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Home My WebLink About03-4230SHIRLEY I. KRADER, Plaintiff VS. RICHARD M. KRADER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. CIVIL ACTION - LAW 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 arc 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 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 the Prothonotary at the Cumberland County Court House, One Courthouse Square, 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, PA 17013-3302 (717) 249-3166 SHIRLEY I. KRADER, : Plaintiff : : vs. : NO. RICHARD M. KRADER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. CIVIL ACTION - LAW 1N DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las pJginas siguientes, debe romar acci6n con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede set emitido en su contra pot la Corte. Una decisi6n puede tambi6n set emitida en su contra pot cualquier otra queja o compensaci6n reclamados pot el demandant. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esttl disponible en la oficina del Prothonotry, en la Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALOUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO~ VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER AS1STENCIA LEGAL. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013-3302 (717) 249-3166 SHIRLEY I. KRADER, : Plaintiff : : vs. : NO. RICHARD M. KRADER, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE COUNT I Plaintiff, Shirley 1. Krader, by her attorney, Jane M. Alexander, }~uire, and files this Complaint upon a cause of action of which the following is a statement. 1. Plaintiff is Shirley 1. Krader, 52 years of age, who currently resides at 120 St. Johns Drive, Camp Hill, Hampden Township, Cumberland County, Pennsylvania, 17011. 2. Defendant is Richard M. Krader, 65 years of age, who currently resides at 4931 Carlisle Pike, Mechanicsburg, Hampden Township, Cumberland County, Pennsylvania, 170.~,~. 3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania for at least six (6) months prior to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on December 8, 1978 in Dillsburg, Pennsylvania by a Minister. 5. Them were no children born between the parties during the marriage. 6. Them were no prior actions in divorce or annulment commenced by the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render her condition intolerable and life burdensome. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNTII 10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by reference and made a part hereof. 1 I. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully Submitted, ey f4.r the Pl~fitiff o. 07355 · Baltimore Street Dillsburg, PA 17019 (717) 432-4514 VERIFICATION 1 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 un-sworn falsification to authorities. Date: COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK S.S Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, Personally appeared Shirley I. Krader who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, information and belief. Sworn to and subscribed before me t,~a,~7~.~ day of ,2003. Halyard E. Alexand~, Notary Publk Dilh .~ Bow. yo~k County My Commission Expires Apr. 23, 2005 SHIRLEY I. KRADER, VS. RICHARD M. KRADER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 03-4230 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE AND ~ of ~~,2003 personally NOW, this ~,~ ~ay appeared Jane M. Alexander, Esquire who swears ding to law, that a true and correct copy of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return receipt requested upon the said, Richard M. Krader 4931 Carlisle Pike Mechanicsburg, Pa. 17055 on Augu~29_,_23~ by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt 4 return receipt hereto attached and made a part hereof. ~~~ / /!one M. Al~'x~lder, Esqu~,e~ [ / Attorney I.D/#07355/ I / 148 S. Baltimore Stre~ I / Dillsburg, PA 17019-0421 V (717) 432-4514 Sworn and subscribed before me this .2.~ day of / NotarY Publi0/ SHIRLEY I. KRADER, VS. RICHARD M. KRADER, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 03-4230 CIVIL CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE Return Reclept Fee (Endorsement Rsquired) (Endorsement Required) · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reveme so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 1"/0 ,5 2. /b~icle Number (Copy from service label) PS Form 3811, July 1999 C. Signature r'l Addressee D. Isdelive~ 17 J--I Yes If YES, e~ter delivery address below: [] No 3. e ~lfled Mall [] .~xpeees Mall [] Reg~tered [J~'Retum Receipt for Merchandise [] Irmured Mall [] C.O,D. 4. Reetdcted Deliver? (Ex'tm FOe) _ 7002 3150 0004 4252 2704 Dome~ic Return Receipt 102595-00-M-095~2 SHIRLEY 1. KRADER, Plaintiff VS. RICHARD M. KRADER, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 03-4230 CIVIL CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE SECTION 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 l'ees or expenses if 1 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 ~rothonotary. 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. Section 4904 relating to unsworn falsification to authorities. Shirley I. Krad~/ SHIRLEY 1. KRADER, Plaintiff VS. RICHARD M. KRADER, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA : NO. 03-4230 CIVIL : : CIVIL ACTION- LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE SECTION 3301(C) OF THE DIVORCE CODE I. l 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 ifl 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. 1 verify that the statements made in this affidavit, are true and correct. I understand that [hlsc statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsx~orn falsification to authorities. [)ate: Richard M. K7a-der ',~ SHIRLEY I. KRADER, Plaintiff VS. RICHARD M. KRADER, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 03-4230 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 27, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. 3. I consent to the entry ora final decree of divorce after service of notice of intention to request entry of the decree. 1 verify that the statements made in the 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 onsworn falsification to authorities. Shirley I. Krarder SHIRLEY I. KRADER, Plaintiff VS. RICHARD M. KRADER, Defendant THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO. 03-4230 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 27, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry' of the decree. I verify that the statements made in the Affidavit are true and correct. I understand that Ihlse statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to uns~xorn falsification to authorities. Date: Richard M. Krader / SHIRLEY I. KRADER, PLAINTIFF VS. RICHARD M. KRADER, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA : NO. 03-4230 CIVIL : : CIVIL ACTION - LAW : 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: was sent certified mail, restricted dclivery on August 28, 2003 and was served to the Defendant on August 29, 2003 3. (Complete either paragraph (a) or (b).) (a) Date of execntion of the affidavit of consent require by §3301(c) of the Divorce Code: by PlaintiffDecember 2, 2003; by defendant December 10, 2003. (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: N/A; (2) (a) Date of filing of Plaintiff's affidavit upon respondent: N/A. (b) Date of service of the plaintiWs affidavit upon the defendant: N/A. 4. Related claims pending: All claims are settled and satisfied by a Post Nuptial Separation and Property Settlement Agreement dated August 7, 2003 signed by both parties. 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 Divorce was filed with the Prothonotary: Deccmber 8~ 2003. (c) Date Defendant's Waiver of Notice in Divorce was filed with the Prothonotary: (/?~e M. A~e~:-an~r~, ,~ttomey/l~ Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PEN NA. VERSUS N O. 03-4230 ~ DECREE IN DIVORCE AND NOW, DECREED THAT ~_~L, IT IS ORDERED AND , PLAINTIFF, __, DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. YET BEEN ENTERED; ATT T: ~ -- - J' ~ ~--' - / PROTHONOTARY