The URL can be used to link to this page

Home My WebLink About07-3118 STAGY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN GARRISON-CRAMER, Plaintiff v. gEVIN L. CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - 3~ ~~ CIVIL TERM IN DIVORCE AND CUSTODY N TI E 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 roamed that if you fail to do so, the case may proceed without you and a decree in divorce or annulment maybe 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 STAGY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN GARRISON-CRAMER, Plaintiff v. KEVIN L. CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - ~~ //~ CIVIL TERM IN DIVORCE AND CUSTODY COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Erin Garrison-Cramer, an adult individual residing at 474 Old Federal Road, Shorter, Alabama 36075. 2. The defendant is Kevin L. Cramer, an adult individual residing at 2751 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013. 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. 4. The parties were married on December 29, 2001, in Birmingham, Alabama. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The plaintiff avers that she has been advised of the availability of counseling and that said parry has the right to request that the court require the parties to participate in counseling. 4 COUNT I ~ZUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DNORCE CODE 7. The averments of Paragraphs 1 through 6 hereof are incorporated herein by reference. 8. The marriage between the parties is irretrievably broken. 9. After ninety (90) days have elapsed from the date of the filing and service of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety (90) days have elapsed fromthe filing and service of this Complaint, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to § 3301(c) of the Divorce Code. COUNT II RF UEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(dl OF THE DIVORCE CODE 10. The averments of Paragraphs 1 through 9 hereof are incorporated herein by reference. 11. The marriage of the parties is irretrievably broken. 12. The parties are living separate and apart; and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years as specified in § 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to § 3301(d) of the Divorce Code. 13. The averments of Paragraphs 1 through 12 hereof are incorporated herein by reference. • ~ 1i 14. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree of divorce pursuant to § 3301(a) of the Divorce Code to Plaintiff, the innocent and injured spouse. COUNT IV CUSTODY 15. The averments of Paragraphs 1 through 14 hereof are incorporated herein by reference. 16. Plaintiff seeks custody of the following child: Name Present Residence Aug Emma A. Cramer 474 Old Federal Road 4 years Shorter, AL 36075 D.O.B. 7/24/2002 17. Plaintiff and Defendant are the natural parents of the child. 18. The child was born during the marriage of the parties. 19. The child is presently in the custody of Plaintiff, who resides at 474 Old Federal Road, Shorter, Alabama 36075. 20. Since the child's birth, the child has resided with the following persons at the following addresses: Plaintiff 474 Old Federal Road Shorter, AL 36075 Plaintiff/Defendant 2751 Spring Road Carlisle, PA 17013 Plaintiff Plaintiff/Defendant 3136 Opal Drive Nigh Ridge, MO 63049 3136 Opal Drive High Ridge, MO 63049 Dates: 1/ 18/07-present 12/2005-1/18/2007 10/2005-12/2005 8/2002-10/2005 .. Plaintiff 1353 Orlando Circle Birth-8/2002 Birmingham, AL 35215 21. Plaintiff has not participated as a parry or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 22. Plaintiff has no information of a custodyproceeding concerning the child pending in a court of this Commonwealth or any other state. 23. Plaintiff does not know of a person not a parry to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 24. Mother has been the primary caregiver of the child since the child's birth. 25. Upon information and belief, Cumberland County Children & Youth Services is currently investigating the child's allegations that Father sexually abused her. As of the date of this filing, there have been no results of this investigation. 26. The child fears her father due to his treatment of Mother and conduct around the child and is currently in weekly therapy sessions. 27. The best interests and permanent welfare of the child will be served by granting the relief requested herein. WHEREFORE, for the reasons set forth herein, Plaintiff, Erin Garrison Cramer, respectfully requests that the Court enter an order granting her custody of the child. WOLF & WOLF ~~ , 2007 BY: STACY B. O F, ESQUI Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff VERIFICATIOI~I I verify that the statements made in this complaint 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. ., 2.~ 2~~ ~~ 6cu~c - C~. ~~, , Erin Garrison-Cramer, Plaintiff -_. (, ~' '~ ~~w ~ c w ,~ C -~ oQ 10 ~, ^a C) ~_-~ -~, ~' i f°1 --< "~ STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 !0 WEST HIGH STREET CARLISLE PA 17013 (717) 241-A436 ATTORNEY FOR PLAINTIFF ERIN GARRISON-CRAMER, Plaintiff v. SEVIN L. CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : N0.07 - ~ ~ _ CIVIL TERM IN DIVORCE AND CUSTODY 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. Z 2007 ~,.~,~`'~'~` Erin Garrison-Cramer, Plaintiff r.., ~? ~ O P +-..J .. , _ ~~ T h _ _ .. 1 ~.. T.,w ~ 7 - r, r ~ ' -.. --! -.~ C, ERIN GARRISON-CRAMER IN THE COURT OF COMMON PLEAS OF PL.,AINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEVIN L. CRAMER DFFE:NDANT 07-3118 CIVCL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, _____ Friday, May 25, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, June 19, 2007 at 8:30 AM for aPre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children arc five or older may also be present at the conference. Failure to appear at the conference may provide grounds t~~r entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: _/s/ acgueline M. Verney, Esg'. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. 1F YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTE-{ I3ELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County 13ar Association 32 South E3edt~~rd Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 C O- SP 5' ,tir ~v.~~S ~-r~ /~ ' ~ -~ 7/-" , ,~j ~ V ~l9r7 ~ ~O S o ~ 2~(/ /~rl ~ ~ ~ "~,~ ~~.~ :_:• ~~ ;~ ~ ,~ ~f-~l. =~L' -~-~~~ JU1~ 19 2D07 ~' ERIN GARRISON-CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA V. : N0.2007-3118 CIVIL ACTION -LAW KEVIN L. CRAMER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~" day of Qom- , 2007, upon consideration of the attached Custody Conciliation Report, it is ordered and directed as follows: 1. The Mother, Erin Garrison-Cramer shall have sole legal and sole physical custody of Emma A. Cramer, born July 24, 2002. 2. This Order is entered pursuant to the agreement of the parties at a Custody Conciliation Conference. The parties may modify the terms of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. cc• acy B. Wolf, Esquire, for Mother vin L. Cramer, pro se 2751 Spring Road Carlisle, PA 17013 A ~' BY THE COURT, ~ ~1l~i~~f~~~hSf`Jh~~d E ~ ~ 1 ~~ { ~ N~lf EgOZ ~b~l~Ivv~ a ~ ~:~~~ GMs ~~? ~,il-~-~x~-~1L~ ERIN GARRISON-CRAMER, Plaintiff v. KEVIN L. CRAMER, Defendant PRIOR JUDGE: None IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA 2007-3118 CIVIL ACTION -LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Emma A. Cramer DATE OF BIRTH CURRENTLY IN CUSTODY OF July 24, 2002 Mother 2. A Conciliation Conference was held in this matter on June 19, 2007. The Mother, Erin Garrison-Cramer, appeared with her counsel Stacy B. Wolf, Esquire. Father, Kevin L. Cramer, pro se. 3. The parties agreed to the entry of the Order as attached. (~ ~, - I c7 -07 Date acq eline M. Verney, Esquire Custody Conciliator STAGY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ERIN GARRISON-CRAMER, Plaintiff v. KEVIN L. CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - ~! ~ ~ CIVIL TERM IN DIVORCE AND CUSTODY ACCEPTANCE OF SERVICE I, Kevin L. Cramer, celtify that I am the defendant in this matter. Furthermore, I hereby certify that on J gh e (g , 2007, I received a certified copy of the divorce complaint filed in this action. J H,, F ~ p , aoo~ ~~ Kevin L. Cramer Defendant r.~ ~ x_ N ~s _.. ~„ ~ ~ ~. ~:" ~ G ~ `~, ,~ ..s ~