HomeMy WebLinkAbout00-06842
~'""
, <
. I,
'".'" "f'''-
~,
,
,
,
"
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
,
PENNA.
STATE OF
HORACE M. CRUM, JR.,
Plaintiff
NO. 2000-6842 CIVIL TERM
CIVIL ACTION - LAW
,
VERSUS
IN DIVORCE
MARY ELIZABETH CRUM,
Defendant
,
,
DECREE IN
DIVORCE
it -z r; <fP; ~ ff
AND NOW,
, PLAINTIFF,
, 2001
, IT IS ORDERED AND
DECREED THAT
AND
MARY ELIZABETH CRUM
, 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 Marriage Settlement Agreement dated October 27, 2000 and signed by
the parties is hereby incorporated into this Decree, but not merged.
C~, ,J
P~THONOTARY
,
--"-. mill
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
.
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
.
,
.
,
,
,
, .'
~._~ --=."~,-,,--.---, .r, ,.1-'_'-",,',,""_'_"<' ""~
'_.1. .'
ill '" , .or.. ,,";t
'\,
l'dSO/ cal {~/tft;:~b7f;4~
/J.S~ C'/ /tp:&; '?14~'/:ib' t~
t>
_A
..
,.,",< ~"""
.
.
~1~J!ilI_"",,.,-.:-,'~,._,... ""_~.'" _ L-
~~~q_""',,: '""-l,, ,1_' ,.~;!;
, ,
,~ -, -.---- ~ ~ ,,-
"___~-,"<w _ ~P...~'~~,",-,","'H~".'~'~' ~,. _'__.,' '-;"~"",,., .,,__,. 'r", "~~ ""_~>'-'~^""
w
'.,
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this~7~ day of October, 2000, by and between MARY
ELIZABETH CRUM, (hereinafter referred to as "WIFE") and HORACE M. CRUM, JR.,
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on March 20, 1999, in
Mechanicsburg, Pennsylvania; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and finally their
respective financial and property rights and obligations as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
J.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
-i
.. --, -. ~=I
,~.~~.. ." '~".- ..
,,"~-.., ,.~ >-"',--..U,'" - "'-',', _ " ";> _.~ ' ~'
,
l.l"il
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever detennine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
2
~
,,~,
- I ~" -,=,-~
. "..,~". ",,' "'", <".,'_, C__C'd_'_
c,'_c>-_F,__ ~_".'
!lid
(I) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: HUSBAND is
represented by Douglas G. Miller, Esquire of Irwin, McKnight & Hughes; WIFE
chooses not to be represented by counsel, and by initialing this page acknowledges
her right to be represented by counsel ~
(2) Is fully and completely infonned of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that confonns to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
3
I" - ~,,-~ <-~-"W'" ~"-~ --K,'" """""'''''''~''' ,'" ",-,',.','-,
"'" ,'i_ 'ce_ ~ ~ -" -
C.rbi1
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marnage.
7.
REAL ESTATE: WIFE agrees to transfer all right, title and interest which she may
have in the real estate situate at 1178 West Trindle Road, Mechanicsburg, Cumberland County,
Pennsylvania to HUSBAND and release all claims which she may have regarding said real
estate. HUSBAND agrees to pay the outstanding mortgage payments and hold WIFE harmless
from any obligations on any mortgage on said property and indemnify her if any claim is made
against her. In consideration of the same, HUSBAND further agrees to pay to WIFE the sum of
Six Thousand and nolI 00 ($6,000.00) Dollars on the date hereof.
4
...J
> -, ..",:,.. 'c,.' ,,_:~
. ~ .
=";'"""'!iaL
8.
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay continuing support to WIFE and that WIFE will not provide any financial support to
HUSBAND. The parties also waive any right they have to receive alimony payments from the
other following the entry ofthe Divorce Decree in this matter.
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest which
she may have in any personal property of the HUSBAND. HUSBAND likewise waives any
right, title and interest which he has in the personal property of WIFE. Henceforth, each of the
parties shall own, have and enjoy independently of any claim or right of the other party, all itetIls
of personal property of every kind, nature and description and wherever situated, which are then
owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to
HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all
purposes as ifhe or she were unmarried.
10.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND currently owns or may own in the future. HUSBAND shall hold WIFE harmless
for any and all liability associated with the use and purchase of any vehicle he may own, and
shall be solely responsible for all insurance and other financial responsibility associated with said
vehicle. HUSBAND hereby waives all right, title and interest in any vehicle that WIFE
currently owns or may own in the future. WIFE shall hold HUSBAND hannless for any and all
5
.'~ ,
~-r'---"-. .,~,' . ~""." ,,-_~--,'~.~_,.i: - C"""~' ,_^_,-_ ,,,__<0,,'-.-_-,
ifi;;
liability associated with the use and purchase of any vehicle she may own, and shall be solely
responsible for all insurance and other [mancial responsibility associated with said vehicle.
11.
MARITAL DEBTS: It is mutually agreed by and between the parties that WIFE shall
assume all liability for and pay and indenmify the HUSBAND against all debts incurred by
WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the
parties' marital separation she has not contracted or incurred any debt or liability for which
HUSBAND or his estate might be responsible and WIFE further represents and warrants to
HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify
and hold HUSBAND harmless from any and all claims or demands made against him by reason
of debts or obligations incurred by her.
HUSBAND shall assume all liability for and pay and indenmify WIFE against all
debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and warrants to WIFE that he will not contract or incur any debt or liability after the execution of
this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall
indemnify and hold WIFE harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him.
6
.od
- ~" ~ r~-
_ _ u ~
.. - '-I"~ .-~ -'"~''''''~.I=", -.,- _.-,.,_" v',C ~-_ ~_'_;"i-.,~'_
, '-~.,
'''~!
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
WIFE waives all right, title and claim to any of HUSBAND's employee benefits, and
HUSBAND waives all right, title, and claim to any of WIFE's employee benefits.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seekingthe divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach or seek such other
7
...
",-, .",- ,- r.~'~~ "-""'"< ~--,,,, ,
'-,',
~i\8;i
remedies or relief as may be available to him or her, and the party breaching this contract shall be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, if any, are fully understood
by both parties, and each party acknowledges that the Agreement is fair and equitable, that it is
being entered into voluntarily, and that it is not the result of any duress or undue influence. It is
the parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
8
-'
_ ,.'_ T<'
"~"~'~ol _- -._,~". "'" '-.n",;'_""" __,0 '~ _,'_ "---i.'--.--, 'y'_,',_ ""':,,, =,~ ,
-, "'OOtJ
fees and. costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
9
..
,~
~ ~ - ,-
__ ,no."~, V~ ".' - ','''' "" ", ;".0- ",'On] _" - -,' "," _' ~-"" _.' ,~,,_""_ _
-n' '-_;'",;,,_
",,"~j
,
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day a
and year first above written.
WITNESSES:
~tWt~ XlIYL11AJ
o
'trvJ~ e. ~H~
M ELIZABETH CRUM
(SEAL)
yJltiU-~' d,1di..t.J~ /
10
..J
> .
.
--,
~-''''I ~.---_' ,.'_"""_ 1- -t-.... "-"" '^,"~ -.
.---,~ ".- "".,,~,J
...k;;..;.,Jit~:
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ~7 -M day of October, 2000, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
MARY ELIZABETH CRUM, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
~~ >f~~
Notarial Seal
Martha L. Noel, Notary Public
Carlisle Bora, Cumberland County
My Commission Expires Sept. 18, 2003
Member, Pennsylvania Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this J7"'" day of October, 2000, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
HORACE M. CRUM, JR., known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
,#~X.~f
Notarial Seal Ii
M~~utha, L Noe!, Notary Public '
Carlisle 8oro, Cumberland County
My CommIssion Expires Sept 1 (~ ~OOO
'"~
Member, fier;;Y1Vania ASSOCiation of Notaries
11
r.___ ~~ ".~
~',' -,' ." "'!,oj' 0'-'
, , I .~ ., I .
i"c_>1
~-~ ""J """,' ~.=
,.-,
- ":'_;:~a~", -,~
-'--"llFli
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSVLV ANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
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 Section 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Mary Elizabeth Crum, on October 12, 2000, by certified, restricted delivery mail, addressed to her at
1178 West Toodle Road, Mechanicsburg, Pennsylvania 17055, with Return Receipt Number 7099 3400 0018 4997
2350.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by plaintiff: January 9,2001; by defendant: January 12,2001.
(b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiff's affidavit upon the defendant:
4. Related claims pending: 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 plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: January 16, 2001.
Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: January 16,2001.
== #. Ik:tl~
DOUG G: MILLER, ESQUIRE
Attorney for Plaintiff
"~L :
I
-" ~ " . --~,~~
.,
'~-~.
,~ ~_., ,,~
".~ ,,~ ,o'~,
~~-'~-
.'"
,
,'"
o
~;:;
:,:,,;:,-
'.Jt,~
S2 ~-~~j
zc--.
(/)L,
--<..,<
~: '::~.
~E~~
L
..._1
~
-.,
.c _,,.,',
~
'~,
C)
'-
_~.7:li
cr',
2:
":S~
':'::::',
~S
~.
,"'J
,., ~ .!h..
~ ..:... ,I
. -<
-"-, -'-
.,1 :1
L __ "I
.
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.SA SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURlTY NUMBER
PLEASE FILL IN THE APPROPRlATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE:
JANUARY 16, 2001
DOCKET NUMBER:
2000-6842 CIVIL TERM
PLAINTIFF~ SS#
182-40-7844
NAME: HORACE M. CRUM, JR.
DEFENDANT~ SS #
206-38-8737
NAME: MARY ELIZABETH CRUM
..,,_. "~
~......IWl>W,,,,,,;,
-'- "~~.
-, -- - <I"" ,\ ---,,--,= U'''' ---"-,'"''''''''"' "',. ~,~,'"''~''' .,n."_, "'---'''';'',,",'l~''''!.;.''~"4;,..'---: ",~',' ~r;;
, .
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION -LAW
2000-UY',,? CIVIL TERM
MARY ELIZABETH CRUM,
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 prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
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, Pennsylvania 17013
717-249-3166
-'
'w,
." -=-~-- - ~..- ~e',~","w_'~ __~_"~r._'~-~' - ,- "'''''~.,'-''''~_.__<
~ ,- .115'
, ,
1-800-990-9108
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.
_w
--"-'=."'-~-~"-' ~= ~
'-U-'o,n'''_:il' '_''-'C''" -, ,.','.'- ~'" '.,' _", A~ 1""
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- r,Wz.cIVlL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the plaintiff, Horace M. Crum, Jr., by his attorney, Douglas G. Miller,
Esquire, and files this complaint in divorce against the defendant, Mary Elizabeth Crum,
representing as follows:
1. The plaintiff is Horace M. Crum, Jr., an adult individual residing at 1178 West Trindle
Road, Mechanicsburg, Pennsylvania 17055.
2. The defendant is Mary Elizabeth Crum, an adult individual residing at 1178 West
Trindle Road, Mechanicsburg, Pennsylvania 17055.
3. The defendant has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
'H
'"
,-
"",~,,-, "-,,,,-,
',-',1<"0-' q=,,_ _I,' ,,~-, ---'I'",' --0- '~'~C~"_t;,,<,,_'_,~',__, "'-i,,~.-.,>-,-,;-">."_ :o"_~-"_"j,,,;,1"_'",;'_6',~.._,
'>'.'
4. The plaintiff and the defendant were married on March 20, 1999 in Mechanicsburg,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were no children born to this marriage.
7. Pursuant to the Divorce Code, Section 330l(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken.
8. The plaintiff avers that he has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the
two parties.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
~~<A/ ~~ ~
Dougl G. M' er, Esquire
Attorney for Plaintiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 83776
Date: October 5, 2000
~
,.,. '~_ _ .<,., h, ""c1 "'. --,,-._,-_,,_.___,.
_'J,<-,_'..ri
'-';--', ';-.-',':,.i ',. "'''-.ti~i
VERIFICATION
The foregoing Complaint is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unsworn falsification to authorities.
"'
Date: October 5th
,2000
-
- '" ' _"~O ,"" ,,"'_ "
, - ,I' , ' --l~ ' '- " ",- ,,"", , I, '.. ;,-, , ' ., ._"a" '> .
''''')','"~G:..;_';''"-:'-;'.' ,-~~~--,-<, ',- """-"""-i:r-".!i{'
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000- ~8'fJ, CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: October 5th , 2000
HORAC
-"O.o'K
~ ~
\l::: ~
CS ~
- VJ
.-l)
0() I'\""'"
-...Q
~ 1 ~ ~
. 1:>. J
d 0 ci
~~
II)
~
-=
+-
.-+
--.,.
:?
~
D
-t-
~
(")
c'.
--,~:
L ,~.'
rnr..
Z::;~l
:>' r .
~~ ~~~.
o:c,
<
)> ...
~?l.. .'
L...,'c;
j; c:~
z
=2
:?
'"'-.
'"
-,
p
C:)
'-":'-'
D
n
~-<
I
(,j',
!~.i
c..,)
~i~: ~_~
:--) co:;
(":) TJ
--l
;~'~
=<
:::J
10
- ,~ - "--~-"," ~ - ,. "
M' .,"". ."
.'. .., """"-""'-'"",,,"
-",OJ
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
October 5, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: January 9th ,2001
-~l '-.; ","""",I
~. ~~ " ~
'_k"'''''''
--^~
<, '''--"11 ~a!lli!f'" .:-',...'~""v^. ..
_.~._"'~ 0 I -"",~"j-' ,-, '. ~"'^
'-'p
~ ,,,I
,-
C)
~:;
0fF
.,<:... ~~.-
/
cij
~~
~~(-'"
'~-.
<'
"~,,,,-, '~.
-;::
-~J
L..,j
C'"
:;:":""
-"
-'..~
, ,
(;:.
:'~
~~5
"
~':
~ '..'
7 _ ",,-, ~ .___' ';- -e.--n"
~-- J,.:.i&-;",~';;;"'w~,,'.; .. "',,-- 'f' --""'- -,-<+ < ~,--- "'","" '- ,,-0:" , ,,- -",&.';i-"~,_<V~",~=,_,,;,''-'",';h;';'''''k-~,"-. ,...;-. r-- , , ~":'i~~
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 ifI 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. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: January 9th ,2001
-
,;...~
n~ ~,.,<,
~, ~ ,
-"-'--
-~,~-~'-
, '~__"'" I. _, ~, ..~.~,
'/c/",'_~' "'-..
-' "'~- -, ,~' .
.~ '
,I...
. e,.'CeCce
C) c:)
c:
:?"
l:ib:,
Tl,}~'
-~
r:::c.:_
'S_.
-'::0'" t_.
S,'-'--,
)>.~
~,;
c_,
-<
.~ 'n"
,
j
I
c,:;:
_C 'i
"...-
:::-r_"
'.'-,
'""
l,D
Iii;
d' _,,,"'~'I'
,,,,,--'''.
--"",",, '.~. V"""_,,,,"_'C ~,~.' .-,'i"'-",,- ";";,""1_"~>'_',-;."",_' ,,,,C_,,,_~ '~~"'''' __".
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
October 5, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: January I:J..-.- , 2001
~tnA-'r.lJ. flit., },..,f'j, (' /V//Y"Yl./
ARY IZABETH CRUM
~j,;.,
", ,.
"
, j-w"';
:'~ira!~"
"
,;,;".
"
",""
, "
--,
Q 0
~-,:
~~;::,
/1
0;'" 0-'
~.~:", ~-~.
~~i~ i"O
=<:' {.':)
..,
,"<-
" ""-~'" ,;-,,-,~ ""'-"",,~~.,:'" '-,"j-,;.-", ii"" "~ ,,'"
"?'.:-, - "oj'-I"'C~",._,_<:,.-_-,,_:_&-,<,,.
c-,-,,"c -",.; ,,_--.':.";"""$:
-'-":;'''t'j
I
. '
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) 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 ifI 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. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: January / J-.- , 2001
'1n~ '2U~..,....ttL ~
Y ELI ABETH CRUM
Defendant
~
I ~ k,
""--'W
".
"'--I"'-'_~ ~
,~ ,~~
.,'- ".
,
ll~'i~"'-);'"
..
..
,<"'""",-
I, - ~,
"".
Ci
~2
r1tf~
:::::~:::<
~ ,
(:75 ::
~;:;
~~
--'(
',-'.'
to
,_n
c>
'-,'"
(:>,
2;::
>.0
I, ~" ,,;
iI , , ",. " , I' .. .',;,,-,~ I ,. ."C' ,.:Cj" :;,;'"".-.-," ,;,\;::"i;,.-:'~/~ ~';:-:~:;6.:;~
. ,. , , ". , <>'-0';- 0" "
;:"'G'.2;;~tl
I
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 192M (a)(1)O)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
NOW, Douglas G. Miller, Esquire, being duly sworn according to law, does depose and
state:
I. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant,
Mary Elizabeth Crwn, on October 10, 2000, by certified, restricted delivery mail, addressed to
her at 1178 West Trindle Road, Mechanicsburg, Pennsylvania 17055, with Return Receipt
NUIllber 7099 3400 0018 4997 2350.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to
unsworn falsification to authorities.
~ Ii. /J1Jllb-
DOU LAS G. MILLER, ESQUIRE
Attorney for Plaintiff
Date: January 16th ,2001
"'"
<~-I I ,I I , ;, "',
,-~ , "-i-'- -~,,",~, , , "j- ,,';--"""-',; " ;..-, ""'j
.
o
'"
IT1
ru
l"-
ll""
IT"
"'"
Postage $
,l?
1,1./0
I, ~5
~,75
(" 17
Postmark
Here
Certified Fee
Return Receipt Fee
c[] . (Endorsement Required)
.....
o
o
o
0'
"'"
IT1
Total Postage & Fees $
DOUG
10-05-00
CRUM DIV.
COM.
Recip;enf's Name (Please Print Clearly) (to be completed by mailer)
MARY ELIZABETH CRUM
IT" -Street,~Apt~-;ijo.;-or~P(YBoxTvo.----_n---n---nn
IT" 1178, W TRINDLE RD
c .ciiy,-srare,-zip+,f---------------------------------
I"-'MECIWIIICS:BURG PA 17055
.' Complete Items t;;,._, and 3. Also complete
item 4 if RestricteJ;j:'Selivery is desired.
.;- Priot your name ~tl~ address on the reverse
so that we can return the card to you.
. Attach this card unne back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
MARY EJ.lZABETH CRUM
1178 W;1TRINDLE RD
MECIJAJQ:CSBURG PA 17055
/PfTt1N5S
3. Service :rype
IXI Certified Mall D. Express Mail
o Registered iXi Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
. Restricted elivery? (Extra Fee) Ef Yes
2. Article Number (Copy from service Jabelj
7099 3400 0018, 4997 235l:l
PS Fonn 3811, July 1999
Domestic Return Receipt
102595-99-M-1789
c' 0
.,
c
-. ,-:
c.
l~n
2~
~"/
-"'--
(n c-
.:<
r::
={_:::: ..
r' 1..,-'
:<::j C:,:
-<. '.
",'"
, > r-~-\ -L" S~"",__
,;1..
--~." ,-~~.-,---"'-' - I "I
""i;--[,-:'- - -,.; -;2__.-',.____ -'""--,~---b"'~__"'"_;"(,--"" '..;j: ;"_':";"""'-::~~"-;'::':";;__';;';;"." ',".~' /..' ;,'~
<
HORACE M. CRUM, JR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2000-6842 CIVIL TERM
MARY ELIZABETH CRUM,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: January 1)-.1 ,2001
Tn <aL~~
~ARY E IZABETH CRUM
-j
"r:" -" ~
".\-.
"" ><,V.'''-,
,~~~ ,,-"~
".,0
;'-c,;,c,. ,_,_;e:
c). " ~ ?,,~,"'-___"'r ~,
;:;:":';~'__'wis,_.'"
"," ~. ~.
".'~
e,'"~
,': ,'~':, .,-
, ~.
'C.,.
.
~,~
~~ - ,',"
_~ Ck~-~_ ":'-"
C)
~;-
-of:;;
;~~'
-,
~>~;
~,.?~~
L.
-~j
-..
"<,,
-,,".-
-",'-
c:~;
.~
.....',
~:
.....-
1..0
\.....J
(J
~