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CATHERINE H, HEMPSTEAD,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
IN DIVORCE
TIMOTHY W. GRIGGS,
Defendant
NO.
CIVIL 1995
PETITION TO PROCEED IN FORMA PAUPERIS
Catherine H. Hempstead, plaintiff in the above titled action,
respectfully requests this Honorable Court to grant her leave
pursuant to Pa.R,C.P. No. 240 to proceed in forma pauperis to the
extent that she be relieved of all costs attendant to this action.
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Date
Respectfully submitted,
SODUS & V~RNEY
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Lay Da~i~l ~ >- ~~d~
1.0, No. 63114
7 Irvine Row
Carlisle, PA 17013
717/243-9190
Attorney for Plaintiff
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Esquire
CATHERINE H. HEMPSTEAD,
Plaint! ff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
TIMOTHY W. GRIGGS,
Defendant
NO.
CIVIL 1995
AFFIDAVIT SUPPORTING PETITION FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
TO THE HONORABLE JUDGES OF SAID COURT:
The petitioner, Catherine H, Hempstead, residing at Cumberland
County, Pennsylvania, deposes and says:
1. I am the named plaintiff in the above titled civil cause
of action and the defendant is Timothy W. Griggs.
2, This affidavit is made to inform the court as to my
status of indigence and to induce the court to grant me leave to
proceed in this cause as an indigent.
3. In making this affidavit, I am aware that perjury is a
felony and that the punishment is a fine of not more than $3,000 or
imprisonment for not more than seven years or both.
4. I do not have any money on my person, at home, or
elsewhere which could be used for expenses of this proceeding.
5, I do not own real estate, personal property, or any other
assets, I am not owed any amounts of money by any person.
6. My husband, Timothy W. Griggs, presently resides at 127
Hershey Road, Shippensburg, Pennsylvania 17257. He is 36 years
old,
(a) I last lived with my husband on January 26, 1994.
(b) I do not have information or knowledge as to whether
my husband is employed, has any money, owns an
automobile, owns real estate, or has any other personal
property or assets; except for (1) automobile
approximately 10 years old, and (2) trailer approximately
1 year old.
(c) Plaintiff anticipates that Defendant husband will
oppose an entry of decree in divorce.
(d) I have not brought action for child support
payments.
7. I have three children: Zachary, born November 1, 1984,
Amber, born December 29, 1986, and Jacqueline, born September 10,
1988, who reside with Timothy W. Griggs at 127 Hershey Road,
Shippensburg, Pennsylvania 17257.
8. I am presently an intern at Rite Aid Corporation since
August 7, 1995.
9. My social security number is 178-50-3253.
10. I have no monthly income.
11. My monthly expenses are as follows:
(a) Rent - $375.00
(b) Gas - $10,00
(c) Electric- $40.00
(d) Telephone - $26.00
12. My husband and I have not maintained a checking account
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CATHERINE H. HEMPSTEAD,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
TIMOTHY W. GRIGGS,
Defendant
NO.
CIVIL 1995
COMPLAINT IN DIVORCE
1. Plaintiff is CATHERINE H. HEMPSTEAD, an adult individual,
currently residing at 3 East Louther Street, Carlisle, Cumberland
County, Pennsylvania.
2. Defendant is TXMOTHY W. GRIGGS, an adult individual,
currently residing at 127 Hershey Road, Lot 13, Shippensburg,
Cumberland County, Pennsylvania and/or 4608 Warrington Avenue,
Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the
Commonwealth of Pennsylvania and have been so for at least six
months immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married beginning in August
1983, by Common-Law,
in Mechanicsburg, Cumberland County,
Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6, The Defendant is not a member of the Armed Forces of the
United states of America, or its Allies,
7. The Plaintiff has been advised of the availability of
counseling and the right to request that the Court require the
parties to participate in counseling. Knowing this, the Plaintiff
VERIFICATION
I verify that the statements made in the foregoing divorce
complaint are true and correct, I understand that false statements
herein made are subject to the penalties of 16 PA,C.S. Section 4904
relating to unsworn falsification to authorities.
Date:
17
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CATHERINE H. HEMPSTEAD,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAN
NO. 95-4959 CIVIL TERM
TIMOTHY N. GRIGGS,
Defendant
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please reinstate the Complaint in Divorce filed on or about
September 18, 1995 by Daniel J. Sodus, Esquire on behalf of the
Plaintiff, Catherine H. Hempstead, in the above captioned action,
Respectfully submitted,
SODUS & VERNEY
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S, , hquire
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17013
Plaintiff