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Home My WebLink About10-0540 N C=D JANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 ? ;? s 17 W. South St. - Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com FAWN K. GREENFIELD, Plaintiff vs. BRIAN T. GREENFIELD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. (-B Civil Term : ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 W 34 77? 1ANE ADAMS ATTORNEY AT LAW Attorney I.D. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 esgadams@gmail.com FAWN K. GREENFIELD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. l Q Pb) Civil Term BRIAN T. GREENFIELD, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Fawn K. Greenfield, a competent adult individual, who resides at 212 Sagamore Hill, Mount Joy, Lancaster County, Pennsylvania, 17552. 2. Defendant is Brian T. Greenfield, a competent adult individual, who resides at 25 E. Main St., Walnut Bottom, Cumberland County, Pennsylvania, 17266. Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on August 7, 1999 in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. N 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: l(? ne Adams, Esquire No. 79465 17 West South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -Respectfully submitted, A 1ANE ADAMS ATTORNEY AT LAW Attorney LD. No. 79465 17 W. South St. Carlisle, Pa. 17013 (717)245-8508 FAWN K. GREENFIELD, Plaintiff vs. BRIAN T. GREENFIELD, Defendant BLED-Ot=~=iG'~ 20lDFEB -S PrM 2= 49 CUiV::.JI.C',..'' ~..J ~~~~..ll.li~tl IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 10 - 540 Civil Term ACTION IN DIVORCE CERTIFICATE OF SERVICE I, Jane Adams, Esquire, do hereby certify that on February 3. 2010, I served a true and correct copy of the NOTICE TO DEFEND and DIVORCE COMPLAINT, in the above-captioned matter upon the following individual(s) by .certified mail, restricted, return receipt requested, addressed as follows: Brian T. Greenfield 25 E. Main St. Walnut Bottom, Pa DEFENDANT ^ Complete Items 1, 2, and 3. Also complete 17266 item 4 'rf Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or ~ the front if space permits. Addressed to: . ~~,c~~ (:ce~,Gel~ ~S G mRm`~- ~\n~I 6oi~u ~fl,.. A. Sfgnatur~ x ~_ ^ AeeM B. Received by (Printed Name) C. Date of Delivery ~ of l~` D~' D. Is delivery address different from item 11 ^ Yes If YES, enter delivery address below: ^ No 3. Service lyps CertlBsd MaN ^ Exp~es Mall ^ Regle6xed ^ Ral+rn Firaoeipt for Merchandise _ ^ Insured MsA ^ C.O.D. 4. Restricted Deliver~R (Extra Fw) ~ Yes 2. Article Number 7 D 0 9 2 8 2 0 0 0 0 2 210 3 214 9 (Transfer from service /abeQ - PS Form 38~ 1, February 2004 Domestic Retum Receipt 1o2e~-~¢-M-tta~ Respectfully Subm ,d'an Adams, Esquire I.D. No. 79465 17 est South St. rlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF FAWN K. GREENFIELD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVA vs. No. 10 - 540 Civil Term r, - BRIAN T. GREENFIELD, ACTION IN DIVORCE 4N Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on January 25, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 1 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. i ? Date: KL4'4-? rian T. Greenfield, Defendan WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) AND &3301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 1 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. 3. 1 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. 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. §4904 relating to unsworn falsification to authorities. Date: 0-?j v 1 Brian T. Greenfield, Defend t FAWN K. GREENFIELD, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVgYIA C= vs. No. 10 - 540 Civil Term, n4rn -0 z? ?' BRIAN T. GREENFIELD, ACTION IN DIVORCE ?7?, r*t-- -vrn a Defendant r-?= °?' c r-D PRAECIPE TO TRANSMIT RECORD c -; 4 - N 2'' TO THE PROTHONOTARY: Please accept this request to transmit tie record; together with the following information to the Court for entr of a di D , y vorce ecree: 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and Manner of the service of the Complaint: sent to Defendant via first class mail, certified restricted, return receipt requested Defendant signed receipt on February 3. 2010. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: March 10. 2011 By Defendant: March 10, 2011 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: March 16, 2011. 6. Date Plaintiffs Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: March 24. 2011. Respectfully submitted, Date: J e Adams, Esquire 1 No. 79465 17 W. South St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF FAWN K. GREENFIELD, CUMBERLAND COUNTY, PENNSYLVANIA. V. BRIAN T. GREENFIELD, : NO. 10 - 540 Civil Term DIVORCE DECREE ,T!/:3)g.rh. AND NOW, it is ordered and decreed that FAWN K. GREENFIELD, , plaintiff, and BRIAN T. GREENFIELD, bonds of matrimony. defendant, are divorced from the 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; the marriage settlement agreement which was filed on March 24, 2011 shall be incorporated and not merged into this Decree. By t ourt, Attest: J. Prothonotary AAwris q/j.Sjtr • (pert 0,0Pyy mailed iv fiJtu Nwoe,