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Home My WebLink About05-5961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW (prrlLJ L . b1;tf:S Plaintiff ::No.05-- 5%1 Civil Term v. Scan K. ~> Defendant : 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. 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OF 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 A venue Carlisle, P A 17013 (717) 249-3166 ... Plaintiff IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE Defendant No. NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding tiled in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLMU COUNTY PENNSYLVANIA v. No. OS -S'lt,l CIVIL TERM Defendant IN DIVORCE COMPLAINT UNDER &3301(c) or (d) OF THE DIVORCE CODE I. Plaintiff is Card "f l. 6rv& , who currently resides at ~Z2R N, Fyonf ~t \lVormlf\{SburS nOq~ Cumberland County, Pennsylvania. 2. Defendant is 8t>nn R 6m;"" , who currently resides at 1131\ 1'\/. V InF St. ShlrEIIY1(l<;"tDvvn PA /lOI \ 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on A/lDcdl I:~, lyc(1 at AM. Holl\/~", PA 5. The marriage is irretrievably broken, and the parties separated on MCI((h '7. 2(){)S 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to fhe best of his/her knowledge and belief, avers that defendant is not in the military service ofthe United States of Americil, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Noy 17, 2005 Date P~~ I, CDn1LI L 6rr:r;s' , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsitication to authorities as provided in 18 Pa. C.S. 94904. _NoY n. ZOOS Date: ~~ Plaintiff, Se Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC (717) 243-9400 (' ~~-' ,.'-- s-;:~\ .-\ ., i:,'\ ..- _\ ~,-"~ , (;"" ,,-------- Cn,~.--lLI L brrf;,r::, U-j" v . 'Pl' 'ff amtl : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA Sean e, ~<; Defendant : NO. 05 - 5'1t,( CIVIL TERM : DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, CDrYly l &r-oss paupens. , Plaintiff, to proceed in forma I, Valerie J. Faden, attorney for the party proceeding in forma lli!Yperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party, ~- Valerie J. ~en Attorney for Plaintiff 2807 Market Street Camp Hill, PA 17011 (717) 920-9461 , , ~ ~ -- -- - ') I, e: (.\ -\ -~.,- :~ \-;, ,-- -' ( ,~\ (;\ - CandLj L. bw-;, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, ~~l NO.d)5"- CIVIL TERlvI S('Q n R. l:rv-oc,,,, IN DIVORCE Defendant ACCEPTANCE OF SERVICE I, DEFENDANT, accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, 94904, relating to unsworn falsification to authorities. I " ,if / ~ ?t' / 7 / Ion D f / I V a e ' -d ~0-' , Defendant I , , {:-;:, (~. ....,"' c;::) '.::.:1 ~.n ~~~ C::I ;~,? C"; CANDY L. GROSS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYL VANIA v. SEAN~ GROSS, Defendant CIVIL ACTION - LAW DIVORCE : No. 05-5961 W AIVER 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 wifhout notice. 2. I understand that I may loose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim fhem before a divorce is granted. 3. I understand fhat 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 fhe profhonotary, I verify that fhe statements made in fhis Affidavit are true and correct. I understand that false statements herein are made subject to fhe penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to aufhorities, DATE: ~ 21, QLfJo CQ~ CANDY 1. SS, intiff- ~ 2", "'0\.1;' (9\:< ~~r;_ t-!}-".,. ee. L_ -', -~; ~~~: " c:.. 7:z: 3. ~ ~ ~ ~,~ ~ f1"\ (;;") :'{, ~, 9-'4. ,-- ...<.."""Il Zf?, <; 7;2. -;::;. z .' ~ o .- CANDY L. GROSS, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA v. SEAN f ~ROSS, Defendant CIVIL ACTION - LAW DIVORCE : No. 05-5961 WAIVER OF NOTICE OF INTENTION TO REOUEST 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 wifhout notice, 2. I understand fhat I may loose rights concerning alimony, division of property, lawyers fees or expenses in do not claim fhem before a divorce is granted. 3. I understand fhat I will not be divorced until a divorce decree is entered by fhe Court and that a copy of the decree will be sent to me immediately after it is filed wifh the prothonotary. I verify that fhe statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to fhe penalties of 18 Pa, C.S, 94904 relating to unsworn falsification to authorities. DATE: :J/;r ~ . / , Defendant (") c ~ ~}Tj ~f": i/) '" -0<;: <r:" ,~c. '"'-C' );c~ Z ;j ~ ...., = = '" ".. c:: In N N ;Do :ll: ~ ~ ~~ :uy ~~C) ~L :r~ ()o esm ~ -< o CANDY L. GROSS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA K. SEAN).. GROSS, Defendant v. CIVIL ACTION - LAW DIVORCE No. 05-5961 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330 I (c) of the Divorce Code was filed on November 17,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of tiling 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: 2- 2i .-CJo ~"L~~~ CANDY 1. ~SS, intiff ~' .") ,:-,1.'\ cr- , :;-1 I'''' Ci\ ..,. .' C,) L..') CANDY L. GROSS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA p-.. SEAN \. GROSS, Defendant v. CIVIL ACTION - LAW DIVORCE No. 05-5961 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330 I (c) of the Divorce Code was filed on November 17,2005, 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 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: 3//r;;i< , xd!~ SEAN R, GROSS. endant (") '"" C~_ c:~ , C~_) c;r.... f,;'; :';::! ,-- ~, j'. , C"" C;, " W C) CANDY L. GROSS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE SEAN R. GROSS, Defendant No. 05-5961 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 1. Grounds for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2, Date and manner of service of Complaint: Acceptance of Service filed on November 18,2005. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by Plaintiff: February 21, 2006; by Defendant: March 18, 2006. 4. Related claims pending: none 5, Date Plaintiffs and Defendant's Waivers of Notice were filed with the Prothonotary: August 22, 2006. DATE: f Its! oft; ~ LD, # 87442 676 Villa Vista Avenue Lewisburg, PA 17837 (570) 523-2026 Attorney for Plaintiff (J "'~, >) :.'n ::::! .." \ G ;::. c...) (:..,'., ~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Candy L. Gross No. Civil 05-5961 Plaintiff VERSUS Sean R. Gross Defendant DECREE IN DIVORCE AND NOW, ~J.-~6M.-- , "2-.:rO Go , I TIS 0 ROE RED AND /J' DECREED THAT Candy L. Gross , PLAI NT) FF, AND Sean R. Gross , 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; There are no claims pendinq. -----/ RT' /J ~ ATTEST,. /J ~ _ '~"7 PROTHONOTARY J. -~f ~~ ~~ ?o',hl"/J ~ p-?'~~ -Prl v'.hI 3 . , . . .' ' . -. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CO-fldLj L. ~<; Plaintiff Vs FileNo. 05 - 5crw I IN DIVORCE Seo.n Q. 6rrJ:;;,s Defendant NOTICE TO RESUME PRIOR SURNAM:E Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or ~ after the entry of a Final Decree in Divorce dated ~p\-, i 31 2lX16 hereby elects to resume the prior surname of S h i ~ l~ , and gives this written notice avowing his I her intention pursuant to the provisions of 54 P .S. 704. Date:~ ~~&'>e- CQ~ Si$P-ature 0 ame being resumed CQf\O~ L. Sh i e. Ids. COMMONWEALTH OF PENNSYLVANIA ) COUNTYOF ~ On the 14 day of 'n.M~ . , 200~, before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and aclmowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ~ L"- O. 7nJft. - JJ2c Jtk if J V Prothonotary or Hotar~' P'lblic NOTARIAL SEAL PRontONOTARY, NOTARY'" CMlISI.E CUMBERLAND coum COURTHOusE MY COMMISSION EXPIRES JANIMRY 4.2010 P&.. L. .:?3-c.Q9.,;2S1' 'JIV'"'"- 1Ii?" v- Of -,,,~,,~ ............. lji,v;'q ~ l'l\); '1;'\ : ;''; t. i~<H)H~}'n~;,):J 'f.. .,}:. '.J) ;]; 0t \ f. .~~ ,:^. .'~ ~ ':: ",~---~- !~_......".-~.,-,~,-~<,-~... (") f; :gF z )t.....,..~ .:: 1'11,1 lj"~ 1"<~ _ww, <-1' , f'o..) = = 0-. :z: o <::: I o ." -l ..,.. ffi:D r- -Of.,...: ~:~ 7) :~~ ~~: i5 f;~ --I .,~,; :':0 .< ~ -.;;,,.. C) c