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HomeMy WebLinkAbout02-0878BRIAN J. GROSS, Plaintiff DEBOROH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 0~--o07~ 2OOl 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 pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland Coumy Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 BRIAN J. GROSS , : Plaintiff : V. ; DEBORAH L. GROSS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2001 CIVIL ACTION - LAW IN DIVORCE NOTICIA Le hah demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o pot abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y pot cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros detechos importames para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 C: \Corel\Suite8\wpdocs\domestic\Gross\Complaint.wpd BRIAN J. GROSS, Plaintiff DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CIJMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW IN DIVORCE COMPLAINT AND NOW, comes Plaintiff, by his attorney, Richard C. Rupp, and files this Complaint in Divorce, based upon the following: 1. Plaintiff, Brian J. Gross, is an adult individual residing at 214 North Walnut Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant, Deborah L. Gross, is an adult individual residing at 909 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at lease six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 12, 1982 in Camp Hill, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the Parties. 6. Plaintiff and Defendant are both citizens of the United States of America. 7. Defendant is not a member of the Armed Services of the United States of America. 8. Plaintiff avers as the grounds on which this action is based are that the marriage is irretrievably broken. 9. Plaintiff avers that there are two (2) children born or adopted of the Parties under the age C:\Corel\Suite8\wpdocs\domestic\Gross\Complaim.wpd of 18. 10. Plaimiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the Parties participate in counseling. 11. Plaintiff and Defendant separated on September 2000. 12. Plaintiff asks the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce dissolving the marriage between Plaintiff and Defendant and such further relief as the Court may determine equitable and just. Respectfully submitted, Richard C. Rupp / - VD Attorney I.D. No.:134832 ' ' 355 North 21st Street, Suite 205 Camp Hill, PA 17011 (717) 761-3459 Attorney for Plaintiff C :\Corel\Suite8\wpdocs\domestic\Gross\Complaint.wpd VERIFICATION I, Brian J. Gross, verify that the statements in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. BRIAN J. fR(SSS Date: r BRIAN J. GROSS, Plaintiff V. DEBORAH L. GROSS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-00878 Gq r~ : CIVIL ACTION - LAW ~'~ii ~ : IN DIVORCE ~' .-~'~:: COUNSELING AFFIDAVIT © 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. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. 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. Section 4904 relating to unsworn falsification to authorities. Date: DEBORAH L. GROSS, Defendant BRIAN J. GROSS, Plaintiff ¥. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-00878 CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 20, 2002. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. I 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 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: r~ DEBORAH L. GROSS, Defendant BRIAN J. GROSS, Plaintiff ¥. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-00878 CIVIL ACTION - I~AW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODr 1. I consent to the entry of a final Decree of Divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 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 if 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 subiect to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: DEBO'I~H L. GROSS, Defendant BRIAN J. GROSS, Plaintiff V. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-00878 : CIVIL ACTION - LAW : : IN DIVORCE ACCEPTANCE OF SERVICE I, KEITH O. BRENNEMAN, ESQUIRE, attorney for the Defendant, DEBORAH L. GROSS, in the above referenced Divorce Action, do hereby accept service of the Complaint in Divorce on her behalf. Keith O. Brenneman, Esquire Snelbaker, Brenneman & Spare 44 West Main Street P.O. Box 318 Mechanicsburg, PA 17055 717-697-8528 DATE: BRIAN J. GROSS, Plaintiff ¥. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-00878 CIVIL ACTION - LAW IN DIVORCE COUNSELING AFFIDAVIT 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. I understand that the Court maintains a list of marriage counselors in the Domestic Relations office, which list is available to me upon request. 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. Section 4904 relating to unsworn falsification to authorities. Date: B~intiff BRIAN J. GROSS, Plaintiff V. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-OO878 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 20, 2002. 0 The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. o I 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 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: B~aintiff BRIAN J. GROSS, Plaintiff ¥. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-00878 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 {C) OF THE DIVORCE CODI: 1. I consent to the entry of a final Decree of Divorce without notice. 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. 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 if 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. Section 4904 relating to unsworn falsification to authorities. Date: /~//~J~ [0,-~. R~'" t B ntiff BRIAN J. GROSS, Plaintiff V. DEBORAH L. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-00878 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under (X) Section 3301 (c) ( ) Section 3301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: 07/11/02 Acceptance of Service 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, 08/14/02 ; by defendant, 07/21/02 (b)(1) Date of execution of plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (b)(2) Date of service of plaintiff's affidavit up~'~'~ 4. Related claims pending: Date: August 15, 2002 Richard C. ~upp,/l~s~ire Rupp & Meikle, I~.C. Attorney I.D. #34832 355 North 21st Street, Suite 205 Camp Hill, PA 17011 (717) 761-3459 Counsel for Plaintiff IN THE COURT OF OF CUMBERLAND COMMON COUNTY STATE OF ~ BRIAN J. GROSS Plaintiff Versus DEBORAH L. GROSS .................................... D~en~nt ................ PLEAS PENNA. No ........ 9.~z~Ta ................. DECREE IN · AND NOW~/~r.~....~...l~l~l"~'~ ........... ...0p.2.. it is ordered and decreed that ......,~t.x..i~...J.:..G.~.O.S.S. ............................ plaintiff, and ............... P~..~9..m3~....~....~..~9.s.s. ........................ defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; NON'R ................. / ~ fie Prothonotary