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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