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Home My WebLink About02-1109MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : No. IlO cIvm TEn ; ; : 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 the court may enter a decree of divorce or annulment against you. 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 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 Tl~E 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, TO GET LEGAL ltF~LP SHOULD CONTACT: Cumberland County Lawyer Referral Service 2 Liberty Avenue, Carlisle, Pennsylvania 1-(800)-990-9108 Dated: COYNE & COYNE, P.C. //~l~isa Marie Co~ne, Esquire 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. Supreme Ct. No. 53788 Attorney for Plaintiff MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN TI~E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ ~ It_t~ CIVIL TERM IN DIVORCE TO THE HONORABLE, JUDGES OF SAID COURT: NOW COMES the Plaintiff, Mark E. Griffin, by his attorney, Lisa Marie Coyne, and files this Complaint In Divorce and avers the following in support thereof: 1. Plaintiff, Mark E. Griffin, is an adult individual residing at 212 State Street, Enola, Cumberland County, Pennsylvania. 2. Defendant, De-Anne M. Griffin, is an adult individual residing at 51 Basin Road, Hammonton, New Jersey. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months ~revious to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 9, 1990, at Fawn Grove, York County 'ennsylvania, and separated on or about June 1, 1993. o Allies. 6. 7. The Defendant is not a member of the Armed Services of the United States or any of its There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 8. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, if both parties file affidavits consent to a divorce after ninety (90) days have elapsed from the filing of this Complaint, or alternatively if the appropriate time has elapsed since date of separation, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce pursuant to Section 3301(c) or Section 3301(d) of the Divorce Code, as may be appropriate. COUNT I - EQUITABLE DISTRIBIYFION 10. 11. marriage. 12. Paragraphs 1 through 9 of this Complaint are incorporated by reference. Plaintiff and Defendant have accumulated assets and debts during the course of their Plaintiff and Defendant have been unable to agree as to the equitable division of said property and debt. Wlt'EREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debt pursuant to the Divorce Code. Dated: Respectfully submitted: COYNE & COYNE, P.C. By: ~)/~ ~ -- //LISA MARIF_/CO~, Esquire ~ ~901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff The facts set forth/n the foregoing are tree and correct to the best of the undersigned's knowledge, inform~6on and belief and are verified subject to the penaltie~ for unswom falsification to authorities under 18 Pa. C.S.A. §4904. MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. : IN THF. COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1109 CIVIL TERM .. _. : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 5, 2002. 2. The marriage of plaintiff and defendant is irre~a-ievably 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 unswom falsification to authorities. Date: , Plaintiff MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1109 CIVIL TERM : : : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODF~ 1. I consent to the entry of a final decree of divorce without notice. 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. o 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~' ~ ]~IARK E. (~l~tl~, Plaintiff MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 2002- 1109 CIVIL TERM _* ; : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 330 l(c) of the Divorce Code was filed on March 5, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed fi.om 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Date: DE-ANNE M. Defendant MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. : IN TH'E COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : NO. 2002- 1109 CIVIL TERM ; ; : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF T1]F~ DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I understand that I will not be divorced until a divorce decree is entered by thc 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 arc 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. Date: DE-ANNE M. G~/~N, Defendant MARK E. GRIFFIN, Plaintiff, VS. DE-ANNE M. GRIFFIN Defendant. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002- 1109 CIVIL TERM : : IN DIVORCE PRAECIPE TO TRANSMIT RECORr{ TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. 1. ~ Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce 2. Date and manner of service of the complaint: March 9, 2002 by Certified Mail. Restricted Delivery. 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by plaintiff on June 25, 2002; by defendant on July 3, 2002. 4. Related claims pending: NONE 5. Date Plaintiff's and Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 3, 2002. Date: COYNE~ COYNE, PfC. / $ISA 1V~xARI~2 C~YNE, ESQUII~ / J3901 Market St./ ' C~p ~i!1; PA 170114227 (71~ 737-~ P~ Supreme ~ No. 53788 ~aorn~ for Pl~n~ff OF CUMBERLAND IN ThL cOUrt OF COMMON PLEAS COUNTY STATE OF ~ PENNA. MARK E. GRIFFIN, Plaintiff Versus .~.~r~.N~E..~.t._~!~, ................................. Defendant DECREE IN D.~c~ V O R C · AND NOW,..~._~..j .................. djlll~.. 2.Q0~ it is ordered and decreed that ............ ~~.~..~.... ?.z.~..~.z?. ....................... plaintiff, and DE-ANNE M. GRIFFIN 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. / ~ Prothonotary