HomeMy WebLinkAbout87-0068 OF CUMBERLAND COUNTY
STATE OF ,~~ PENNA.
SUSAN M. GRAY, ...................... 68 CIVIL 19 87
_~!.aintif~
Versus
................ ~P~A._!~---~,.---~--r~-.-Y-' ............................
De£end~nt.
DECREE IN
DIVORCE
. .~..~.,6 ~ z '~" 19. ~.7..., it is ordered and
~/ Susan M...qr..ay. . .... aintiff,
........... pi
:;,~ decreed that ............ ' .........
..... defendant,
~l and ........... .J.o,n.~b.~n .M .... ~. ...........................
~'~ 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
ny The ~o. urt:
....................... :
........ / ................... l-'rotnon
IN THE COUR~ OF CO:~.ION PLEAS OF
SUSAN M. GRAy, CU~IBERLAND COUNTY, PENNSYLVANIA
Plaintiff
.- v. NO, 68 CIVIL 1987
· . JONATHAN M. GRAY,
De f endant
PRAECIPE TO TRANSMIT KECOKD
To the Prothonotary:
Transmit the record, together with the following info.rmation, to the court
for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section (201(c))
~E(~X~Xof the Divorce Code· (Strike out inapplicable section.)
2.' Date and manner of service of the complaint: January 14, 1987 by
Certified Mail, ~eturn receipt requested arid'~attached a's Exhibit "A"
3. (Complete either paragraph (a) or (b) .)
(a) Date of execution of the affidavit of consent required by Section
201(c) of the Divorce Code: by the plaintiff April 14, 1987 ;
by defendant April 12, '1987 ' .
(b) (1) Date of execution of the plaintiff's affidavit required by
Section 201(d) of the Divorce Code: ;
(2) date of service of the plaintiff's affidavit upon the defendant:
&. Related cla!m~ pendtmg: NONE
Attorney for (Plaintiff)
SUSAN M. GRAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
V.
:
JONATHAN M. GRAY, :
Defendant : 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
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 the Cumberland
County Court House, High and Hanover Street, Carlisle.
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.
Court Administrator, Third Floor
Cumberland County Court House
Carlisle, PA 17013
(717) 249-1133
Attorney for Plaintiff
~USAN M. GRAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
· : NO. CIVIL 1987
:
ONATHAN M. GRAY, :
Defendant : IN DIVORCE
COMPLAINT
1. Plaintiff is SUSAN M. GRAY, who currently resides at
428 South Hanover Street, Carlisle, Cumberland County,
Pennsylvania.
2. Defendant is JONATHAN M. GRAY, who currently resides
~t R.D. 96, Box 25, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been a bona fide
~esidents in the Commonwealth for at least six months
.mmediately previous to the filing of this Complaint.
?laintiff has lived in Pennsylvania all of her natural life,
~eing 23 years.
4. The Plaintiff and Defendant were married on June 26,
1983 in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
~nnulment between the parties.
6. The Plaintiff has been advised of the availability of
narriage counseling and the Plaintiff may have the right to
SAIDIS&GUIDO request that the Court require the parties to participate in
26 W. High Street
Carlisle, Pa. ~ounseling. Having been so advised Plaintiff does not desire
5he Court to order counseling.
WHEREFORE, Plaintiff requests Your Honorable Court to
enter a decree in divorce.
Ed~a' . ' , -
Attorney for Plaintiff
SAIDIS & GUIDO
26 W. High Street
Carlisle, Pa.
COMMONWEALTH OF PENNSYLVANIA :
: SS.
COUNTY OF CUMBERLAND :
Before me, the undersigned authority, personally appeared
SUSAN M. GRAY who, being duly sworn according to law, deposes
and says that the averments contained in the foregoing
Complaint of which she has personal knowledge are true and
correct and those averments based on information received from
others she believes to be true and correct.
Sworn and subscribed to
before me this %~day
,
/
ROBERT C. SAIOlS, Notary Public
Carlisle, Cumberland Co. PA
My Commission Expires Au~Jst 14., 1981'
SUSAN M. GRAY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. CIVIL 1987
V. :
JONATHAN M. GRAY, :
Defendant : IN DIVORCE
AFFIDAVIT
I, SUSAN M. GRAY, being duly sworn according to law, deposes
and says:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling.
(2) I understand that the court maintains a list of
marriage counselors in the Prothonotary's 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 counselling 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.
./ Susan M. G~ay
Sworn and subscribed to
before me this %~day
EXHIBIT "A"
ELIZABETH GRAY
Attorney I.D # 48457
103 Township Line Road
Philadelphia, PA 19111
(215) 663-0400
SUSAN M. GRAY : COURT OF COMMON PLEAS
CUMBERLAND COUNTY
-vs- : NO. 68 CIVIL 1987
JONATHAN M. GRAY : IN DIVORCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the
defendant, Jonathan M. Gray, in the above captioned
matter.
ELIZABETH A. GRAY, ESQUIRE
~ f Attorney for defendant
DATE:_,/ ~ ~,~-
/
"' SUSAN M. GRAY, : IN THE COURT OF COMbION PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVanIA
Plaintiff .~
: NO. 68 CIVIL 1987
V. :
:
JONATHAN M. GRAY, : IN DIVORCE
Defendant :
:
'AFFIDAVIT OF CONSENT
(1) A Complaint in divorce under §201(c) of the Divorce Code
was filed on January 13, 1987.
(2) The marriage of Plaintiff and Defendant is irretrievably
broken and ninety 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 rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim them
before a divorce is granted.
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.
~ Susan M. Gray /
ELIZABETH GRAY, ESQUIRE
Attorney I.D.#48457
103 Township Line Road
Philadelphia, PA 19111
(215) 663-0400
SUSAN M. GRAY
, : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PA
: NO: 68 CIVIL 1987
JONATHAN M. GRAY,
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 201(C)
of the Divorce Code was filed on January 12, 1987.
2. The marriage of the plaintiff and defendant
is irretrievably broken and ninety days have elasped from the
date of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that if a claim for alimony, alimony
pendente lite, martial property or counsel fees or expenses
has not been filed with the court before the entry of a final
decreee in divorce, the right to claim any of them will be lost .
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.
] [ Jofathan' M. Gray'
D~endant