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HomeMy WebLinkAbout05-0283 (). ,. v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : OJ ~0283 : NO. - CIVIL TERM THOMAS R. GRUNDON Plaintiff SUT A TIP GRUNDON Defendant. :CIVIL ACTION - LAW : 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 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 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 Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE COMPLAINT AND NOW, comes the Plaintiff, Thomas R. Grundon, by and through his attorney, Kirstin M. Sweigard, Esquire, and files this Complaint in Divorce of which the following is a statement: I. The Plaintiff is Thomas R. Grundon, an adult individual residing at 2001 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Sutatip Grundon, an adult individual residing at 2001 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 11, 1982 in Lawton, Oklahoma. 5. No prior actions for divorce or annulment have been filed. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member ofthe Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and have been living separate and apart since July 2004, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully Submitted, Date: I//~I.! :.;- ~;2L1P"- 111ff7~ zd Ki stin M. Sweigar , Esq . re Supreme Court ID# 83801 P.O. Box 1168 Camp Hill, P A 17001 (717) 932-4646 Fax: (717) 932-3577 Attorney for Plaintiff VERIFICATION I veri1)r that the statements made in the foregoing Divorce Complaint 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. 7.rfJ hi tJ.5' Date G;)R~ eJ' ~ --, .....r1 C- " '"' <..f\ ~ ~ \ - ~ q ~:::; ~ ,...., .-;"~, ~:,;> "-" '-- C) ., ---l T.-r, i11F -n1~71 -nC; <':;(S ~.. ~ -r. '.:.-n ;:~~~ii -'--t -1;-' J-i ., --.,,,, ~...,. w -c:::. '--') O'~ 0)'- :2~'J, CIY.f DIVORCE SETTLEMENT AGREEMENT THIS DIVORCE SETTLEMENT AGREEMENT, made this jfft] day of January, 2005, by and between Thomas Grundon, (hereinafter "Husband"), and Sutatip Grundon, (hereinafter "Wife"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on March ] 1, 1982, in Lawton, Oklahoma; and WHEREAS, differences have arisen between HUSBAND and WIFE, the consequence of which they intend to live separate and apart from each other; and WHEREAS, HUSBAND and WIFE desire to settle and determine their property rights and obligations growing out of their marital relationship; WHEREAS, there were no children born ofthe parties' marriage NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree as follows: 1. Separation. The parties are currently and have been living separate and apart since July 2004, and will not cohabitate with each other. It shall be lawful for each party at all times hereafter to live separate and apart from each other at such a place or places as he or she may from time to time choose or deem fit. 2. Interference. From the date of signing this Agreement, each party shall be free from interference, authority and control of the other, as fully as ifhe or she were single or unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or compel the other to cohabitate with the other or in any way harass or malign the other, or in any other way interfere with their peaceful existence, separate and apart from the other. 3. Mutual Release. Subject to the provisions contained in this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, forever release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except a cause or causes of action for divorce or all causes of action for breach of any provisions of this Agreement. Further each party, subject to the provisions of this Agreement, releases and forever discharges the other from any and all claims one may have against the other arising out of this matrimonial action, including, but not limited to alimony, alimony pendente lite, spousal support, equitable distribution, counsel fees, costs and expenses. 4. Waiver of Claims A2ainst tbe Estate. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future law of any jurisdiction to share in the property or the estate ofthe other as a result of the marital relationship, including, without limitation, dowry, courtesy, statutory allowance, widow's allowance, homestead rights, right to equitable distribution, rights to take in intestacy, right to elect against the will of the other, and right to act as administrator or executor of the other's estate. Each party will, at the request of the other, execute, acknowledge and deliver any and all instruments that may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 5. Division of Real Property: HUSBAND and WIFE are joint owners of the property located at 2001 Chestnut Street, Camp Hill, Cumberland County, Pennsylvania. The parties agree that WIFE shall retain ownership of said property. HUSBAND agrees to execute, acknowledge and deliver any and all instruments that may be necessary or advisable to carry into effect this transfer and relinquishment of all such interests, rights and claims. Upon transfer, WIFE shall hold HUSBAND harmless from any liability, cost or expense, including attorneys' fees, which is incurred in connection with the interests and/or assets referred to in this Paragraph. 6. Division of Personal Property. Except as set forth herein, each of the parties hereto has divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital personal property, including household furnishings, automobiles and other similar property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession andlor under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. The property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time ofthe signing ofthis Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as a passbook, check book, policy or certificate of insurance or other similar writing is in the possession or control of the party. The titles to the said motor vehicles shall be executed by the parties, if appropriate, for effecting the transfer as herein provided, on the date of execution of this Agreement if the title is in the possession of one or the other party. In the event that either or all of the documents of title to the said vehicles shall be in the hands of a bank or other holder of the lien or encumbrance upon said vehicle, the parties agree to advise such bank or holder as to the transfer of title set forth herein and they further agree to execute whatever documents may be required to transfer title or said document of title as in the hands of such bank or holder. 7. Additional Instruments. Each of the parties shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary on insurance policies, tax returns and other documents and do or cause to be done any other act or thing that may be necessary of desirable to effectuate the provisions and purposes of this Agreement. If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 8. Debts and Liabilities. HUSBAND and WIFE hereby represent and warrant to the other that he or she has not incurred any debts or liabilities or made any contracts for which the other or his or her estate may be liable, except as stated in this Agreement. If either party has incurred an individual obligation during the term of the marriage, that party shall be responsible to discharge said obligation and hereby agrees to indemni1)r and save the other spouse harmless on account of said obligation. 9. Warranty as to Future Obfu!:ations. HUSBAND and WIFE each covenant, warrant, represent and agree that with the exception of the obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemni1)r and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the date of execution of this Agreement, except as may be otherwise specifically provided for by the terms ofthis Agreement. 10. After Acquired Personal Property. Each of the parties hereto shall hereafter own and enjoy, independent of any claims or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 11. Representation bv Counsel. This Agreement has been prepared by Kirstin M. Sweigard, Esquire, Attorney for HUSBAND. Kirstin M. Sweigard, Esquire has not represented WIFE in any respect to the negotiation and preparation of this Agreement. WIFE acknowledges and understands that she is entitled to legal representation, however, has declined that right. WIFE acknowledges that she has reviewed the terms and conditions contained in this Agreement and has signed the same voluntarily with full knowledge and understanding of the provisions set forth herein. This Agreement shall be interpreted fairly and simply, and not strictly for or against either of the parties. 12. Mutual Consent Divorce. The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both have signed consents to the entry of a decree in divorce pursuant to Section 330l(c) Of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (hereinafter referred to as the Code). HUSBAND has filed a No-Fault Divorce action in Cumberland County at Docket No. 05-283 at his sole cost and expense, and both parties agree at the appropriate time to execute such consents, affidavits and other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301 C of the Code. All parties agree to make any necessary corrections to any documents to finalize the divorce. 13. Effect of the divorce Decree. The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the parties hereto that this Agreement shall create contractual rights and obligations as well as becoming incorporated into the Court Order and that this Agreement may be enforced by contract remedies in addition to any other remedies which may be available pursuant to the terms of this Agreement or otherwise under the Pennsylvania divorce laws. 14. Bank Accounts. Certificates. Insurance Policies. Pension Funds and other Assets. Each party shall be and remain the sole owner of any other asset in his or her control not specifically covered by other provisions in this Agreement, including but not limited to stocks, bonds, 401Ks, and mutual funds. Should it become necessary, each party agrees to sign any other titles or documents necessary to give effect to this section upon request of the other party. 15. Pensionl40Il(K). HUSBAND and WIFE agree to waive all claims and/or rights to each party's pension or 401K. 16. SUDDort/Alimonv. HUSBAND agrees to pay WIFE one lump sum payment of $5,000.00 at the time of execution of this agreement. Thereafter, HUSBAND and WIFE agree to waive all rights to any claim for Supprt and/or Alimony. ] 7. Breach. If either party breaches any provision ofthis Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach. The party breaching this agreement shall be responsible for the payment of all legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. ] 8. Modification and Waiver. Modification or waiver of any provision of this Agreement shall be effective only ifmade in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this agreement shall not be construed as a waiver of any subsequent default ofthe same or similar nature. 19. Severability. If any provision of this agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 20. DescriDtive Headinl!:s. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 21. Successors and Assil!ns. This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors in interest of the parties. 22. Governinl! Law. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 23. Entire Al!reement. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above-written, WITNESS: BbQi;R~ Thomas Grundon BY2..~~~ SutatIp Grundon COMMONWEALTH OF PENNSYLVANIA : ss: COUNTY OF On this, the 28 day of ~L~ ,2004, before me the undersigned officer, personally appeare omas G don, known to me or satlsfactonly proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ n. ,& AlU.l!dl Notary Public -_.._-- ~ . . .~.'~.. - '".._"~......-_.._, ;.;0 r~~,f '. . .' ".' ! ;., ,:.~ ,- i_(":~L~! '.-.:' '. COMMONWEALTH OF PENNSYLVANIA : ss: COUNTY OF On this, the :28 day of , 2004, before me the undersigned officer, personally appeare Sutatip G don, known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~7rL. AkcV~{t Notary Public ~~-'-----"-'-" ...---_.~'_..._~~._-- ; ?In;'.O;.~:,\>.,. -, 11'":'-"''';.0; ';-"-",: ,,','", I ~ '-"., ,:".', :. . ~/ ;':';ubii:: I ! ", "... ...__1 ~. .::, .- ',:. .. -~~"'-'-~," " '.~ -". ,~, c::, Co"" ~!'\ ~ ~ ~ I N ..." :.;" f" C',J .!. ,-~ ~ .-"~ -17 .~1 lf1j~ -'lj (/ THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, ENNSYL VANIA v. : NO. 05-283 - CIVIL TERM SUT A TIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE ACCEPTANCE OF SERVICE I, Sutatip Grundon, defendant in the above-captioned matter, do hereby accept 'J (1 ril service of the Divorce Complaint on this "" 0 day of Januarv 2005. ---------------- r:::_~, ~ g~ ..-"'f': -:-~';" ~~/. \ "" ....-':-' -.,.. ~,. t'9 - THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(C) of the Divorce Code was filed on January 13, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose the rights concerning Alimony, Division of Property, Lawyer's fees or Expenses in do not claim them before a Divorce is granted. I veri1)r that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. 94904 relating to unsworn falsification to authorities. Date: /I ~~ J 'c;/->' () ,.., 0 c::::.) c- c::::> -n (".J"\ .-'";. -0.: I ,'0 r.,? <...) -. .t:"- THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the 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 ifI do not claim them before a Divorce is granted. 3. I understand that 1 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 veri1)r that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P AC.S. 94904 relating to unsworn falsification to authorities. Date: 7:- J. T-{) 5" .--> ~E; J:..1l ~: \ N -"(''' I;? (0 W THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE WAIVER OF COUNSELING 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 veri1)r that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. 94904 relating to unsworn falsification to authorities. ) Date: .y-23--o~ ....... Sutatip r) r-::> c) eo> ,... ,'';;':::> -n ('~n -" -~. I 1'-) ~? G) ,..- .- THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUT A TIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(C) of the Divorce Code was filed on January 13, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce, 4. I understand that I may lose the rights concerning Alimony, Division of Property, Lawyer's fees or Expenses if! do not claim them before a Divorce is granted. I veri1)r that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsification to authorities. Date: ~3 i)P\O \' J:G2~ Thomas R. Grundon n (:~ t',- I ...., = C=} ~ c\ '''''fi ~ fhi';~ '" l? ~) -,,,,, ~::~ I N -r fv ("j THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the Entry of a final Decree of Divorce without notice. 2. 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. 3. 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. I veri1)r that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. 94904 relating to unsworn falsification to authorities. cJ-. -? - Date: :) 4pr 6 S. ~4~ Thomas . rundon -~-~,-,~,.- l) (~, .--' c.-:':} c::::' .:.1' .-~', .' u' .'\',' -~'.. o --(I ,;-: '-'" j;:-' <~-,--~-,-~.~~----- ~. \ "" THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE WAIVER OF COUNSELING 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 veri1)r that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. 94904 relating to unsworn falsification to authorities. 442~ Tomas . rundon Date: /),'-3 AProS" _-r_._,......"'~.. ,...., C:;J c"" U' ~.:," '.:.;:,~ , r'" r;;.~ C',) ,- THOMAS R. GRUNDON Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-283 - CIVIL TERM SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : 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: 1. Ground for Divorce: Irretrievable breakdown under 93301(c). 2. Date and Manner of service of the complaint: Service was made by certified mail and accepted on January 28, 2005. 3. Date of execution of the affidavit of consent required by 93301(c) ofthe Divorce Code: by plaintiff: April 23, 2005 by defendant: April 23, 2005 4. Related claims pending: None 5. Date plainitff's Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: May 2, 2005 Date defendant's Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: May 2, 2005 Respectfully Submitted, Date: 5/ ~ \' '-/IckMPA.- /J? ;;;7'/ ("kU Kirstin M. Sweigard, Esquirg Supreme Court ID# 83801 P.O. Box 1168 Camp Hill, PA 17001 (717) 932-4646 Fax: (717) 932-3577 Attorney for Plaintiff n C::" r--> c~ .;? CJ' "'1: )Y --<. \ U\ C' l ~ , ::~; -< 7-'" -~" -'.. o -n :::;l r~l;2 ,,<1' ~:'':\~,~, \-~,~?, ';:::\ 25 '-<: ~? ..0 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-283 - CIVIL TERM THOMAS R. GRUNDON Plaintiff SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (C) of the Divorce Code was filed on January 13, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose the rights concerning Alimony, Division of Property, Lawyer's fees or Expenses if! do not claim them before a Divorce is granted. I verilY that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 p AC.s. ~4904 relating to unsworn falsification to authorities. Date: :;;b. I/o \ ---.. ------ o ~; ~1:}7f' ~ ~ ~ '= " u;: ~'" r:: ,~: 'J."" - ~ ~:!J r:: :"\!-.i _rJ j (),G, ::2=g Do ~7.. n i-')f '~ 'i:1 ~'-<. w -0 :;$ {)"I - - v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-283 - CIVIL TERM THOMAS R. GRUNDON Plaintiff SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECfION 330Hc) OF THE DIVORCE CODE I. I consent to .the EnttY..Qb.fimllD~.rejeoflliyor~~~!J!.ol,lt n.<>tice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a Divorce is granted. 3. 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. I verilY that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P AC.S. 94904 relating to unsworn falsification to authorities. Date: 5?/jo\ ~ Thomas R. Gnmdon ------- ~ cC:> GJ' ~:: :.:;: - v> ~ --0 ::;:: ~-n r'\1r=: -0 I'C' 'rl,q rjt) -'~l-l" ~,L4' .<,'~~) ':.;c~" r1 t.;::!\ '"1:-"" ?t - cJ1 -' v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-283 - CIVIL TERM THOMAS R. GRUNDON Plaintiff SUT A TIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(C) of the Divorce Code was filed on January 13, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose the rights concerning Alimony, Division of Property, Lawyer's fees or Expenses if I do not claim them before a Divorce is granted. I verilY that the statements made in the 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: 5'""-d 1- uS ~ (") ~:;-. ,..., c> c::;> ,-" ~- S':; ..... W -0 :;l;; o -n ..... X~ :~n~ Cl'*J :9"1 CJO ---1-T, +-::0 """~() ,;:,,\)"'n ~ 'D :< <.1l - v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 05-283 - CIVIL TERM THOMAS R. GRUNDON Plaintiff SUTATIP GRUNDON Defendant. :CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301((:) OF THE DIVORCE CODE 1. I consent to the Entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a Divorce is granted. 3. 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. I verilY that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 p AC.S. ~4904 relating to unsworn falsification to authorities. -s~ Date: 5' -;?j- t?S "" ,= <;"..;:;) en '- s;:; ~ o " :;:!~ rn..l-! -oFn :0,6 ; , ~j_J _' r, (52} ~"o Om -~ s:; ---< w '"'0 ::!T.: U1 THOMAS R. GRUNDON Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-283 - CIVIL TERM SUT A TIP GRUNDON Defendant. :CIVIL ACTION - LAW : 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: 1. Ground for Divorce: Irretrievable breakdown under ~3301(c). 2. Date and Manner of service of the complaint: Service was made by certified mail and accepted on January 28, 2005. 3. Date of execution of the affidavit of consent reqnired by ~3301(c) of the Divorce Code: by plaintiff: May 21,2005 by defendant: May 21, 2005 4. Related claims pending: None 5. Date plainitfI's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: June 14,2005. ------ Date defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: June 14, 2005 Respectfully Submitted, Date: tPj/ojnc:: ui!lU1?;: 1j;,~ie~ . . M. Swei Esq Supreme Court ID# 83801 P.O. Box 1168 Camp Hill, PA 17001 (717) 932-4646 Fax: (717) 932-3577 Attorney for Plaintiff ~ 'i],; {~.~ c- -;.:s: - C ~'/ :2 <.>l ~~ .--\ -r.:-n f\1S :go 1.:)(S ^"'1,-,,,-, '1--""'" (,~)~) :0(\\ o -'-' -0 -~ -- -- r..f" -- :3:, - ~, , , , , , . . .. .. . . . . . . IN THE COURT OF COMMON PLEAS . OFCUMBERLANDCOUNTY . PENNA. . STATE OF . . . Thomas R. Grundon . No. 1)$ 2RJ Civil T_ . . . ~ VERSUS . Sutatip Grundon . . . . . . . DECREE IN DIVORCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AND NOW, 1" , :z..ooS, IT IS ORDERED AND /3' Thomas R. Gnmdon , PLAINTIFF, DECREED THAT Sutatip Grundon . DEFENDANT, AND 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: The Divorce Settlement Agreement dated January 28, 2005, is incorporated but not merged into this Decree. . ~ . . J. . . . . . , . . . . . . . . . . . . . . PROTHONOTARY :+: ;t;:+:;+:;t; :+:;f. ;t;;+;;t; 'f.'f.:+::f. .. . . . .. . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ...b ~ -'1?"',.... ~u, Whl 1 ~~ ~ ::7- "'tJ'~'y ~ -/"9 50' ftl.~ " 'It..... 1," ..