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Home My WebLink About98-04465 , , t ,'"" ., .. ' "T'" Cynthia M. Crawford, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : NO, 98.~"l{.cIV1L TERM v, John J. Crawford, Defendant 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 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, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249,3166 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. _ I, .",. '~, ':, " '(.','," . :" ..:'..' '..:.' ......;, ' ' ,,' ,~., .'" .', "i t,l,'~'.' '. :'." Cynthia M. Crawford, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. John J. Crawford, Defendant , ; NO. 98- 4Llu,r-; CIVIL TERM COMPLAINT UNDER 23 Pn,C,S, ~l\ 330tlc) nnd 330tldl OF TIlE DIVORCE CODE The plaintiff, Cynthia M. Crawford, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Cynthia M. Crawford, who currently resides at 426 First Strcct, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is John J. Crawford, who currently resides at 1619 G1enbrook Avenue, Coraopolis, Allegheny County. Pennsylvania 15108. 3. Plaintiff has bccn a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on May 23, 1992. 5. Plaintiff and defendant have lived separate and apart sinee May 14, 1995. 6. There have bccn no prior actions of divorce or for annulment betwccn the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has bccn advised that counseling is available and that plaintiff or defendant may have the right to request that the court require the parties to participate in counseling. 't"' '.....,... WHEREFORE, plaintiff requests the court 10 cntcr a decrce of divorce dissolving the marriage. Date ') J ,c/ '"~ , , , il/' .' " , I ,,' '''' .i,_ (';" ,I 1 , / }'i, iI". I Megan C, 'Huff Certified Legal Intern u~, 'l W61r!1 f\\\?kL THOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S, ~4904, relating to unsworn falsification to authorities. Date: ~0'9f 'I' .;~'" '. J," ' , ,..:.r '...~,..t,'_ ';,..-,., " , "',) ...., ~, ,~-) -. ~~;J -', ,." ) V '.;1 i:::: C"- tl ().. ,~ C~) 1..( ell u.. h I) " :> ;'{j{ J> /: ,0 ," ~ ' tI '" .--' ! ~J- ..'..~ , c~ ~':.i ( , u' U " , , , . ,f, I ' , . .' . .' : "..: '. '~ . <I,... '. <, . , , I' ., '',:.::' " .' " . ~ \' . , ' . Cynthia M. Crawford, Plaintiff IN TilE COURT or COMMON PLEAS or CUMllElU-AND COUNTY, PENNSYLVANIA CIVIL ACTION.LA W v. John J. Crawford, Dcfendant NO. 98- ./'iuS CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Cynthia M. Crawford, Plaintiff, to proceed in forma pauperis. I, Megan C. Huff, of the Family Law Clinic, Certified Legal Intern for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party, The party's affidavit showing inability to pay the costs of litigation is attached hereto. Date: -11?,r->ICJ-" , \,j Ii I , <f-:'yl>, fl., ) \.- -- -.iJ :' 'v I / /I,.\-ll..... \..__ Megan C. Huff Certified Legal Intern ]JJ~ Mmr ROBERT E. RAmS THOMAS M. PLACE KATHERINE C. PEARSON Supervising Attorney DONALD MARRlTZ Staff Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 . ~ ~ . " " . ",. '.. ' I..." " .' eo I, ... ~ ' , , ,'. Disability payments: $0 Unemployment compensation and supplemenlal benefits: $0 Workman's compensation: SO Public Assis::uJce: SO Other: SO (d) Other contributions to household support: SO Contributions from children: $0 Contributions from parents: SO Other contributions: $0 (e) Property owned Cash: SO Checking account: SO Savings aecount: SO Certificates of deposit: SO Real estate (including home): N/ A Motor vehicle: 1990 Chevrolet Cavalier Amount paid: $13,000 Amount owed: $0 Stocks; bonds: $0 Other: SO (I) Debts and obligations Mortgage: N/ A Rent: S325/month Loans: SO Other: Day Care: Sl40/month Phone: S70/month Electric: S65/month Credit Card: S70/month Medical Bills: S40/month Gas: S52/month Laundry: S35/month Food: S200/month Non-Food Household Goods: S20/month Car maintenance: S20/month Car registration and insurance: S50/month (g) Persons dependent upon you for support (Wife)(Husband) Name: NtA Children, if any: Name: Age: Corinne Crawford 5 Other persons: Nt A Name: Relationship: ; CD I. : , , 1":-: " , , I , " .. IU 0,_1. :l~ l) ( ..,,) {J', U . .' . 'o.! '. " .' "" ., . ',." : " _' ,; ," ~ ... , '-, '. .", .,' '. ~, , . j " I Cynthia M, Crawford, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE v. John J, Crawford, Defendant ; NO. 98- '-/4US CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counleraffidavit within twenty clays after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF TIlE DIVORCE CODE 1. The parties to this action separated May 14, 1995, and have continued to live separate and apart for a period of at least 3 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 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 falsifieation to authorities. Date gd~7R , " " : -. " " ., ," '1 : - c: iD ~J... c.::' , ,- c" ':-j c 0" 0 , :'-:'1 ::-,.-:: ,~~:,:,':", !:.. '.,.' .'",:: . ",1", ,..,"',.1':", '.::~,~,f:".':""'l"" ,~';.:',._-"-'''' ...~... -:-t' .. ~, ,.,-0\ ",- a . r:; <.'r;: " " ( , UJi~ (.);". . . w~ ::-~ .,-. C', ::;~ f . I.;"': / ._J , (,". !.i L"::' -, " ;:2 ,.-- . " m -~) CI C" U r' . t...:",'~,~'., ,_' '< __,' :~,'.~:.. '..' ~'~' ',..: :,~-"\ ':.' I. t,.' , 0:.' .', ~1. . :-~-.:..","."~'o,_~..~ :~...._..':', -'.,:" :,', ;,,', . Cynthia M, Crawford, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE v. John J, Crawford, Defendant NO. 98-4465 CIVIL TERM DEFENDANT'S COUNTER-AFFIDAVIT UNDER ~3301(d) . OF TilE DIVORCE CODE 1. Check either (a) or (b): ( ) (a) I do not oppose the entry of a divorce deeree. ( ) (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): ( ) (a) I do not wish to make any claims for eeonomie 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 divoree is granted. () (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 ofIntention to Request Divorce Decree, the divorce decree may be entered without further delay. 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. ~4904 relating to unsworn falsification to authorities. Date John J. Crawford, Defendant 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. ,'~. ....:., .'" ":,,. ,', ,,'<,'~f,,' ",',~:~,,'; I', t."'~ .' '. I,: ','_~O "'_'.'_:~~'.;,:.'"_".\.. ,*^,.'~' : .\,' ~' Cynthia M. Crawford, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMUERLAND COUNTY, PENNSYLVANIA IN DIVORCE v. 10hn 1, Crawford, Dcfcndant NO 98-4465 CIVIL TERM CERTIFICATE OF SERVICE I, Megan C. Huff, hcrcby ccrtify that I am scrving a true and correct copy of the Notice of Intention to Request Entry of Divorce Deeree and Defcndant's Counter-Affidavit on 10hn 1. Crawford, residing at 1619 Glcnbrook Avenue, Coraopolis, AlIcghcny County, Pennsylvania 15108 by depositing a copy of the same in the United States first class mail, postage prepaid, this ;C:' I "~I day of August, 1998, FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 ',. ': ,',', 'r,!': '\', . ,"II.' ',~, : ':~ : ..~:,~":'_:','::" __'~:a :." .,'r::.."." ..., Cynthia M. Crawford, Plaintiff IN TIlE COURT OF COMMON PLEAS OF CUMIlERLAND COUNTY, PENNSYLVANIA IN DIVORCE v. 10hn 1, Crawford, Defendant NO 98,4465 CIVIL TERM CERTIFICATE OF SERVICE I, Megan C. Huff, hereby certify that I am serving a true and correct copy of the Notice of Praecipe to Transmit Record and Vital Statistics Form on 10hn 1. Crawford, residing at 1619 Glenbrook Avenue, Coraopolis, Allegheny County, Pennsylvania 15108 by depositing a copy of the same in the United States first class mail, postage prepaid, this til ~,I day of September, 1998. I ,--~(il'l () \/ ,1// t/- b_ ".1~fl\/ Megan C; Huff ct.: Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA /7013 717-243-2968 , ~~, ",'.,' . ~ " '.. "~," ,"" ,~,: "". '",', ,i .:__ ",':if" "',' "'~'''~~''f'~' '_~ .-,'.. ',.;" ~'_.- fr. c: ?-:: :;:{ ". ,'. r'" -1;",: UJ .;'~ ~:j: :'; 0" --(.. U-'> ..;.:.:, '~ ~:J ~i:' I, , ~.J) ,,": '" , ~;,: ,::\"" c. 1:"tI,!.J u:v: 1'-' ,~JD__ ;:.: C/O :'3 I.!.- C;:; 0 CJ' (.)