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HomeMy WebLinkAbout09-0751 JASON R. GROVE, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - CIVIL TERM BARBARA J. GROVE, Defendant CIVIL ACTION-LAW 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 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, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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. 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 AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 i JASON R. GROVE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - CIVIL TERM BARBARA J. GROVE, CIVIL ACTION-LAW Defendant DIVORCE COMPLAINT 1. Plaintiff is Jason R. Grove, an adult individual who currently resides at 573 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Barbara J. Grove, an adult individual who currently resides at 1010 Northfield Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 11, 2004 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: c ael . Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: 05? Jason R. Grove ?} AJ C^'• ? rte, " t , r ? l ? , Ti - y r c JASON R. GROVE, Plaintiff V. BARBARA J. GROVE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009 - 751 CIVIL TERM CIVIL ACTION-LAW PROOF OF SERVICE 1, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card. DATE: February 17, 2009 fit Osrr?pteb? tgirns 1, Mwn 4 if Rast+fa?sd Datsry is, +pd. • P* t your rw . sW addms on ftte raw w w oud we can rotwn the card to you. s Aft d Oft card to the back of the ffm%A oe, or on the frr>rtt If space pwnfts. 1. Artlds addressed to: 5 .j. aMV.' to I b NORArfwd t)pj VU O'BRIEN, BARIC & SCHERER M c el cherer, Esquire - \ o Ag" fA D M by(t'IlntedName) a of ad- o. is d*.wy address from Fwn 1? r+se If YES, ,m *w d*my e& en Wow: ? No 10 Cetdw Me E3 Me 13 Rspfelsn I C] PAW R90W fbr MewhwWbe C] k=md MO ? COD. a. ResMcesd taefwerYt 0" Fier Ov! 4'Av0ds4hWAw 7008 0150 0001 8366 4995 tlourerMclbler?rR in toe to wtsre r-a JASON R. GROVE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 -751 CIVIL TERM n ~ _ BARBARA J. GROVE, CIVIL ACTION-LAW Defendant rfi,r,-; ~ ~: ~:,~~ .~:_ - .~~ -y ... ~_ "T"j i ~ (~ :. -..:7 ~_.... NOTICE TO DEFEND AND CLAIM RIGHTS ~=- - ~° = =~~~ -- .. ._/ You have been sued in court. If you wish to defend against the claim>~et forth ~~' in the following pages, you must take prompt action. You are warned that if you f~l 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, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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. 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 AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 JASON R. GROVE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009 - CIVIL TERM BARBARA J. GROVE, CIVIL ACTION-LAW Defendant AMENDED DIVORCE COMPLAINT 1. Plaintiff is Jason R. Grove, an adult individual who currently resides at 573 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. Defendant is Barbara J. Grove, an adult individual who currently resides at 5216 Royal Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 11, 2004 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. In the alternative, Defendant has offered such indignities to the Plaintiff as to make his life burdensome and condition intolerable. 8. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in Counseling. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARK & SCHERER Date: ~~~1~~° Michael A. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Amended Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: ~ 9 /v Jason R. Grove CERTIFICATE OF SERVICE I hereby certify that on June `l , 2010, I, Lori Duncan, of Baric Scherer, did serve a copy of the Amended Divorce Complaint, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Barbara Grove 5216 Royal Drive Mechanicsburg, PA 17055 L. ~-- ri Duncan JASON R. GROVE, v. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA BARBARA J. GROVE, Defendant NO. 2009 - 751 CIVIL TERM CIVIL ACTION-LAW PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 11, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: ~~9~/y c-~ ~ .>> T~ Jason R. Grove ~ --+ "U t1~ ` ~ ~ _~, -i-c z rfF ! ! 2_ ".:~ . ~ f.:.. i ~ ~ t ~ 4,.y (~~~ - ^ ~` W L~..~~f = t~ ~ -z ~ ~ a:. ~~ JASON R. GROVE, Plaintiff v. BARBARA J. GROVE, Defendant ~_~ -_.--5 - -- G? .~1 :"1 IN THE COURT OF COMMON ~-.EAS~F f ",` CUMBERLAND COUNTY, PEN~SYLV.QNIA ~ `= =. NO. 2009 - 751 CIVIL TERM ~- c { -~ CIVIL ACTION-LAW w 0 0 DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 11, 2009. 2. Defendant acknowledges receipt and accepts service of the Complaint on February 13, 2009. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: Barbara J. Grove JASON R. GROVE, v. Plaintiff C~ C~ ~ r;l IN THE COURT OF COMMON PL~~iS O.~ ~~' CUMBERLAND COUNTY, PENNS~'t_VANr~ '__ .' ~; ~~OO~~'' Gi (a NO.z~998~- 751 CIVIL TERM - ~" ~ - IN DIVORCE _ ` '' w :: . C~- -_- Cr ~ 0 BARBARA J. GROVE, Defendant NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff in the above matter, hereby elects to retake and hereafter use her previous name of Barbara J. Murphy. / prior to the entry of a Final Decree In Divorce or after the entry of a Final Decree In Divorce dated and gives this written notice avowing her intention pursuant to the provisions of 54 P.S.A. 704. Dated: `~ Barbara J. Grove TO BE KNOWN AS Barbara J. Murphy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the~~~ day of , 2010, before me, a notary public, personally appeared Barbara J. Grove to a wn as Barbara J. Murphy, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and ofi'icial seal. COMMONWEALTH OF PENNSYLVANIA Noharial Seal Jerxrfer S. Lindsay, No~ry Publ~ Carlisle eoro, Gmbedand coixdy My Conxn~ion Fires Nov. 29.2011 Member, Pennsylvania Aasoclation of Notarlee $Il.oo Pp A'I'1'y C~' I (i95(o ,~ar~loas 1 JASON R. GROVE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0. 09 - 751 Civil BARBARA J. GROVE, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ~~ day of L(iLC, , 2010, no economic claims having been raised in the proceedings and the parties having executed affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can be concluded under Section 3301(c) of the Domestic Relations. Code, the appointment of the Master is vacated. BY THE COURT, ~~ Kev' A. Hess, P.J. cc: /Michael A. Scherer Attorney for Plaintiff ~ Barbara J. Grove ~-~ Defendant ~-~- ~ T_~ ~_ I~~~ - -T, ~~ES rYtct [~, ,., L` ' ~- ~ _ ~ ~_ -_ JASON R. GROVE, Plaintiff Vs. BARBARA J. GROVE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA fc_~ ^; \_:, _. , ;. CIVIL ACTION -LAW '~~ `~ C.' ~r_T NO. 2009-751 ~- IN DIVORCE _ ~~ PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: ~. ~' ;~ .W -~; ~4 ~ ': Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant was served by certified mail on February 12, 2009. 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: by Plaintiff on June 6, 2010; and Defendant on Juty 30, 2010. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiff s Affidavit upon the Defendant: N/A 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: None served as the parties signed the Waiver of Notice. Defendant on July 30, 2010 and Plaintiff on June 6, 2010. Respectfully submitted, Mi a c erer, Esquire JASON R. GROVE ; V. BARBARA J. GROVE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2009-751 NO. DIVORCE DECREE AND NOW, ~.~Y /~ 20 r0 , it is ordered and~decreed that JASON R. GROVE plaintiff, and BARBARA J. GROVE ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite 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 By the Cpurt, s ~ i ~ • 10 ~+. coq m~,.~ (ed -tv A-rt~ g• I~• l o ~a~. mcx;led ~-o i~~..