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HomeMy WebLinkAbout05-1679 ,. A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE AND CUSTODY DA VID LEE GRIMM II, Defendant : NO. OS-lIP 1 Cf CIVIL TERM 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 right 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, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER1S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MA Y LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford St. Carlisle, P A 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE AND CUSTODY ; NO. 05-1 (P 1'[ CIVIL TERM DAVID LEE GRIMM II, Defendant DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, A. Renee Grimm, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and custody: COUNT I DIVORCE UNDER 23 Pa.C.S. ~~3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is A. Renee Grimm, who currently resides at 301 East Orange Street, Apt. I, Shippensburg, Cumberland County, Pennsylvania since June I, 2004. 2. Defendant is David Lee Grimm II, who currently resides at 166 Secrest Park Road, Breezewood, Bedford County, Pennsylvania, since June 2004. 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. The plaintiff and defendant were married on May 16, 2000 in Bedford, Bedford County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since June 1, 2004. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II CUSTODY 9. Plaintiff repeats and realleges paragraphs 1 through 8. 10. Plaintiff seeks custody of the following children: Name Victoria May Grimm (shared custody) Ashley Nicole Grimm (shared custody) David Grimm III (shared custody) Present Residence 301 East Orange Street, Apt. 1, Shippensburg, P A 17257 Age 4 166 Secrest Park Road, Breezewood, PA 15533 301 East Orange Street, Apt. 1, Shippensburg, P A 17257 3 166 Secrest Park Road, Breezewood, PA 15533 301 East Orange Street, Apt. 1, Shippensburg, P A 17257 2 166 Secrest Park Road, Breezewood, PA 15533 None of the children were born out of wedlock. The children are presently in the custody of A. Renee Grimm, who resides at 301 East Orange Street, Apt. 1, Shippensburg, P A 17257 and David Lee Grimm II, who resides at 166 Secrest Park Road, Breezewood, PA 15533. During the past five years, the children have resided with the following persons and at the following addresses: Persons A.Renee Grimm David Lee Grimm II A. Renee Grimm David Lee Grimm II Address 301 East Orange Street, Apt. 1, Shippensburg, P A 17257 Dates June 2004 - present ( shared custody) 166 Secrest Park Road, Breezewood, PA 15533 June 2004 - present (shared custody) 108 Ontario Road Breezewood, PA 15533 June 2001 - June 2004 A. Renee Grimm David Lee Grimm II Julianna Street Bedford, PA 15522 Birth - June 2001 The mother ofthe children is A. Renee Grimm, currently residing at 301 East Orange Street, Apt. 1, Shippensburg, P A 17257. She is married. The father of the children is David Lee Grimm II, currently residing at 166 Secrest Park Road, Breezewood, PA 15533. He is married. 11. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Victoria May Grimm Ashley Nicole Grimm David Grimm III Relationship Daughter Daughter Son 12. The relationship ofthe defendant to the children is that of father. The defendant resides with the following persons: Name David Lee Grimm Susan Leberfinger Victoria May Grimm Ashley Nicole Grimm David Grimm III Relationship Defendant's Father Defendant's Mother Daughter Daughter Son 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 14. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff has been the primary caretaker ofthe children since birth; b) Plaintiff provides the children with a stable home environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs; c) Plaintiff has permitted and encouraged continuing contact between Defendant and the children and will continue to allow periods of partial custody; d) Plaintiff continues to perform the parental duties and enjoys the love and affection of the children. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the children. fi( C( ..1 "rI-~ ~:l-ff ~( ck~L ROBE' E. RAINS THOMAS PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Counsel for Defendant Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. 94904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. Dated: j/30/():j , a1f!:lIH [Mu rmm A. Re ee Grimm 1'--0,) ~-:s ("...-r', ~!t;, o -n --l ir, :J1 , I rn ? ;, ~~~ en ;:;,.... .....-.. ;-.-"",,, (,,) c:> -'r) r..) en ,.,~..."~ A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY : NO. 05- I b 71 CIVIL TERM DA VID LEE GRIMM II, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow A. Renee Grimm, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date 3(30( 6~ ~~ c- 7 (/1J{C~// / :1 ROB E INS THO AS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys (l ,1 f--.., //7 ,-'(C/{i /;;J . F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 o l,~:~~ r....:. = ~::.:., c_r1 n ':-n :::?:t: :':"~-,i' ......, :-C.,... nl ,~; - (: rI.1 -'\-t ,-.J ~i~ ~~ -~.~~~.~ J. .j ... '-, <....) c::) ,....) en ---- -- PLAINTIFF IN THE COURT OF COMMON PEAS OF CUMBERLAND COUNTY, PENN YL VANIA A. RENEE GRIMM v. 05-1679 CIVIL ACTION LAW DAVID LEE GRIMM, II DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, April 01, 2005 , upon consideration of th attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Ve ney, Esq. ,the conciliator, at 4th Floor,Sumberland County Courthouse, Carlisle on __. Thursday, Ap~iI1.8, 2 05 at .10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resol e the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appe r at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection I' om Abuse orders, Special Relief orders, and Custody orders to tbe conciliator 48 hours prior to schedule hearing. FOR THE COURT, By: isi lacqueline M. Vemev. Esa. Custody Conciliator IJrA The Court of Common Pleas of Cumberland County is required by law to co ply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonabl accommodations available to disabled individuals having business before the court, please contact our ol~ce. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You ust attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE T E OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . .p' ~'?7?f/f;:tJ '-+~ p,nvp' /~h;J .#p 't~ ~~ '7:d ~ ~ ktP,? .p?;l '" '/,~:.""<) :,_. "..1_\'':1 (\\\'t/. t,l ,'? V"\ ",- ,'...:'-~\' .;U'-'" ::i t ".' \,"-1 . " ,,', - ~..::... ::"~-) . '-'," ,'- .-\ 5?} hI? J,J /1 ./7 ;'7 /7 t.,. ,( ~ /7 - . . A. RENEE GRIMM, Plaintiff ; IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM AFFIDAVIT OF SERVICE I, James R. Abbott, hereby affirm that I am a competent adult and that I served a true and correct copy of the above captioned Complaint for Divorce under 23 Pa. C.S. SS3301(c) and 330I(d) on the defendant, David Lee Grimm, II, by depositing a copy of the same in the United States mail, certified number 7003 3110000457742617, restricted delivery, return receipt requested on the 6th Day of April, 2005 addressed as follows: David Lee Grimm, II 166 Secrest Park Road Breezewood, PA 15533 Dated: ~;j2 "/,, r- Sender's receipt no. 7003 3110 0004 5774 2617 is attached hereto and incorporated by reference. On lhe 18th day of April, 2005, domestic return receipt number 7003 311000045774 2617 was delivered to the Family Law Clinic, bearing the signature David Lee Grimm, II and showing a date of service of April 15, 2005. Domestic return receipt number 70033110 0004 57742617 is attached hereto and incorporated by reference. I understand that making any false statement would subject the Family Law Clinic to penalties under 18 Pa. C.S. S4904 (relating to unsworn falsification to orities) / ~/ ~~~~ Jame . Abbott Cer!" led Legal Intern F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 . " u.s. Postal Service", CERTIFIED MAIL", RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) I'- .-'l ...lI ru postage :r r'- r'- lJ1 :r Cl Cl Retu'" R",~pt Fee CI (E:ndorsement Required) o RestrIcted Delivery Fee M (Endorsement Reql..llred) .-'l m Certified Fee ,A' "L7' (I ....f 7:5 .50 I Total Postage & Fees $ g /S- m Cl Cl r'- . Complete items 1, 2, and 3. Also complete item 4 if Restricted Dellvery 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 on the front jf space permits. 1. Article Addressed to: c. SiMure,_ X 'V-> 4-- J '^- '" o Agent o Addressee DYes ONo D. Is deHl/slY address different trom item 1? If YES, enter delivery address below: ijo ViCC. leI' (7YiiYi/Y1 JI / G' 6 Sa us! Pa rl1. /Cd.. .? t7!u,!/,.(){)od, PI/-- /5533 Ff.turn Receipt Fl. uasted 3. Sel)ice Type 5t Certified Mail 0 PKPress Mal! o Registered G! Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 7003 3110 0004 5774 2617 PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 CJ -n r,_, c) M:.".., ( ) :-,\;--1 t'.) 0-' RECEIVED MAY 02 m.tI ry A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005-1679 CIVIL TERM DA VlD LEE GRIMM, II, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this ~ day of wi ~ 1 ,2005, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, A. Renee Grimm, and the Father, David Lee Grimm, shall have shared legal custody of Victoria May Grimm, born July 11, 2000, Ashley Nicole Grimm, born July 31, 2001 and David Grimm, III, born January 9, 2003. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. This means that both parties are entitled to all records from school and doctors. 2. The parties shall share physical custody on a week on/week offbasis. The exchange day and time shall be Sundays at 11 :00 a.m. 3. Three weeks prior to start of school in August, 2005, Mother shall have physical custody of the children during the week. Father shall be entitled to two conseculive weekends from Friday at 7:00 p.m. to Sunday at 7:00 p.m. Mother shall have the next weekend. This weekend schedule (two weekends for Father/one weekend for Mother) shall continue until school vacation when physical custody shall revert to week on/week off as specified in paragraph 2 until three weeks prior to the start of the next school year. 4. Thanksgiving: Falher shall always have physical custody of the children from 3:00 p.m. Thanksgiving Day to Sunday at 7:00 p.m. 5. Christmas. The Christmas holiday shall be divided inlo two blocks. Block A shall be from the day school recesses at 7:00 p.m. to Christmas Day at 4:00 p.m. Block B shall be from Christmas Day at 4:00 p.m. to January 1 at 4:00 p.m. Father shall have Block A in odd numbered years and Block B in even numbered years. Mother shall have Block A in even numbered years and Block B in odd numbered years. 6. Easter: Father shall always have physical custody of the children from Good Friday at 3:00 p.m. to Sunday at 3:00 p.m. ff, ~~: (> s~~ Z~,:, ~~5 \~~\ ::S {\~ \ J.) 0- ~~tt:! \.l.-F CI- a ("") <=> - - ..-:: -;C.t. ("") \ -,,,- .~~ :.C ~"n = co> ..... >- \:z :~;~; -,!~! c'.02 \~ :~^l ~~G \~~l Cl.. ~5 o ------ 7. Mother's Day/Father's Day. Mother shall have physical custody of the children on Mother's Day and Father shall have physical custody of the children on Father's Day at times agreed to by the parties. 8. Transportation shall be shared such that the parties will meet at the Ft. Littleton Interchange of the Pennsylvania Turnpike. 9. Only a mature, responsible, competent individual who has a valid driver's license may provide child care to the children. 10. The custodial parent shall allow reasonable telephone contact between the children and the non-custodial parent. 11. Each party shall inform the other of any change in address and lelephone number and the names of any individuals with whom they are residing. In lhe event that the children are yisiling away overnight from their usual place ofresidence, the custodial parent shall provide a name, location and telephone number where the children may be reached. 12. Each party shall inform the other of all medical care any of the children receives while in that party's care. Each party will promptly notify the other of any medical emergencies that arise while any of the children are in that party's care. 13. Neither party shall do or say anything or permit a third party to do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development of the Children's love and respect for the other parent. The parties shall make every effort 10 minimize the use ofprofanily in front of the children. 14. Without prior Order of Court, neither parent may relocate the children to a location that would change the current transportalion arrangement. 15. This Order is entered pursuant to a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. BY THE COURT, ~ . ccvfunes R. Abbott, certified legal intern Anne MacDonald-Fox, Esquire, Family Law clinic, Counsel for Mother J'avid Lee Grimm, II, pro se 166 Secrest Park Road Breezewood, PA 15533 o/ry I ,QJ O<t) A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 2005-1679 CIVIL TERM DAVID LEE GRIMM, II, Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Concilialor submils the following report: I. The pertinent information concerning the Children who are lhe subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTL Y IN CUSTODY OF Victoria May Grimm Ashley Nicole Grimm David Grimm, III July 11,2000 July 31,2001 January 9, 2003 shared shared shared 2. A Conciliation Conference was held in this matter on April 28, 2005, with the following individuals in attendance: The Mother, A. Renee Gimm, with her counsel, James R. Abbott, certified legal inlern, Anne MacDonald-Fox, Esquire, Family Law Clinic, and Father, David Lee Grimm, pro se. 3. The parties agreed to an Order in the form as attached. c..j -;;.< 7 -(.15- Date .~ A il: ~ {Vi. ~C:I facq ine M. Verney, Esquire t/ Custody Concilialor A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under !}3301(c) ofthe Divorce Code was filed on March 30, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 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. !}4904, relating to unsworn falsification to authorities. Date~~ P,".ti" /1 !k~,~w A. Renee rimm ("1 <;:. '::.-., ':', -t)\': , (I)i:~ '~~I .~:~~ Y:f? ~- ~ ~ '{}. rE. CJ -- o ~ -' ~'?,,; -::r;C? 9lf, ::Y.-t"\ nD ~."'~ "{\ .",,< SI ~ ~ ~ :..- -- " A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under s3301(c) of the Divorce Code was filed on March 30, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe Complaint. 3. 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. S4904, relating to unsworn falsification to authorities. Date 7. 5 () . 6:f Defendant 1)...) &:-.. Qj~ David Lee Grimm II ~ (1 ~. '-f..~~;~,_, ~I'\'T' -? .-',:' ~? \""",. '~::~<~: 'j.,~ i~ ~~"-!" 3. ..-:! ~ d' ~ <;;, " ..- o q, ~~ :Bt;' ~~ {~~ ~ ~ 0, (..0-' "p. ~~ -- -- .' A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 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 7/:Jufn ~NJin~~rN A. Rene Grimm, Plaintiff 0 "', = ~ c = -.:.: "" G. ".. ~ (::' c:: m::r.l <;? -u!3 0 :"6 0 :po ,:2-'<'; j~~:n :Jt: b~ - - ~ 0 ~ N A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 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 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. 94904 relating to unsworn falsification to authorities. Date I 30-of 9-7 ~.lk ~~'^-~ David Lee Grimm II, Defen ant ---- o ~"9 ""-".. ....' ~ <J' ~ G'> - o " ':::>:. .' ~~:(;. ,T ':2 .~ Q, -~:l1~ 1) ~,~ ~7:~ "?') '.;;.< 'V' '::'1 o iJ) :<";. -;.\~... .- .- .' A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM CERTIFICATE OF SERVICE I, Brenda Coppede, hereby certify that on this 10th day of August, 2005, I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet on David Lee Grimm, II by first class U.S. mail, addressed as follows: Mr. David Lee Grimm, II 166 Secrest Park Road Breezewood, PA 15533 Date: oJO!D) enda Coppede . Certified Legal Intern F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 7I 7/243-2968 0;\i' ~";f (~";'-' "'""- o G. ~~,. .;;; % :g: G'> - c::> ~i:~\~:-,_, jrc;,. 3. q, 1-.~ 1)~ ") 1 (, - ~,,'1' 1_-1) ;~J..'7t :.t:-(" 9 -1;:0- ~ ~ .?- - - .' o .- - - A. RENEE GRIMM, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM 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 S 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 6, 2005 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the plaintiff, July 26, 2005; by the defendant, July 30, 2005. 4. Related claims pending: none. 5. Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: August 10, 2005. Date defendant's Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: August 10,2005. 5/;O/oT I ~~~~ Certified Legal Intern ~CI ~ ~L.AJ&L LU STON-WALSH ANNE MACDONALD-FOX Supervising Attorneys Date: F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 's};~, (J/' .F'::.. '\... ~s~ ,,?,C-:,. ~:J" ^,L. ~ ~ -- -- .' <.;\ ~~ :91~ '~:r6 r:~ 1;; ~i'.... \' Z3 ~ o. .r; (1 (;Of ~ 'f}. ~ <P -- o A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under &3301 (c) of the Divorce Code was filed on March 30, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 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. !!l4904, relating to unsworn falsification to authorities. Date~~ Plmntiff Ii l:tdA~ A. Renee rimm ~ "" ~.:;' ~\\,. \ .~-; .' i~< \... '/';,";. U.~ ^ ((i~':;\ 'Z''-c:: ''y- i:;, .' , ,'- ~ ~ V' ~ c.-- v.-, -0 ~ ~. -;;:;. ." ~ oJ Q, ~~ \ , ;?'\ ~~ q~(\ ;~ ~ ;z. A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM AFFIDAVIT OF CONSENT L A Complaint in Divorce under S3301(c) of the Divorce Code was filed on March 30, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ofa 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. S4904, relating to unsworn falsification to authorities. Date 7 - 5 0 - (J j Defendant l).J 4".. . Q!.)v-. David Lee Grimm II 7P (2 (~-;; :~~l,' (""\"-" ~:~ .~ ~ Q, ~ ~~ ~ ~\ o 12~ ~ 5' ~ A ~ "~ .. -;z 0, '-" A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand thaI 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 ofthe 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. s4904 relating to unsworn falsification to authorities. Date 7/d&J'h ~JfnA;"rN A. Rene Grimm, Plamtlff (') "-' ~ = ;,; = c.n ~c~: ",. -t :c c:: m::E G> .-- -om -T"JO 0 ("6 .) ;p. _~-rj C:):D Z .:2:0 - r,)m - ::::, ~ 'J> :<. 0 ::0 N -< A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 ifI do not claim them before a divorce is granted. 3. I undersland 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. I 30-of 9...J ~~ ,~J'-~ David Lee Grimm II, Defen ant Date o c -,~ -:.,~ "DtT,\ r11\"1 , ~6{' {~->'-:~ ~~:- ....' "'" ~ ~ (0) - o "V"'"C 7.~' 'y'C:~ 7- "2 <;?, ~~ ;~ ;5,6 "':;l--,.. -.--..' (')-'"' ,,,,R. ~ 'J:" ~ ::r'" -- _\t.. - - .' o u:> A. RENEE GRIMM, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM CERTIFICATE OF SERVICE I, Brenda Coppede, hereby certify that on this 10th day of August, 2005, I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheel on David Lee Grimm, II by first class U.S. mail, addressed as follows: Mr. David Lee Grimm, II 166 Secrest Park Road Breezewood, PA 15533 Date: ptu!:J) b~~ ~nda Coppede . Certified Legal Intern FAMIL Y LA W CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ~~;;'?1' -;-',;)- 1{)::' () <;;, -;..,~. ~ <= <J' :D" '3 - r;_~ \:.:~ :~~1'c~ h -~ ""- Cl Q. :t,::!.1 ':'",~ -'l\:? 1:>b ~~, {":?B -'" n 'C:{ .'-'\ 11 ::.:: :P' ""l" .-.- - - .' o .- - A. RENEE GRIMM, Plaintiff Y. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY DAVID LEE GRIMM II, Defendant : NO. 05-1679 CIVIL TERM 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 S 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 6, 2005 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the plaintiff, July 26, 2005; by the defendant, July 30, 2005. 4. Related claims pending: none. 5. Date plaintiff's Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: August 10, 2005. Date defendant's Waiver of Notice in S 3301(c) Divorce was filed with the Prothonotary: August 10, 2005. Date: J/;(}!o ,- I ~~ /~DA COPP Certified Legal Intern ~t1 ~vr4 ~w&L LU<< STON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ~ ::- -- ." ~ --' ~~ :,?}\;3 '~Aq, ::...,;:, -f' (1~ (:", --'" ~ C? "'- Q C~ '::cZ" .~}:';: y~:~ -<7 { ':2~ i~~'~ >..~ "'-J. :4 ~ ';:}. ~ G' -- c:::> ------- ,,' . . . . " . . . . . . . . " . . . . . . . . . . . . . . . . . . . . . . . . . . " . . . . " . " . " " " . . . . . . " . " " " . " . . . . . . " . . . . . " . . " . . . . . . . . . . . . . . . . . . . . . . ~,.., Of. Of " +.+.+.+. +. +.+.+. +.+.+.+. +. +. +.+.+. +.+.+.+. +. +.+.+.+. +.+.+.+.++.+.+.+. +++.+.++ +.+. +. +.+.+. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. 14_ RRNRR (;RTMM. No. 1679 2005 Plaintiff VERSUS DAVTD ~RE (;RTMM. TT. f)pfennAnt DECREE IN DIVORCE AND NOW, ~tJD\l.s..t l~ 26C.::'~ IT IS ORDERED AND DECREED THAT A. RENEE GRIMM , PLAINTIFF, AND DAVIn ~EE GRTMM .TI , 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: NONE BnHE COU7A;Co ~ 0 Jl, I ATImb " { ~~P"O'HOHO'A"' +'f :+. +. +. 'f +. Of. +. Of +';to 'f 'f:+:+' +. +. Of +. 'f Of. 'to 'f +.:+.:+. +. +. . 'f +. Of.:tO +.:+ +. +. 'f Of. 'f " Of +. +. +. 'f'f+':+:+ " " " " " . " . " " " . " " " " . . . " " . . . . " " . . " . " " " " . . . " . " . " " " . " . . . " " " . " . . . " . " " " . " " . " . " . " . " . " . . . " . . " " " . . " " . " " . . . . 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