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HomeMy WebLinkAbout01-4424 ... ,~:>_.,._;..::.-:,:.";XlIII(XlIII(XlIII(XlIII(XlIII(XlIII(,_:;,_:;'-:XlIII(;'-:XlIII(~::>_;J{>-XlIII(XlIII(XlIII(-XlIII(XlIII(XlIII(XlIII(~ " ~ ~ " : IN THE COURT OF COIVIMON PLEAS .~ ~ . ~ ~ ~ ~ ~ s ;.0-; . 8 i " ~ ~ I ~ ~ ~ 8 A. " i ;;. ~ ~ . " ~ . S . S ~'4 ~ ~ S ~ ~ ~ . . . I . . ~ ~ *.... . 8.., i I ~ . ~ i ..,.."........-..,..,.. .,....., : , AUeat: ~ J " ~ .' ~ .~ ' -.., .. ' Prothonotary' ~ ,', * _~___________________~__~_.._J ~ ~ i s ~ s ~ i:i ~ s ~~ ~ OF CUMBERLAND COUNTY STATE OF '* PENNA. ....GARY. R.,. ,GRANO"... N o. .9~.::.~.~.2.~..... <:::I.Y.:r.L.... pg Plaintiff Versus .... ..JACQUELINE., .J... .GRANO"......,.....,............... , "..Oe.fe.ndant....nn DECREE IN DIVORCj: AND NOW, ~~.. ~ .'J.. .. " ~~. ~. it is ordered and decreed that .GARY. .R.. GRA.NO................................, plaintiff, and. . ../i\.~.QI,J];:~.I.I>jJ;:. ;r... .GRMQ. . . . . . . . .. . . . . . . . . . . . . . .. .. . . . ., 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 . .., ,..... ". ....... ....... ..... ...... .... .... ..... ... ... ... ...... ........ t~ ~ ~ ,.' ~ .. ~ -.;( ):. ~- : . ~:i .,+ ). : GARY R. GRANO, : IN THE COURT OF COMMON PLEAS Plaintiff : : CUMBEI/LAND COUNTY, PENNSYLVANIA : VS. : CIVIL DIVISION : JACQUELINE J. GRANO, : NO_ 01-4424 CIVIL TERM Defendant : 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: 1. Ground for divorce: irretrievable breakdown under S330l(c) ~~~x>>if~i of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Julv 26. 2001 Certified mail, restricted delivery 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by S330l(c) of the Divorce Code: by plaintiff 17./10/01 by defendant 17/,/01 (b)(l) Date of execution of the affidavit required by S3301(d) of the Divorce Code: ; (7.) Oatc cf filing and service of the plaintiff's affidavit upon the r~spondent: 4. Related claims pending: Nnnp 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's filed with the Prothonotary: Date defendant's filed with the Prothonotary: Waiver of NoticE! in S330l( c) P-ec,.,d-f'p" /7r.?ct>d/ Waiver of Notice in S330l(c) p.. r!.pttft"p" I ~ ,;t d cf I Divcrce was Divorce was C:~?f~41R~~ Attorney f (Plaintiff)1~ 0 c) ~ C , ~ r, :J '" 0 VI (J,- "" ~ GARY R. GRANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION .. LAW JACQUELINE J. GRANO, Defendant : NO. 0/- 4-424 ~ : IN DNORCE NOTTf'F TO DFFEND A NT) ('T A 1M HTGHTS 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, Pennsylvania (717) 249-3166 Anthony L. DeLuca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 GARY R. GRANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW : NO. 01- <lY..2'1CNIL : IN DIVORCE JACQUELINE J. GRANO, Defendant COMPLAINT UNDER SECTION 3301 (c) OF THE DNORCE CODE I. The Plaintiff is Gary R. Grano, who currently resides at 753 Dogwood Terrace, Boiling Springs, Cumberland County, Pennsylvania, since March 6, 1992. 2. The Defendant is Jacqueline J. Grano, who currently resides at 400 E. Randolph Ave., #42, Mine Hill, New Jersey, since September 1,2000. 3. Plaintiff and/or Defendant have been a bona fide residerlt(s) in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 11,1992 in North Saco, Maine 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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 counse:ting. 8. Plaintiff requests the court to enter a decree of 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. S 4904, relating to unsworn falsification to authorities. Date: 7/11)8 I , ~~y~~ ~ Anthony L. uca, Esquire '1 'f'- IB Front Street P.O. Box 358 Boiling Springs, PA 17007 (717) 258-6844 Attorney for Plaintiff GARY R. GRANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CNIL ACTION '. LAW JACQUELINE J. GRANO, Defendant : NO. 01-4424 CIVIL : IN DNORCE AFFIDA VTT OF MATT TNn COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND Anthony L. DeLuca, attorney for Plaintiff, being duly sworn according to law, says that he mailed by certified mail, return receipt requested, a true and eorrect copy of the Complaint in Divorce under Section 3301 (c) of the Divorce Code to the Df~fendant at her residence and that Defendant did receive same, as evidenced by the signed receipt attached hereto as Exhibit "A". By: ~~~~~ Ant]~:n~ ~Muca, Esquire 113 Front Street P.O. Box 358 Boiling Springs, P A 17007 (717) 258-6844 Sworn to and sub~bed before me this I'7llay of L!2-u ' ,2001. l;l)7U~~ C{ /)~e<Z.~, Public NOTARIAL SEAL MARJORIE A. DeLUCA, Nola PUbHc S:1h Mlddlel?n Twp., CUmbe~nd Co CommIssIon Em/res Nov. 1.2003' c ~ L~'i f' ~_? C':. :J r': " ~ .$ ~ 3 ~,:'~" :,;:; (- .. . ..., '.~I .....' -_.) SENDER: COMPLETE THIS SECTION Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse 50 that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: (1~w!<'h.L }. ~I dfXJ C 12,"',' '-'-10; ()};~. dl:t/,t ,~;.Jr;M) r1/ 8c~' , .' t.3 / COMPLETE THIS SEe ON ON DEUVE;HY : I .. I' A. ~.9ived by (Please ~;j.nt Clearly) . .JQ..( c0<,j'f1t. -,j GlCn~1 c, n tei:J '~y . 0 ent eli ery address d~m 1? ~:res... , enter de\iverf addresS below: 0 No ,~ ~I . 3. Se~ Type ~Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandise o C,O,O, / rg{es 4. Restricted Deliver,? (Extra Fee) 2. Article Number (Copy from service label) 7tJOC> otoo OOdll 0G.'TS ~/c13 PS Form 3811, July 1999 Domestic Return Receipt 102595-00-M-0952 UNlTEO STATES POSTAL SERVICE 111111 First-Class Mail Postage & Fees Paid USPS Permit No. G-10 . Sender: Please print your name, address, and ZIP+4 in this box. anf-;1(.7/-J,/ L, b_~LuCf'l, &!fUi/:.'t'. PO. SoY: '-'166 ~I'.e ('Ii! S, '&,'I.{f ~ , '. '.'- ~ i I "j' n~,' ~ _. ,. , v: ~', L' '- ". ~ Pn- /' rvO,.<f\,1U" r Yo' 'll' i 7ClO?+O::::Se. l.ulll,..II/".I/, ../,..IIf.....II. ".I.,..I..,.I.lul,.I/,./ GARY R. GRANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CNIL ACTION - LAW JACQUELINE J. GRANO, Defendant : NO.01-4424 CIVIL ; IN DNORCE WANER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DNORCE DECREE UNDER 93301(c) OF THE DNORCE CODE I. 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] 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 arld 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: hl/~/D/ Gj?~:!;t~ () :-"""'J .t ~ cJ f'l r. ...J ~ o vJ ~ '.:, ( ;~ GARY R. GRANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CNIL ACTION - LAW JACQUELINE J. GRANO, Defendant : NO. 01-4424CNIL : IN DIVORCE A FFmA VTT OF rONSRNT I. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 20,2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of final decree of divorce aft,er service of notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true alld correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: /2/10/0/ ( I 2Jau,fLjJ~ Gary R. ~10 S? Q " " ..J -I> '. I:) vi ~ ,_...., , . ~ ~<, (..) GARY R. GRANO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CNIL ACTION - LAW JACQUELINE J. GRANO, Defendant : NO. 01-4424 : IN DNORCE WANER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lINDER 9330l(c) OF THE DNORCE CODE I. I consent to the entry of a final decree of divorce \vithout notice. 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 verify that the statements made in this affidavit are true aJlld 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: /13101 I Q -;,," ---1 , ~ 12... ') " ~ ,J -f: -:J --; 0 I ,~! vi ~ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA GARY R. GRANO, VS. : CNIL ACTION - LAW : NO. cJl-'f"t~r CIVIL : IN DIVORCE JACQUELINE J. GRANO, Defendant A FFIDA VIT OF rONSFNT 1. A Complaint in divorce under Section 330l(c) of the Divorce Code was filed on July 20,2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of 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. Sec. 4904 relating to unsworn falsification to authorities. Date: I J.-/ 3 /0 I , / Q C) c-. t'- " " .... '-.c ,J -R ~ :...::) "" (--> ~