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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF r? fPENNA.
GERI RIGG-CROLEY
............. 99-6987
....Plaintiff. \u....................... .................
\'crsu?
CHRISTOPHER JODY CROWLEY
Defendant
DECREE IN
DI V0R1C?E?.??SP,,? .
AND NOW, ........ .2 3... ,pW.R .. • , it is ordered and
decreed that ....Ger:..ltigg-Growl,ey ........... . . . ........... . plaintiff,
and . . . . . . . . ....Christopher Jody Crowley . . . . . . . . . . . . . . . . . . .,
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;
0. .................................... ............
................ .. ..... ....................................... ............
By The
Attest:
? J.
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. Prothonotary
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GERI RIGG-CROWLEY,
Plaintiff
VS.
CHRISTOPHER JODY CROWLEY
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO.99 - 6987 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
decree:
Please transmit the record, together with the following information to the court for entry of a divorce
1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and manner of service of the complaint: by U.S. Mail, postage prepaid, certified with
restricted delivery, return receipt requested on November 24, 1999.
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 the Plaintiff 2/21/00; By the Defendant 2/21/00.
B. (1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the Divorce
Code: none
(2) Date of service of the Plaintiffs affidavit upon the Defendant: none
3. Related claims pending: None
4. 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: none
B. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary:
2/22/00; Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary 2/22/00.
Attorney f9 r Plaintiff
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GERI RIGG-CROWLEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
vs. : CIVIL ACTION - LAW
CHRISTOPHER JODYCROWLEY, NO. 99 - Joct't7 CIVIL TERM
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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office 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.
Court Administrator - Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
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.
James J. Kayer, Esquire
Attorney for Plaintiff
Liberty Loft
4 East Liberty Avenue
Carlisle, PA 17013
(717) 243-7922
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GERI RIGG-CROWLEY.
Plaintiff
VS.
CHRISTOPHER JODY CROWLEY.
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO.99- G 9S J CIVILTERM
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 3301(c) and 3301fd) OF THE DIVORCE CODE
COMES NOW, Plaintiff GERI RIGG-CROWLEY, through her attorney, James J. Kayer, Esquire
and avers as follows:
COUNT I - DIVORCE
1. Plaintiff is Geri Rigg-Crowley, an adult individual, whose current address is 129 Mulberry Drive,
Mechanicsburg, Cumberland County. Pennsylvania, 17055
2. Defendant is Christopher J. Crowley, an adult individual, whose current address is 2570 Sanger
Lane, Apt B, York Haven, York County, Pennsylvania, 17370.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on November 15, 1996 in Towson, Maryland.
5. There have been no prior actions of divorce filed in this matter.
6. Plaintiff and Defendant are not members of the United States Armed Forces.
7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) and
Section 3301(d) of the Divorce Code.
8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to
request that the court require the parties to participate in counseling.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
Jame§ I J. Kayer`,
L'
be E
y Loft/
irt
4 Liberty Avenue
Carlisle, Pi 17013
(717) 243-7922
Date: November 1, 1999
VERIFICATION OF PLEADINGS
The foregoing document is based upon information which has been gathered by my counsel
and myself in the preparation of this action. The language of the document may, in part, be the
language of my counsel and not my own. I have read the statements made in this document and to
the extent that it is based upon information which I have given to my counsel, it is true and correct
to the best of my knowledge, information and belief. To the extent that the contents of the
statements are that of counsel, I have relied upon counsel in making this Verification. 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: 0nG(r .2lo 11999 J.6c " (('??
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GERI RIGG-CROWLEY,
Plaintiff
VS.
CI-IRISTOPHER JODY CROWLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 99 - 6987 CIVIL TELRM
: IN DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO Pa R.C.P. 1920.4(a)(1)(ii)
COMMONWEAL'TI-1 OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
1, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff, GERI RIGG-CROWLEY, and that he did serve a true and correct copy of the
Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S. Mail,
postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant,
CHRISTOPHER JODY CROWLEY, on November 18, 1999. The return receipt is attached hereto.
Sworn to and subscribe fore me
Ctfiis I51 day of Decembe 19-21._,
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Naar ??t fc
NOTARIAL SEAL - -- • --:- ^ ___.
DENISE PINAMONTI, Notary Public
Carlisle Borough, Cumberland Count'
2000
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GERI RIGG-CROWLEY,
Plaintiff
VS.
CHRISTOPHER JODY CROWLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6987 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRFE
UNDER & 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. ]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 1 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 18, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the
date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry
of the decree.
4. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses
if 1 do not claim them before a divorce is granted.
I verify that the statements made in this Waiver and 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.
DATE: 2000 ,?y(M / ail(} ' ?? ,tJ ?( u1?
GERI RIGG-C WL
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GERI RIGG-CROWLEY,
Plaintiff
VS.
CHRISTOPHER JODY CROWLEY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6987 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER & 3301(c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final decree of divorce without notice.
2. 1 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.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 18, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the
date of filing the Complaint.
3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry
of the decree.
4. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses
if 1 do not claim them before a divorce is granted.
I verify that the statements made in this Waiver and 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 unswom falsification
to authorities.
DATE: 0712.1 2000 i I l "'f.,?A
CHRISTOPFIER CR WLEY
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GERI RIGG-CROWLEY,
Plaintiff
vs.
CHRISTOPHER JODY CROWLEY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 6987 CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO RESUME PRIOR NAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a final
decree in divorce on the 23rd day of February, 2000, hereby intends to resume and hereafter use the
previous name of GERI RIGG-CROWLEY and gives this written notice avowing her intention in
accordance with applicable law.
LZ4C-
To GERI RIGG-CRO EY
be known as:
A/1 k ?/IGI'
GERI RIGG
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND SS.
On the day of CJQYy UaCL 2000, before me, a notary
public, personally appeared GERI RIGG (formerly known as Geri Rigg-Crowley), known to me to
be the person whose name is subscribed to the within document and acknowledged that she
executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
NOTARIAL SEAL
DENISE PINAMONTI, Notary Public
Carlisle Borough, Cumberland County
M Commis soon Expires Nov. 20, 2000