... ) 150.00" " (60.00" ") JUDITH A. GRZYMSKI LIVING EXPENSES AS OF MAY 2003 Mortgage Loans Pool Awnings Yard (flowers) Furnace maintenance Taxes Insurance Propane Phone PP&L Oil Water & Sewer Cable TV Papers Auto Insurance Life Insurance Car maintenance Gas/Lunch Medical Prescriptions Counseling Clothing Food Haircut Credit cards Vacation Health Club Dog - Vet/Groom MONTHLY 267.65 248.00 33.75 4.00 12.50 12.50 44.46 100.40 23.50 5.30 56.50 67.00 51.09 26.33 42.00 25.00 64.75 339.15 29.16 60.00 20.84 38.08 8.33 60.00 208.00 250.00 50.00 300.00 66.67 20.83 45.00 YEARLY 3,211.80 2,976.00 405.00 48.00 150.00 15o.o0 533.52 1,204.80 282.00 63.60 678.00 804.00 613.00 315.96 504.00 300.00 777.00 4,069.80 350.00 720.00 250.00 457.00 100.00 720.00 2,496.00 3,000.00 600.00 3,600.00 800.00 250.00 540.00 Totals 2,580.79 30,969.48 JUDITH A. GRYZMSKI Vo GERALD A. GRYZMSKI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4721 CIVIL TERM IN DIVORCE INCOME REPORTED FOR 2002 Gerald Gryzmski - W-2 H & R Block Carlisle Hospitality LP State Employees Retirement System YEARLY 13,443.05 16,190.95 38,723.00 Judy Gryzmski - W-2 Waypoint Bank 17,664.06