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Home My WebLink About06-2761,, ADO NISSA M. GREENE, : THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. OL - o< < b ?t v i h? STEVEN H. GREENE, CIVIL ACTION - AT LAW Defendant : 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 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 Courthouse, Carlisle, Pennsylvania. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3308 (717) 249-3166 A A NISSA M. GREENE, Plaintiff V5. STEVEN H. GREENE, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW IN DIVORCE AND NOW comes the Plaintiff, Nissa M. Greene, by and through her attorney, Jeanne B. Costopoulos, Esquire, and avers the following in support of this Complaint in Divorce: 1. The Plaintiff, Nissa M. Greene, is an adult individual who currently resides at 12 W. Main Street, New Kingston, Cumberland County, Pennsylvania, 17072. 2. The Defendant, Steven H. Greene, is an adult individual who currently resides at 157 Whiskey Run Road, Newville, Cumberland County, Pennsylvania 17241. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 27, 1997 in Hialeah, Florida. Count I - Divorce 5. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievable broken. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. %1 U 9. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 10. There are two dependent children from this marriage, namely Connor Robert Greene, born October 7, 1999, and Abigail Mae Greene, born May 21, 1998. 11. This action is not collusive. RESPECTFULLY SUBMITTED: Dated: akne B. Costopoulos, Esquire 3803 Gettysburg Road Camp Hill, PA 17011 PA Supreme Court ID No. 68735 Telephone: (717) 920-2500 Fax: (717) 920-9108 ATTORNEY FOR PLAINTIFF ,401. • NISSA M. GREENE, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 06- --4-761 STEVEN H. GREENE, : CIVIL ACTION - AT LAW Defendant : IN DIVORCE VERIFICATION I, Nissa M. Greene, hereby verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. Date: Signature: i a ene A" .. n, ? ? N a C? m m .-t_ CJ p 2 cn rn i? NISSA M. GREENE, Plaintiff vs. STEVEN H. GREENE, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-2761 CIVIL TERM CIVIL ACTION - AT LAW DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Divorce filed at the above-referenced term and docket on May 15, 2006. BY: c Jeanne B. Costopoulos, EsquireATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 DATE: -Fllf/06 PA Supreme Ct. ID No. 68735 a o ? JCT m- ,, m ?' c. tv a cn ca NISSA M. GREENE, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 06-2761 CIVIL TERM STEVEN H. GREENE, CIVIL ACTION - AT LAW Defendant DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) 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 on August 6, 2004 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. 4. I hereby verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: ` Signature: issa Greene O v°> 06 NISSA M. GREENE, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06-2761 CIVIL TERM STEVEN H. GREENE, CIVIL ACTION - AT LAW Defendant DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE 1. I, Nissa M. Greene, am the Plaintiff in the above matter. 2. I personally know that the Defendant, Steven H. Greene, is over the age of eighteen (18) years and that he currently resides at 157 Whiskey Run Road, Newville, Cumberland County, Pennsylvania, 17241. 3. The Defendant is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldier's and Sailors Civil Relief Act of 1940 and its amendments. 4. I hereby verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature: sa .Greene o O ?r G N c. C) G t`? Z Cil NISSA M. GREENE, THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06-2761 STEVEN H. GREENE, : CIVIL ACTION - AT LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby verify that on this date I personally hand- served upon the Defendant the following documents: 1. Complaint in Divorce originally filed May 15, 2006, reinstated on August 17, 2006. 2. Praecipe to Reinstate Complaint filed August 17, 2006. 3. Affidavit under Section 3301(d) of the Divorce Code filed August 23, 2006. 4. Affidavit of Non-Military Service filed August 23, 2006. 5. Counter-Affidavit under Section 3301(d) of the Divorce Code (blank) I verify that the statements made herein are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. BY: -10-- eanne B. Costopoulos, Esquire 3803 Gettysburg Road Camp Hill, PA 17011 PA Supreme Court ID No. 68735 / Telephone: (717) 221-0900 Dated: 30 ?b Fax: (717) 914-1520 ATTORNEY FOR PLAINTIFF N Q D b ?j O "G?? f '- y C? a ?:? , N f <.:_ ? ; ? ? ? - NISSA M. GREENE, Plaintiff vs. STEVEN H. GREENE, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 06-2761 CIVIL ACTION - AT LAW DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COI INSELINCr 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 15, 2006, and reinstated on August 17, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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. 4. 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. Dated:1 Signatw ?? C" r ? ?_:; ?__:i cC?:? ._i r €'?,: C'».? _ Y __: ?.? ``3 i ,. JFf. NISSA M. GREENE, Plaintiff vs. STEVEN H. GREENE, Defendant : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 06-2761 : CIVIL ACTION - AT LAW : DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE I INFER SECTION 1301(c) OF THE nTVC)RC E C ODE 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. 4. 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 unworn falsification to authorities. Dated: Li-11 J) I n I? Signature: C"? 1 r"" . i ("= ?.' *>) _ w? l_ r ?7 ?? c`?.. ?4_ } ?. .+6... 7Fit NISSA M. GREENE, Plaintiff VS. STEVEN H. GREENE, Defendant TO THE PROTHONOTARY: 2019 MAY -6 AN 9: 66 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2761 CIVIL TERM IN DIVORCE PRAECIPE Please withdraw all economic claims previously filed in this matter on behalf of the Defendant Steven H. Greene. 4 May 2010 S L. Andes Attorney for Defendant Supreme Court ID # 17225 525 North 12' Street P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 NISSA M. GREENE, Plaintiff VS. STEVEN H. GREENE, Defendant FlE ?.; ?:. ,vL t It 2010 M.AY -G AH 9: 5) ) PRAECIPE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2761 IN DIVORCE TO THE PROTHONOTARY: Please withdraw any claims for alimony, alimony pendente lite, counsel fees and expenses, or equitable distribution previously filed on behalf in the above action. Date: issa 14. Gree Plaintiff Fly E?-??t -,U?= 1 i 1riV 1y:. TI PIE NISSA M. GREENE, Plaintiff vs. STEVEN H. GREENE, Defendant 2010 MAY -6 AiN 9: 65 CL'Pe`) t', ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2761 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 15 May 2006 and served upon the Defendant within thirty days thereafter. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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. 1 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. 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. Dated: XfSSAWGftFW r rte. ? 2010 MAY _6 AN 9: 66 NISSA M. GREENE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. STEVEN H. GREENE, Defendant CIVIL ACTION - LAW NO. 06-2761 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. Ground for divorce: Irretrievable breakdown under 3301 (c) 2. Date and manner of service of the complaint: Divorce Complaint was reinstated on August 17, 2006 and served upon the Defendant within thirty days thereafter. 3. a. Date of execution of the Affidavit of Consent required by 3301 (c) of the Divorce Code: By Plaintiff: 4 May 2010 By Defendant: 22 April 2008 4. Related claims pending: None. 5. Date of Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: 4 May 2010 Date of Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: 22 April 2008 Samuel L. Ande Attorney for Defendant Supreme Court ID # 17225