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HomeMy WebLinkAbout09-3791Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) MICHAEL P. GRIFFITHS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW NICOLE S. GRIFFITHS, 09 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 against 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 with 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, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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 1 013 (717) 249-3166 BY Andrew C. Sheely, Es PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) MICHAEL P. GRIFFITHS, Plaintiff VS. NICOLE S. GRIFFITHS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - 3-291 IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) MICHAEL P. GRIFFITHS, Plaintiff VS. NICOLE S. GRIFFITHS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 0 9 - 32 4/ IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is MICHAEL P. GRIFFITHS, an adult individual who currently resides at 111 East Locust Street, Mechanicsburg, Borough of Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is NICOLE S. GRIFFITHS, an adult individual who currently resides at Lot #32, Regency Woods North Mobile Home Park, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married in Mechanicsburg, Pennsylvania, on June 16, 2001. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing and service of the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about May 11, 2009. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT II - DIVORCE - 3301(d) 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 2 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. Respectfully submitted, J! G??? Date: June 2009 Andrew C. Sheely, Esquire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 3 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 penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: June 2009 Aa fAa??) Michael P. Griffiths Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) MICHAEL P. GRIFFITHS, Plaintiff Vs. NICOLE S. GRIFFITHS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - 3? g> IN DIVORCE AFFIDAVIT Michael P. Griffiths, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. June ?? 2009 A4 Id ? ' Michael P. Griffiths 4), OF Tt, MiARY 2069 JUN -8 PM 2.52 f'EN"'SY' jvpdela 3?qi . r 6411 11 t 0-11 1700 F Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) MICHAEL P. GRIFFITHS, Plaintiff IN THE COURT OF COMMON PL AS OF CUMBERLAND COUNTY, PENNSY VANIA VS. NICOLE S. GRIFFITHS, Defendant CIVIL ACTION - LAW 09 - 3791 IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA . : SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon NICOLE S. GRIFFITHS, Defendant, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt card and United States Postal Confir ation Notice, on June 9, 2009. C. SWORN to and subscribed before me this / 0 1 day of June, 2009. Nota y blic My Commission Expires: WTAMSK t *f E?p"'19t 2010 d 1111111i?Pomplete items 1, 2, and 3. Mw W" e€ elved by fRease-Prim clearly) B. Date of D Nivery item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse C. Signature so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, ? Age L d it or on the front if space permits. ? Add 066 ressee ? 1 Article Addressed to: Yes D. Is delivery address differen Mom item 1? . If YES, enter delivery address below: ? No Nicole S. Griffiths RESTRICTED DELIVERY FOR ADDRESSEE ONLY Lot #32 Regency Woods North Mobile 3. Service Type ACertifiedMail ?ExpressMail Home Park ? Registered ? Return Receipt for Merch andise Carlisle PA 17015 ? Insured Mail ? C.O.D. , 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Copy from service label) 7 0 0 1 0 0000 3029 4862 PS Form 381 1 , July 1999 Domestic Return Receipt 102595-004 1-0952 ru -0 4- ?' 61G_ PA Postage $ °s man" rr p m Certified Fee JUN 8rk 0 Return Receipt Fee Here ?? 7 0 (Endorsement Required) , Ii??'?" C3 Restricted Delivery Fee C3 (Endorsement Required) U S rl O Total Postage 6 Fees $ - - - ti sent To cole S. Griffiths .5. TRI. ' .El) ---D.Z V •--•-••----------••••-... ,a C3 sheer, APL '.; or PO Box No. Lot #32,Regency ods North A??I I C3 ...... crry, srare, nP+a C a P r l i s l e, PA 1 1 c UPS -.Track & Confirm • ?: s Track tofu' http://trkcnfrmI.smi.usps.com/PrFSlntemetWeb/InterLabellnqui... Home I Help I Sign In Track 8 Confirm FAQs Label/Receipt Number: 7001 2510 0000 3029 4862 Class: First-Class Maii® Tfack & COU&M Service(s): Certified Mai1TM Enter Label/Receipt umber. Restricted Delivery Return Receipt Status: Delivered' ' Your item was delivered at 11:53 AM on June 9, 2009 in CARLISLE, PA 17015. Detailed Results: • Delivered, June 09, 2009,11:53 am, CARLISLE, PA 17015 • Notice Left, June 09, 2009,11:39 am, CARLISLE, PA 17015 • Acceptance, June 08, 2009, 6:01 pm, MECHANICSBURG, PA 17055 Iicomo . Track 8r Confirm by email Get current event information or updates for your item sent to you or others by email. > Site Map Customer Service Forms Govt Services Careers Privacy Policy Terms of Use Business Customer Gate Copyright© 2009 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA 1 of 1 6/10/09 11:25 AM Y 1 IL t i='?,i 2N9 ..4UA l f NI l: 4 8 Cup < < PEENNSYLVAINI1A