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HomeMy WebLinkAbout06-1654 KATHRYN GRIFFITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - LAW NO.Or" - 1bSf' CIVIL 2006 IN DIVORCE EUGENE D. GRIFFITH, Defendant NOTICE TO DEFEND 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 ATl1,RNE\'S.AT'lAW lNDSAY I SAlDIS, FLOWER & LINDSAY 26 West High Street Carlisle, f'A SAIDIS, FLOWER & LINDSAY ATTORNEYS'AT-lAW 26 West High Street CarlisJe,I'A KATHRYN GRIFFITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. PI, -1t.SlcIVIL 2006 v. EUGENE D. GRIFFITH, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. The Plaintiff is Kathryn Griffith, an adult individual, residing at 231 "G" Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Eugene D. Griffith, an adult individual, residing at 532 First Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint 4. The Plaintiff and Defendant were married on December 27, 1997 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. SAIDIS, FLOWER & LINDSAY ATIURNEYS.AToIAW 26 West High Street Carlisle,PA WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with S3301 of the Pennsylvania Divorce Code. Respectfully submitted, Dated 3/2.1 ( Cr.: C"J' " <--....; / /1 Carol J. LindsCly, Attorney Id. 4f693 26 West High.sm{.,t Carlisle, PA 1701:l (717) 243-6222 Counsel for Plaintiff SAllIS, FLOWER & UNDSAY ATIURNEYS.AT.lAW 26 West High Street Carlisle, PA 1\ VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S S4904, relating to unsworn falsifications to authorities I ~. , ~ <".' 4.." vttt1/iA ~. .4fvd-- Kath ryn Griffith . Date: 390 DC r....) I"--y ~~:;11 ~;\,., ('.i' .....{ -r-: ~r ;; ... c~ "69- (:::> '----- ~ ~ --'J S> ~ U[ - ~ C> -.{. D ~ ~ ~ --- --.a ---.:J f? ..~ {".j ~. . .-~ ~ ~'. KATHRYN GRIFFITH, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2006-1654 CIVIL EUGENE D. GRIFFITH, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of the firm of Broujos & Gilroy, P.C. and Hubert X. Gilroy, Esquire as attorney for Defendant Eugene D. Griffith. On behalf of the Defendant, I hereby acknowledge Receipt of Service of the Divorce Complaint and Accept Service ofthe Complaint as of March 24, 2006. Dated: March 23, 2006 Hubert X. roy, Esquire Broujos Gilroy, P.c. 4 N. Hanover Street Carlisle, PA 17013 (717) 243-4574 ID #29943 Attorney for Defendant ~.<^; ~"'.' C') SAIDIS, FlOWER &. LINDSAY ....._.-.01_ 26 West High Street Carlisle,PA II KATHRYN GRIFFITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1654 CIVIL 2006 IN DIVORCE v. EUGENE D. GRIFFITH, Defendant DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on March 22, 2006. 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 in 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 to the best of my knowledge, information and belief, I understand that false statements herein are made SUbject to the Date: YUk>" I penalties of 18 Pa.C.S. 4904 relating to unsworn falslfi DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER' 3301 leI OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that J may Jose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statement penalties of 18 Pa,C.S. 4904 relating to unsworn falsifi rein are made SUbject to the Date: '7f-io" c.) r't -' -n .-\ -C -r; ;'11;::-::- '"')'~~ .-''', -,-." .'," .<;" SAIDIS FlOWER'& UNDSAY JU.I~_._"'IJ/N 26 West High Street Carlisle,PA II KATHRYN GRIFFITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1654 CIVIL 2006 IN DIVORCE v. EUGENE D. GRIFFITH, Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9 3301 (cl of the Divorce Code was filed on March 22, 2006. 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 in 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 to the best of my knowledge, information and belief. 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: 7/Zflo& . .~~ PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER' 3301 leI OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 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 a divorce is granted. 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 made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: 1/ZEJ/Ob . . ~~,-~~ Kathryn Gri th l..,\~ \ \ \ \ r_.;' -(-..~ ',,:i;' ~~. ?~~'2.- ~7" ~.~ . ~. (,) ,~~ \^., J . SAIDIS, FLOWER & UNDSAY lU.u.>....."""",.IA.W 26 Wesr High Street Carlisle,PA II KATHRYN GRIFFITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-1654 CIVIL 2006 IN DIVORCE v. EUGENE D. GRIFFITH, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on March 23, 2006. An Acceptance of Service was filed with the Court on March 28, 2006. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: July 28, 2006 and filed with Prothonotary on August 1, 2006. By Defendant: July 26, 2006 and filed with Prothonotary on July 29, 2006. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated February 2, 2006, are incorporated, but not merged, into the Decree in Divorce. 5. executed: Date Waiver of Notice under Section 3301(c) of the Divorce Code yv'as By Plaintiff: July 28, 2006 and filed with Prothonotary on August 1, 2006. By Defendant: July 26, 2006 and filed with Prothonotary on July 29, 2006. .t- , .. SAIDIS, FLOWER &. UNDSAY AI" .~.u.w 26 West High Stteet Carlisle,PA II I CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Hubert X. Gilroy, Esquire Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 SAlOIS, FLOWER & LINDSAY . . ... 0 ..... ~ = c: = :z" .,... -oCjj > i~ 111r1! c:: Z:'J'~ C'> z5 (fl c- U1 .;..(,....,:.,. ~(> -;-T )>h ." :I:-rl ~~ :::Jt 0-- t5~ ~ ~ 0 W -< i , , i I , i , i I 1 I 1 I I I .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . + . . . . . . . + + + + . . + . + + . + + + + + + + + + + . + . + . . + . . . . . + . . + + + + + . 'f''t':t ~ '" '* :+ :+::f.:f. ... if.if.:f.:t: * :f.;+;;t; **** ;f.:+;;f.:f.:f.+:f.Cf.+ '+ +++ . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. KATHRYN GRIFFITH No. 06-1654 VERSUS EUGENE D. GRIFFITH DECREE IN DIVORCE AND NOW, ~ ,\},.s f ? '> KATHRYN GRIFFITH , Zoot" IT IS ORDERED AND DECREED THAT , PLAI NTI FF, AND EUGENE D. GRIFFITH , 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; The terms ofthe Separation and Property Settlement Agreement dated February 2, BYTHECO~ PROTHONOTARY +.~+'~:f:+;F*'f'''':+*;t''+':-f+ **""* . ++ ++++'+"1''1;'1''1' :t' +. :+.:+: +. +. +':+:f. '+' Of + + :+:+:+:+ '+' '" +. 'f 'to . +. + + + . + . + + + . + . + + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . + . . . . . . . . . . . . . . . + . . + + + . . J. . . . . . . . . . . . + . . . + . :+ i' ++. 51:'" l' ~ ~ "V$'P ~ "+'0 ~ 4.6; r9 1;}'5P ~ 71-. J-f' 'f/ '. , , " .