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HomeMy WebLinkAbout09-1077DAVID A. GREGORITS, Plaintiff V. MARY D. GREGORITS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 09- l0`1r7 O-iyil T&r. CIVIL ACTION - LAW IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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, One 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 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 on elly, Jr., Esquire for Plaintiff i DAVID A. GREGORITS, Plaintiff V. MARY D. GREGORITS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :NO. 0 9 -/0 7 7 ? -72.- CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant 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 decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, 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. Prothonotary DAVID A. GREGORITS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA MARY D. GREGORITS, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is David A. Gregorits, who currently resides at 3002 Market Street, Apartment 4, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Mary D. Gregorits, who currently resides at 3607 Hillcrest Road, Harrisburg, Dauphin County, Pennsylvania 17109. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 9, 1980, in Middletown, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. The parties to this action have been separated since June 13, 2003. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. This action is not collusive. WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant. Dated: 01- 19 - 0 1 By: Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP ??aa J , Jr. A rney ?nnel 15615 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff David A. Gregorits VERIFICATION I, David A. Gregorits, verify that the statements made in this Pleading are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Date: 9-t 9-01 David A. Grego ' s W V ..C D by u _: DAVID A. GREGORITS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-1077 MARY D. GREGORITS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN : ss. AND NOW, this 26th day of February, 2009, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Divorce Complaint was served on the Defendant, Mary D. Gregorits, on February 25, 2009, by certified mail number 7008 1300 0001 8217 5270, as evidenced by the return receipt card attached hereto and made a part hereof. #- - so - J i!!!ly, Jr., Esq 're Sworn to and subscribes before me this o1( day of February, 2009. 0_1e? ??d Notary Public Notarial Seal Maria B. LaRue, Notary Public Derry Trap., Dauphin County MY Commission Expires Nov. 8, 2008 Member, Pennsylvania Association of Notaries WIMWJMViWM- 1. 40-O Aim ROA -x lkwn 4 # RMdia¦d 0dwy le deaksd. X ¦ P* t your nwn an r d mi rlrs?s art ttwisva?m. so WW vm can Mum the cod to you, ¦ 141doh cod to tlwe beck of the mm" wk a RewMd (PMMrd C. D11% d tJ?tiwry or an thsftrit N apace pates 1. Mids Adtfw?W to D. Mddirwyd??adtiwwatilomtiMnl4 Yea H YES, ~ d*4wy addle bdow D No Pf P) ts. or-A-S % w 0 ~#" O l mud b Cl irptrl O fawn itp 1011bl AlnehlritIB M ClbMnd#Ad Q C4U ?? o C s ? - l' 4.filiU * t]~OftFSO 2 Allim" 7000 1300 0001 - , ! C3 .. ti Ln r- F -OF F r cc Postage A CerBBed Fee C3 C] RO Recut Fee 4 (EndorgertM 1 RegWred) Deftwy Fee O m r-I Total Postage & Fees co ?-,enr ro C3 or P?O? Ills.?L? w : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID A. GREGORITS v. MARY D. GREGORITS NO. 09-1077 DIVORCE DECREE ~-- ~ ~ ,SD G ' rv- , AND NOW, ~ , ~~~ , it is ordered and decreed that DAVID A. GREGORITS ,plaintiff, and MARY D. GREGORITS 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.") The parties' Marital Settlement Agreement dated March 29, 2010 is hereby incorpora e u no merge , in o is ecree in ivorce. the Court, ~-(~ $ ~ I d Ge~c--a-. c~~ t`~1a~ 1 ed ~-- ~ $ ~ ~ O ~ crli cam. t'~lcc.~ \ed ~ ~~~e,C