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HomeMy WebLinkAbout06-1120 1'1 RANDY C. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006- ;/.){) CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION-LAW 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 the diyorce 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 , , - !i II Ii I , i RANDY C. GRIFFIE, I Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006- J / ;)d CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTION 3301/d) OF THE DIVORCE CODE 1. Plaintiff is Randy C. Griffie, an adult individual who currently resides at 190 Pine School Road, Gardners, Cumberland County, Pennsylvania 17324. 2. Defendant is Shannon M. Griffie, an adult individual who currently resides at 15 Ball Park Drive, Gardners, Cumberland County, Pennsylvania 17324. 3. Plaintiff and the Defendant have been bonafide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 29, 1997, in Mt. Holly Springs, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above. 6, There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 7. Plaintiff and Defendant are not in the Armed Forces of the United States. 8. Plaintiff avers that the marriage between the parties is irretrievably broken. " I I I 9. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. Respectfully submitted, O'BRIEN, BARIC & SCHERER II II II I I 2.2.'-1. ()c, 1I/i0fv- Michael A. Scherer, Esquire 1.0. # 69174 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Date: I \ II II I mas.dir/domestic/griffie/divorce.pld ,I .> VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. I \ \ 'I :1 II Ii I I II I C.S. S 4904, relating to unsworn falsification to authorities. ; '~' '/' >' . , . . . j ,', '. J ,/ i -)' f"';~v..j'J' \.., /\'-i~ (Randy C. Gri if , "I '., Date: ^- - '" -Ct.. e:--" \~) \\ ::J d --c:.. ~ '.j 'b ~ ',- ~ c" ~ ~ ,~V" - ...." , \;" \'\ (j\ \j) ~ ~ ~ 't, ~ , ~, , . '. \'.^-, ;: ~J -~ r \ . . :::~ r.: ';';-1 ~'" . ,--' '.... .---- ~\~ ( il- ~ , ' ,-I', r ,n ; ~ .-- C;'. RANDY C. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2006 - 1120 CIVIL TERM SHANNON M. GRIFFIE Defendant CIVIL ACTION-LAW IN DIVORCE II il I , I i I ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. ( " :2 [\j'1 Date:j)'. it)' ../"--' 15 Ball Park Drive Gardners, Pennsylvania 17324 ( c t ..... 'I RANDY C. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - 1120 CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301/d) OF THE DIVORCE CODE 1. The parties to this action separated in the year 2000 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 I I verify that the statements made in this affidavit are true and correct. I I understand that false statements herein are made subject to the penalties of 18 I! Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: .3 - [)-o& 4G/~ Randy C riffie I, t ~ " II 1 RANDY C. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - 1120 CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. , I , , I I i I, II II the Court and that a copy of the decree will be sent to me immediately after it is filed , 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before the divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by with the Prothonotary. I verify that the statements in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.SA 4904 relating to unsworn falsification to authorities. Date: 3 -8-<!J<t- ~{~ Randy C. Gr ,. .' 'i' ""- - - I ' RANDY C. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 - 1120 CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER ~ 3301ld) OF THE DIVORCE CODE II 1. Check either (a) or (b): ~ (a) I do not oppose the entry of a divorce decree. _ (b) I oppose the entry of a divorce decree because: (Check (i), (ii) or both): _ (i) The parties to this action have not lived separate and apart for a period of at least two years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): t(a) I do not wish to make any claims for economic relief. 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. Ii _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-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 authoritie Date: 03) 1//06 NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. 1- () ~:::- "-,,) C:'_") (:-.:~) ~>\ ""', ~~:;,~ ~) .'\,.) "0 ~1 :.::~ I~:) C-r Q:>' 'I RANDY C. GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2006 -1120 CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301ldl OF THE DIVORCE CODE I, II il I, I, , property, lawyer's fees or expenses if I do not claim them before the divorce is granted. I I I I I I I II I 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of 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 in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. Date:-ID)I~~ i./tXJ0JL! ~)L(__ Shannon M. ~ ,......) c:-:) (-'1 0:::.-;:1 "::;'t C,.... -'. .,~.;.~ r"-,) N " r<> en C) II RANDY C, GRIFFIE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO, 2006 - 1120 CIVIL TERM SHANNON M. GRIFFIE, Defendant CIVIL ACTION - LAW 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, Code, Ground for divorce: irretrievable breakdown under Section 3301 (d)of the Divorce , I , I II I' II I 2, Date and manner of service of the Complaint: Defendant signed an Acceptance of Service on March 3, 2006. 3, Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: March 8, 2006, Date of service of the Plaintiff's Affidavit upon the Defendant: March 15, 2006, 4, Related claims pending: None, 5, Indicate date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce Code: Notice was sent by regular, postage prepaid mail to the Defendant's address of record, namely Shannon M, Griffie, on March 15, 2006, and Defendant signed attached Waiver on March 16,2006. Respectfully submitted, O'BRIEN, BARIC & SCHERER J1IifJ,~ Michael A. Scherer, Esquire () (~ ..",.. ,~. -r:"l-:~ , ~:)\, .f.;~ 1!;', ~:::~ '. r--' c.'::> c;? 0" ::;: V' _"'- I x;- '"" -' - -;:~. C") .n .-1 :r:4"'l rnp ~~ t:~, i:) )-, <.f? x;- u:> --- ..-,~ .-~_C ?\~I ~ > IN THE COURT OF COMMON PLEAS > OFCUM8ERLANDCOUNTY STATE OF RANDY C. GRIFFIE, > > > Plaintiff > VERSUS > SHANNON M. GRIFFIE, > Defendant > > > CIVIL > > > > > > > > > > > > > PENNA. No. 2006 - 1120 > DECREE IN DIVORCE > > > G:1 ~. ")~j'J~ , ,~, IT IS ORDERED AND > AND NOW, /Hvo If) > DECREED THAT RANDY C. GRIFFIE PLAINTIFF, > > > AND SHANNON M. GRIFFIE , 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. > > Arr,,"~~ > > > PROTHONOTARY > > > >" > > > > > > > > > > > > > > > > > > > > > > > > > . > > > > > > > > > > > > J. > > > > > . > > . > > > > > > > > > > > >> .~t!~~ N''e/'? ,-%,p~~_~p; "}(J''el-F . ~ . \ .. .....!~.~ ....'. '\ "",-., ~ .. -. '. *' ..........