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Home My WebLink About06-2164Megan M. Grabiec, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Joseph O. Grabiec, : NO. 06 -,?I b q CIVIL TERM 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 action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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 Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION 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, PA 17013 Phone: (717) 249-3166 (800)990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Megan M. Grabiec, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW Joseph O. Grabiec, : NO. 06 - CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Megan M. Grabiec, an adult individual, who resides at 42 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Joseph O. Grabiec, an adult individual, who resides at 42 Partridge Circle, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on February 20, 2000 in Waipahu, Honolulu, Hawaii. 5. There have been two prior actions for divorce between the parties hereto in Perry County, Pennsylvania and Dallas County, Texas. The Perry County divorce petition was withdrawn on November 8, 2005 and the Dallas County divorce petition was withdrawn in April 2005. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff Megan M. Grabiec, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. Joseph O. Grabiec, Defendant : CIVIL ACTION - LAW NO. 06 - IN DIVORCE CIVIL TERM VERIFICATION I verify that the statements made in this Complaint 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. Date: u? T C?WC q / , b ?? ';?4c Megan rabiec, Plaintiff (`i ?? ? ?? '?` ?? ( ? . ?`+? ./try/ l 11 ,l • } f MEGAN M. GRABIEC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 06-2164 JOSEPH O. GRABIEC, : CIVIL ACTION - LAW Defendant : IN DIVORCE STIPULATION AND NOW on this day, hereinafter set forth, the parties hereto stipulate and agree as follows: 1. On or about April 12, 2006, the Plaintiff filed a Protection from Abuse against Defendant. 2. A temporary Protective Order was entered in this matter and has continued to be in effect due to joint requests for continuance of the hearing on the PFA case. 3. Plaintiff filed a Complaint in Divorce on or about April 17, 2006. 4. Plaintiff has remained in the parties' former marital residence located at 42 Partridge Circle, Carlisle, Cumberland County, Pennsylvania to Defendant's exclusion. 5. Defendant has agreed to provide Plaintiff with exclusive possession of the aforesaid rented property. 6. In return for Defendant's agreement to provide Plaintiff with exclusive possession and consideration of the best interests of both parties and their children in the present proceedings, Plaintiff shall withdraw her Protection From Abuse Action contemporaneously with the filing of the within Stipulation. 7. The parties wish to have the Court enter an Order or Orders as follows: (A) Plaintiff shall have exclusive possession of the residence of 42 Partridge Circle, Cumberland County, Pennsylvania; (B) Defendant shall be permitted to remove items of personal property including his clothing and other personal items pending comprehensive resolution of the property distribution aspects of the divorce case, with the time and arrangements for the securing of the personal property to be agreed upon in writing through counsel. (C) Plaintiff shall execute a Petition to Withdraw and Vacate the Protection from Abuse Order in this matter contemporaneously with executing this Stipulation. NOW THEREFORE, the parties hereto stipulate and agree as follows on the day herein b16[w Date 6. 9 Date osepn u. urabiec, llletendant ? R) r L.... Y7_- •. c lii RECEIVED JUN 2220066 M. GRABIEC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06-2164 0. GRABIEC, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER AND NOW, this day of June 2006, upon presentation and consideration of the Stipulation, it is hereby Ordered and Directed as follows: 1. Plaintiff is granted sole and exclusive possession of the parties' former marital residence located at 42 Partridge Circle, Carlisle, Cumberland County, Pennsylvania. 2. Defendant shall be permitted to return to the marital residence at a time and under circumstances agreed upon in writing between counsel for the purpose of removing his clothing and other personal property items pending a comprehensive resolution of the property distribution aspects of the parties divorce; 3. Contemporaneously, with the entry of this Order, the Court shall enter an Order vacating the prior temporary Protective Order filed in the Protection from Abuse action docketed to No. 06-2063 in the Court of Common Pleas Cumberland County Pennsylvania. BY THE 9OURT, 1. \ ?l EDGAR B. BA i 1 v .,., ?J . ??, c? .? r ,? ,c,? ;, , ?, 7 3 .Cal' : ?'. " } ,1,U? si ?,; ?:__? ,?, .r• MEGAN M. GRABIEC, Plaintiff VS. JOSEPH O. GRABIEC, Defendant PRACEIPE TO ENTER AND WITUDRAW APPEARANCE TO THE PROTHONOTARY: Kindly withdraw the appearance of Karl E. Rominger, the Plaintiff. Date: (?f-. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2164 CIVIL ACTION - LAW IN DIVORCE I B' as counsel of record on behalf of Karl E. Rominger, Esquire Sup. Ct. ID No. 81924 155 South Hanover Street Carlisle, PA 17013 Kindly enter the appearance of Andrew H. Shaw, Esquire as counsel of record Date: 7-0 Atfdrew H. Shaw, Esquire Sup. Ct. ID No. 87371 61 W. Louther St. Carlisle, PA 17013 717-249-1177 Plaintiff. Y? I@ CERTIFICATE OF JERVICE I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following document, Praecipe To Enter and Withdraw Appearnace, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Bradley L. Griffie, Esquire Griffie & Associates 200 North Hanover' Street Carlisle, PA 17013 Attorney for Defendant ' Date: 7 7 0( MEGAN M. GRABIEC Plaintiff vs. JOSEPH O. GRABIEC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2164 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April 17, 2006 and served on/or about April 19, 2006 as indicated in Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES QF 18 a.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. /1 I DATE: 6 ! o Axx?' 0. GRABIEC, Defendant n G `. ? ?= Gs vi Ul pr N MEGAN M. GRABIEC Plaintiff VS. JOSEPH O. GRABIEC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2164 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 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 property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT F SE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF18 C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. A / DATE: Cr 5 Z.0O. GRABIEC, Defendant Ln r..? G MEGAN M. GRABIEC Plaintiff VS. JOSEPH 0. GRABIEC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2164 IN DIVORCE ACCEPTANCE OF SERVICE I, Bradley L. Griffie, Esquire acknowledge that on or about April 19, 2006 I received a Complaint in Divorce in the above captioned action and acknowledge that I am authorized to do so on behalf of Defendant, Joseph 0. Grabiec Date: LM 9? D (o 2ffie, Esquire orney or Petitioner 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 it s fl n2, r' to _o MEGAN M. GRABIEC Plaintiff vs. JOSEPH O. GRABIEC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-2164 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April 17, 2006 and served on/or about April 19, 2006 as indicated in Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 THE FOREGOING 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. 1 DATE: r J MEGAN M. GRABIEC, Plaintiff t!y .? ??-? ? ? ? ? ? aC' ..3 MEGAN M. GRABIEC Plaintiff VS. JOSEPH O. GRABIEC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 06-2164 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 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 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 THE FOREGOING 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. DATE: -9//3/07 / - "" r'j MEGAN M. GRABIEC, Plaintiff ..., ?? ? ? ..? :.a ..3 MEGAN M. GRAB C Plaint vs. JOSEPH O. GRAB C, Defe dart : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2164 IN DIVORCE PRAECM TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the recordp together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable (breakdown under §3301(c) 3301(d)(1) of 1-bee MWOM Ge&. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on April 19, 2066. 3. Complete either aragraph (a) or (b). (a) Date of ex cution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff. 9/13/2006 by Defendant: 8/15/2006 (b) (1) Date o execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date o filing and service of the plaintiff s affidavit upon the respondent: 4. Related claims ending: none 5. Complete either! (a) or (b). (a) Date and !manner of service of the notice of intention to file Praecipe to Transmit record, ?a copy of which is attached: (b) Date of plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 14, 2007 Date de endant's Waiver of Notice in §3301 (c) Divorce was filed with the Protho otary: August 21, 2006 4e, Esquire ASSOCIATES Attorney for Pla intiff Fn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MEGAN M. GRABIEC Plaintiff VERSUS NO. 06-2164 JOSEPH O. GRABIEC Defendant DECREE IN DIVORCE AND NOW, b ,'C!? 1 IT IS ORDERED AND .21 MV PPMM or2s DECREED THAT Megan M. Grabiec , PLAINTIFF, AND Joseph O Grabiec , 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 BY THE-CC(URT: ATTEST: J. PROTHONOTARY 7 ?v Lo. e -d1 • • x