HomeMy WebLinkAbout03-2175
TODD W. CRAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CML ACTION - LAW
2003 -~r'~IVIL TERM
LISA MARIE CRAIN,
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
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.
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TODD W. CRAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003 - ,.,'15CIVIL TERM
LISA MARIE CRAIN,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
NOW comes the Plaintiff, Todd W. Crain, by his attorney, Marcus A. McKnight, III,
Esquire, and files this Complaint in Divorce against defendant, Lisa Marie Crain, representing
as follows:
1. The Plaintiff is Todd W. Crain, an adult individual residing at 234 Bonneybrook Road,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant is Lisa Marie Crain, an adult individual residing at 14 Piper Court,
Carlisle, Pennsylvania 17013.
3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on June 9, 2001, in Cumberland County,
Pennsylvania and separated on July 4, 2002.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Plaintiff and Defendant have one child born prior to this marriage, namely Nicolas
William Crain, born August 28, 1997.
7. Pursuant to the Divorce Code, Section 3301(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,
By:
Date: May 6, 2003
Mare . Me
Attorney for Plaintiff
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 25476
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have head 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.
~~td.., tWo ~
TODD W. CRAIN
Date: May 6, 2003
TODD W. CRAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
LISA MARIE CRAIN,
Defendant
2003 -
CIVIL TERM
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: May 6, 2003
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TODD W. CRAIN
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TODD W. CRAIN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
LISA MARIE CRAIN,
Defendant
2003 - 2175 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, do hereby certifY that I have served a true and
correct copy of the Complaint in Divorce upon the person indicated below by first class United
States mail, Certified Mail 7001 2510 0009 2828 4319, Restricted Delivery, postage paid in
Carlisle, Pennsylvania 17013, on the date set forth below:
Ms. Lisa Marie Crain
14 Piper Court
Carlisle, PAl 71 03
McKnight, , quire
Supreme ourt I.D. No. 25476
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Date: May 23,2003
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1. ArtIcle AddI'llS88d to:
lIS LISA IWUE CJlAIB
14 PIPER. COURT
COLISLE PA 17013
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MARRIAGE SETTLEMENT AGREEMENT
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THIS AGREEMENT made this l" day o~ 2004, by and betwee LISA
MARIE CRAIN, (hereinafter referred to as "WIFE") and TODD W. CRAIN, (her inafter
referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on June 9, 2 1, in
Plainfield, Pennsylvania, and were separated on July 4, 2002. The parties hereto agr e and
covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live ap from
each other. It is the intent and purpose of this Agreement to set forth the respective righ s and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner hich
conforms to a just and right standard, with due regard to the rights of each party. It is the' tent
of the parties that such division shall be final and shall forever determine their respective
The division of existing marital property is not intended by the parties to constitute in any
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the othe at any
place or places that he or she may select as they have heretofore been doing. Neither p y shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter wha oever.
Each party may carry on and engage in any employment, profession, business or other act vity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall i terfere
with the uses, ownership, enjoyment or disposition of any property now owned and not s cified
herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtai ed 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, con ssed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he 0 she,
respectively:
(a) is represented by counsel of his or her own choosing;
(b) is fully and completely informed of the facts relating to the subject ma er of
this Agreement and of the rights and liabilities of the parties;
(c) enters into this Agreement voluntarily after receiving the advice of couns 1;
(d) has given careful and mature thought to the making ofthis Agreement;
(e) has carefully read each provision of this Agreement; and
(f) fully and completely understands each provision of this Agreement, both s to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the purpose and intent of this Agreement to settle forever and completely the i terest
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 he rs and
assigns. The parties have attempted to divide their Marital Property in a manner that coni< rms to
a just and fair standard, with due regard to the rights of each Party. The division of existi g
Marital Property is not intended by the parties to constitute in any way a sale or exchange f
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obli ation
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 0 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 obligati ns of
any nature for which he or she is currently liable or may become liable. Each further repr sents
and warrants that he or she has not made any gifts or transfers for inadequate considerati n 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 . oint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties d ring
marnage.
3
7.
REAL ESTATE: The parties own no real estate.
8.
SUPPORT: HUSBAND will not provide spousal support or alimony to WIFE a er the
divorce. WIFE will not provide spousal support or alimony to HUSBAND.
9.
PERSONAL PROPERTY: The parties agree that the personal property shall be vided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. His bank accounts;
c. Any Life Insurance Policy;
d. Any employee benefits; and
e. WIFE will return to HUSBAND the bench located at her mother's
home and the large tent.
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
c. Any employee benefits; and
d. HUSBAND will return to WIFE the basketball net.
The WIFE hereby waives all right and title which she may have in any personal pro erty
of the HUSBAND. HUSBAND likewise waives any interest which he has in the per onal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independ ntly
of any claim or right of the other party, all items of personal property of every kind, natur and
4
description and wherever situated, which are then owned or held by or which may reafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to ispose
of same as fully and effectually, in all respects and for all purposes as if he or s were
unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on accoun of the
other and that from the date of this Agreement, neither party shall contract or incur obli ations,
liens or any liability whatsoever on account ofthe other.
10.
AUTOMOBILES:
a. WIFE agrees to waive any and all interest which she may h ve in
HUSBAND'S motor vehicles.
b. HUSBAND agrees to waive any and all interest which he may h ve in
WIFE'S motor vehicles.
11.
MARITAL DEBTS & BANKRUPTCY: Each party will be responsible for thei own
debt incurred after the date of separation. It is hereby understood and agreed by and betwe n the
parties that their obligations pursuant to this agreement shall not be affected by any ba ptcy
proceeding and shall not be deemed to constitute or be a dischargeable debt of a b tcy.
Both parties warrant that helshe has not heretofore instituted any proceeding pursuant t the
bankruptcy laws nor are there any such proceedings pending with respect to himlher which ave
been initiated by others.
5
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that y life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, in luding
but not limited to retirement, profit sharing or medical benefits of either party, shall be the r own.
WIFE waives all right, title and claim to HUSBAND's employee benefits, and HUS AND
waives all right, title, and claim to any of WIFE's employee benefits.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, tit e and
interest which she may have in the savings or checking or any other bank accounts f the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank acco nts of
the WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining final
divorce of the marriage. It is agreed that the parties will execute and file the consents nec ssary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall p y all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other arty
shall have the right, at his or her election, to sue for damages for such breach or seek such ther
remedies or relief as may be available to him or her, and the party breaching this contract s uld
be responsible for payment of legal fees and costs incurred by the other in enforcing their ghts
under this Agreement.
6
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to tim 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 lega effect
have been fully explained to the parties by their respective counsel, and each party ackno
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and t
not the result of any duress or undue influence. The provisions of this Agreement ar
understood by both parties and each party acknowledges that the Agreement is fair and eq
that it is being entered into voluntarily, and that it is not the result of any duress or due
influence.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding f the
parties and there are no representations, warranties, covenants or undertakings other than ose
expressly set forth herein.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws 0 the
Commonwealth of Pennsylvania.
7
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all operty
settlement agreements which mayor have been executed prior to the date and time f this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS: The parties agree to pay for their own costs required to btain
and complete the divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise pro ided,
each party may dispose of his or her property in any way, and each party hereby waiv s and
relinquishes any and all rights he or she may now have or hereafter acquire, under the pre nt or
future laws of any jurisdiction, to share in the property or the estate of the other as a result 0 the
marital relationship, including without limitation, dower, curtesy, statutory allowance, wi ow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to ct as
administrator or executor of the other's estate, and each will, at the request of the other, ex cute,
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.
8
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals he day
and year first above written.
WITNESSES:
Y17J t w~
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LISA MARIE CRAIN
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TODD W. CRAIN
9
(S AL)
(S L)
COMMONWEALTH OF PENNSYLVANIA
S8:
COUNTY OF CUMBERLAND
~"''''~{
PERSONALLY APPEARED BEFORE ME, this Ie day of).1.il'f,2004, a Notary
Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, LISA
MARIE CRAIN, known to me (or satisfactorily proven) to be the person whose e is
subscribed to the within Marriage Settlement Agreement, and acknowledges that she e ecuted
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and 0
!<9MMoNWEALTH OF PENNSYLVANIA
NoIarIaI Seal
Nathan C \Voff l\'olaJy Public
CatflSle ~~o, C.umlnf1'am County
My CommiSSIOn Expires Apr. 19,2008
Member, Pennsylvania AssocIatIon Of Notaries
/
COMMONWEALTH OF PENNSYLVANIA
5S:
COUNTY OF CUMBERLAND
II II' f)eu",b~
PERSONALLY APPEARED BEFORE ME, this ~ day of My, 2004, a
Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, TOD W.
CRAIN, known to me (or satisfactorily proven) to be the person whose name is subscri
the within Marriage Settlement Agreement, and acknowledges that he executed the same f< r the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
NolaI1llISeaI
Mar1I1a L Noel. NolaIY PublIc
CaItiSIO 80m, Cuml:>/lIIIlI1d CountY
My Ccm'nIISlOn E><Pil8S SeI>l '8.1ro1
Member, PennlylvlIInl8 Alsoclltlon Of Notaries
10
TODD W. CRAIN,
: IN THE COURT OF COMMON PLE S OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
CIVIL ACTION - LAW
2003-2175 CIVIL TERM
LISA MARIE CRAIN,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May
3,2003.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days ave
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, la er'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 at
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relati g to
unsworn falsification to authorities.
Date: December 22. 2004
~cw,~
TODD W. CRAIN
Plaintiff
Plaintiff
: IN THE COURT OF COMMON PLE S OF
TODD W. CRAIN,
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
CIVIL ACTION - LAW
2003-2175 CIVIL TERM
LISA MARIE CRAIN,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May
3, 2003.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days ave
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, la
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
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relati to
unsworn falsification to authorities.
Date: I @-l Lr 04
LISA MARIE CRAIN
Defendant
TODD W. CRAIN,
: IN THE COURT OF COMMON PLE S OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
CIVIL ACTION - LAW
2003-2175 CIVIL TERM
LISA MARIE CRAIN,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
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, la er'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 C urt
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 at
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relatin to
unsworn falsification to authorities.
Date: December 22, 2004
'tJ ~ q,v e-y
TODD W. CRAIN
Plaintiff
TODD W. CRAIN,
: IN THE COURT OF COMMON PLE S OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
CIVIL ACTION - LAW
2003-2175 CIVIL TERM
LISA MARIE CRAIN,
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, la er'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 C lilt
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 t at
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relatin to
unsworn falsification to authorities.
Date: lR:J (p -04
rAm
LISA MARIE CRAIN
Defendant
TODD W. CRAIN,
: IN THE COURT OF COMMON PLE S OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL ANIA
v.
CIVIL ACTION - LAW
2003-2175 CIVIL TERM
LISA MARIE CRAIN,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand th t 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 t at
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relatin to
unsworn falsification to authorities.
Date: J ~ -I ( 0- (J L/
ffiGAJJ ~
LISA MARIE CRAIN
Defendant
TODD W. CRAIN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2003-2175 CIVIL TERM
LISA MARIE CRAIN,
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 decr e:
I. 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 serv d upon
the defendant, Lisa Marie Crain, on May 20, 2003, by certified, restricted delivery mail, addressed to her at 1 Piper
Court, Carlisle, Pennsylvania 17013, with Return Receipt Number 70012510 0009 2828 4319.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c) of the lvorce
Code: by plaintiff: December 22,2004; by defendant December 16,2004.
(b)(l) 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 ofIntention to file Praecipe to Transmit R cord,
a copy of which is attached:
(b) Date plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed wi the
Prothonotary: December 22, 2004.
Date defendant's Waiver of Notice in Sec'
Prothonotary: December 22, 2004.
Divorce was filed WI the
~~~~~~+.~~++~~+~+~+~++~+++~+~++++++*~+
e+:+++++++.+++++
IN THE COURT OF COMMON
OF CUMBERLAND COUNTY
STATE OF
PENNA.
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TODD W. CRAIN.
PLEA
No.
2003-2175 CIVIL TERM
Plaintiff
CIVIL ACTION - LAW
VERSUS
IN DIVORCE
LISA MARIE CRAIN.
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Defendant
DECREE IN
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DIVORCE
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December
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2004
AND NOW,
DECREED THAT
TODD W. CRAIN
AND
LISA MARIE CRAIN
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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, IT IS ORDERE
, PLAI NTI FF,
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AND
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
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BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HA
YET BEEN ENTERED;
The Marriage Settlement Agreement dated December 16. 2004 and s~ b
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the parties is hereby incorporated into this Decree, but not merged.
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PROTHONOT RY .
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By THE COURT:
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