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HomeMy WebLinkAbout99-0758211 j IN THE COURT OF COMMON! FLEAS OF CUMBERLAND COUNTY STATE OF GLORIA.. KRAMER ............... ................................Plaintiff...... Versus PENNA. .............. j? N t>....... 99.-7582 ...Civ„il. HAROLD_ C-...KRAMF.R .......... ........._ l Defendant.. . .... ....__. DECREE IN D I V O// R C E ?- J0`1s'A,1k . AND NOW, .........?:`"R .....T..., V9..?9901 it is ordered and decreed that .. .....Gloria. .J...Kramer . . . . . . . . .. .. . . . . . . . . . . .. . . . . . plaintiff, ........ , Harold, C.,,Kramer ........................... defendant, and ................... 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; ........................................................................... .................................................. D y r t : Attest: J. Prothonotary W . W. •a: s:• W. W. te> ;c• te:•. 'V. <? • •:e> :e: +e> •y:? te> tc• <e, ce:• ?:e:• <e> :e:• :e:• •:e: •:w ? `:e:• •:e:•. t%• •: iy ,o 0 ti ;.¢?? ?/ f?D ? ??? n? ? ?? ??/Jp `???a 5 n?? ? G? . ? GLORIA J. KRAMER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff C NO. C/C, - v. I IN DIVORCE HAROLD C. KRAMER, 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 pages 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?he Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Telephone: (717) 249-3166 011711-00001/12.16.991MCD/PAR/123208.1 GLORIA J. KRAMER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99- 7-582 (ncuc? V. IN DIVORCE HAROLD C. KRAMER, Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(iZ) OR 3301(4) OF THE DIVORCE CODE COUNT I - DIVORCE AND NOW, comes the Plaintiff, GLORIA J. KRAMER, by her attorneys, Johnson, Duffle, Stewart & Weidner, and files this Complaint in Divorce of which the following is a statement: 1. The Plaintiff, Gloria J. Kramer, is an adult individual with an address of P.O. Box 632, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Plaintiff will utilize P.O. Box in the interest of privacy and safety. 2. The Defendant, Harold C. Kramer, is an adult individual residing at 101 Fowlmouth Road, Bainbridge, Lancaster County, Pennsylvania, 17502-9430. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 17, 1989, in Harrisburg, Dauphin County, Pennsylvania, and separated on March 18, 1999. 5. There has been no prior action for divorce or annulment between the parties. 011 711-00001/12.16.99/MCD/PAR/123208.1 6. The Plaintiff has been advised of the availability of marriage counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce pursuant to Section 3301 (c) or (d) of the Divorce Code. JOHNSON, DUFFIE, Attorney I.D. No. 75966'V 301 Market Street P.O. Box 109 Lemoyne, Pennsylvania 17043 (717) 761-4540 Attorney for Plaintiff Gloria J. Kramer 11_x,.:.. 011711.00001 /12.16.99/M CD/PAR/123208.1 VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A § 4904, relating to unsworn falsification to authorities. DATE: Y? - 1 ` '1999 GLORIA J. KRA 011711.00001112.16.99/MCD/PAR/123208.1 GLORIA J. KRAMER, V. Plaintiff HAROLD C. KRAMER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AFFIDAVIT IN DIVORCE GLORIA J. KRAMER, 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. 1 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 by the Court. 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 unswom falsification to authorities. Date. /_l'.l'.. , 1999 Alai GLORIA J. KRAM R Defendant 011711 00001 /12.16.99/MCD/PAR/123208.1 GLORIA J. KRAMER, Plaintiff V. HAROLD C. KRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7SrzC7, IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OFA DIVORCE DECREE UNDER SECTION 33010 OF THE DIVORCE CODE I consent to the entry of a final Decree in 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. 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 falsification to authorities. Dater 11999 ?J b U 1 ' 1f?-Cd> 7L( GLORIA J. KRA R, Plaintiff 1. ..i 1? tip CJ IN THE COURT OF CCMMCN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GLORIA J. KRAMER, NO. 99-7582 Civil Plaintiff VS. HAROLD C. KRAMER, Defenant 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the comolaint: December 30, 1999 certified mail, restricted delivery 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 March 31, 2000 by the defendant March 31. 2000 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: none 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code Parties filed Waiver of Notice of Intent to file Praecipe to Transmit Record on January of 2000 and np,t,Pr 2n, Iggg ?( A torney for PI if f /Defendant f, _,. lu"i 1 . u _? J l7 . ?/1 - . C. .1: 'LU .m, il11711.00001 /9.8.00/MCD/PAR/123208.1 GLORIA J. KRAMER, Plaintiff V. HAROLD C. KRAMER, Defendant AFFIDAVIT OFCONSENT NO. 99-7582 IN DIVORCE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 20, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. 1 have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA counseling prior to the divorce becoming final. r.- l{ V311711.00001/3.8.00/MCD/PARI123208.1 P 'r. 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 unswom falsification to authorities. Date: I 2000 GLORIA J. KRA ER lain iff G C?j L r r . IU?: C\J -7? 1_ir', ti ^I - ui i w r.IG C O U - -Is i 011711.0000113.8.OOIMCDIPARI123208.1 GLORIA J. KRAMER, Plaintiff V. HAROLD C. KRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7582 IN DIVORCE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 20, 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 in divorce after service of notice of intention to request entry of the decree. 4. 1 have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 011711-00001/3.8.00/MCD/PAR/123208.1 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 falsification to authorities. Date: '2000 ?, 1? ^ d' X? PA 1 HAROLD C. KRAMER, Defendant uICJ Ci•;; IL !-: IL (1 c-j tr. L, Ov l =i f? I ' Il C:. • I.: f O CD r f GLORIA J. KRAMER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. QQ, -7gpo IN DIVORCE HAROLD C. KRAMER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OFA DIVORCE DECREE CINDER SECTION 3309(0 OF THE DIVORCE CO 1. I consent to the entry of a final Decree in 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. 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 unswom falsification to authorities. Date:. , 02000 " 0, . i !' HAROLD 0. KRAMER, Defends C N t f n ,J O Johnson, Duffle, Stewart & Weidner By: Mark C. Duffle I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 GLORIA J. KRAMER, Plaintiff V. HAROLD C. KRAMER, Defendant PROOF OF SERVICE NO. 99-7582 Civil CIVIL ACTION - IN DIVORCE I hereby certify that on the 28' day of December, 1999, that I served a true and correct copy of the COMPLAINT IN DIVORCE upon the Defendant, HAROLD C. KRAMER, by certified mail, restricted delivery, No. Z 200 146 415, to his address at 101 Fowimouth Road, Bainbridge, Pennsylvania 17502-9430, return receipt requested, attached hereto and made a part hereof. JOHNSON, DUFFIE, STEWART & C I rk C. Duffie Attorney I.D. No. 7590 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 761-4540 Attorneys for Plaintiff Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :129992 v SENDER: I also wish to receive the follow- in 13 Complete Items 1 andfor2 for additarWl serviws. Ing services (for an extra fee): y ^`+ Complete hems 3,4a. and 4b. ' D Print yourrwme and address on the reverse of this form so that we can return INS 1. p Addressee's Address u ' cardteyou:4. 1Anach this forth to the front of the mallpiece, or on the back it apace does not porrnt 2•iestricted Delivery e { I m rte. DWdte'Fatum Receipt Aequestod'on the mailpiece below the snide number. It h wham tw snide was delivered and the dale a - DThe Ratum flece?pl vn a ON to m delivered. d 3. Article Atldressed to: 4a. Article Number Z 200 146 415 Mr. Harold C. Kramer 3 101 Fowlmoach Road 4b?. Service Registered Type d *certified cc SaitiEfHd•7e, PA 17502-9430 0 Express Mail C ensured 6. Signature (Addressee or Agent, 0 N PS Fonn 3811, December 1994 ? Return Receipt for Merchandise ?COD °I . 7. Date of Del' S.Atldressee's Address (only U requestedand fee is pald)l, 102595.99.e.o223 Domestic Return Receipt Z 200 146 415 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. C a a O GO li U, 6 Do not use for International Mail Soo reverse Senile HirrArl r- Kramer Street 8 Number Post Office, Stale, 8 ZIP Code Postage $ Certified Fee Special Delivery Fee Restricted Deli a ee ! - '^•? Rehm Recd S g to W So horn t \ ?. l BR Dai ddr eT, 1•t I c? : •p f TOTAL P, 8 i Postmark or Data --,,_IV mcd 11711-1 ( ?o c` r r,. u ?^ h I-) ti Ui i -- U{ cli u- 0 O o a V GLORIA J. KRAMER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. NO. QQ_ HAROLD C. KRAMER, IN DIVORCE Defendant AFFIDAVIT HAROLD C. KRAMER, being duly sworn according to law, deposes and says: 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. 1 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 by the Court. 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 falsification to authorities. Date: I J 20001 A 0J . HAROLD C. KRAME ? l N ,i,• Q 77. CL _. L_ 'l J I IJ C3. i O U , t"6'- wg I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. ACTION - LAW Plaintiff VS. AR tA M Y?- Defendant File No. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /Defendant in the above patter, having been g,Fagte a Final Decree in Divorce on the 1 day of h reby 1elects to resume the for surname of lJ and gives this written notice pursuant to the provisions of 54 P. S 704. DATE: Signa ur W Signature & a me being resumed COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND On the /(i&__ day of Notary Public, personally app eci the be the person whose name is subscribed acknowledged that he/she executed the therein contained. P / before me, a above affi.ant known to me to to the within document and foregoing for the purpose In Wi.Lness Whereof, I have hereunto set. my hand and official seal.. PATRICIA A. SHATTO, Notary Public Car!!Ala 0om, CumberlAnd County My Comml?iiian Fr000 Occembor 17, 2001 s; ?I i. C, • ` Cl- J O 1111... - ?? LI :J L? e : J `I m (L 1 _ l I?.