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Home My WebLink About07-5075 .+ LEONARD W. CRUMB, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAI~TIA Civil Action- Law No. ~7-,5'o7s PAMELA A. CRUMB, Defendant IN DIVORCE N TI E You have been sued in oourf. If you wish to defend aSaiffit the claims set forth in the followi~ pages, You mast tales prompt action. Yan are warned that if you fail m do so, the case may proceed witinout you and a decroe oI' divorce or annulment may be entered against yon by the court. A judgn~rt may also be entered against you for any other claim or relief rarycsted in these papers by the Plainttiff. Yoa may lose money or property or other rights importa~ to yon, inch~ding custody or visitation of your children. When the ground for tine divorce is indignities or irretrievable brealcdovvn of the marriage, you may request marriage counseling. A list of marriiage counselors is available in the Office of the Prodronatary at the C;umberlaml Camty Court house, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ATfNUi-MENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TIIrEPHONE 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 Phone: (717) 249-3166 (800)990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Gad Camty is required by law to comply with the Americans with Disabilities Act of 1990. For won about accessible facilities and reasonable axommodations available to d;sabled individuals Laving boainess before the Coart, please contacx oar office. All must be made at l~ 72 Laos pricer tD aay hesning or business before the Cant All ~ mnst be made ~ least 72 hours prior to any hearing or business before due court. You must attend the scheduled conference or hearing. f ~ LEONARD W. CRUMB, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law : No. O'y' -says l: lvtL ~ PAMELA A. CRUMB, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Leonard W. Crumb, by and through his counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Leonard W. Crumb, who currently resides at 41 I~llside Drive, Cumberland County, Carlisle, Pennsylvania. 2. Defendant is Pamela A. Crumb, who c~rrrently resides at 538 Harvest Lane, Cumberland County, Mechanicsburg, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents in the Commom~vealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 21, 1985, in Morris, Ostego County, New York. 5. There have been no prior actions of divorce or for annulment between the patties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is availabley and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. .+ 8. Plaintiffrequests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiffrespecxfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, Date: ~~ a ~~, ~ ~ ..G,.X ~,.~ Michael J. Whare, 're Attcxney for Plaintiff 37 E. Pomfret Street Carlisle, PA 17013 (717) 243-3561 Supreme Court LD. # 89028 . , LEONARD W. CRUMB, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law PAMELA A. CRUMB, Defendant . No. IN DIVORCE ATTORNEY VERIFICATION I, Michael J. Where, Esq., verify that the statements made in this Complaint are true and direct. 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: ~'a~''~ ~~~~.J Michael J. Where, ~(ti~ `w V` W c *+ 1 e . ._.., ~ , . ~_ Gj ~~ ~ ~. ' 74~ 4 + _. U F '~.~t~ 1' ' "L7 ~ 1 t"='1 ' , ~ ~~C i _ tU ---1 LEONARD W. CRUMB, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 07-5075 Civil Term PAMELA A. CRUMB, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c} of the Divorce Code was filed on August 24, 2007. 2. The marriage of Plaintii~ and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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: ~2 • Z l ' Zoy~ Leonard Crumb, Plainti rya fJ ~ rrt~ ~ a ~L`~ N ...,,~ ~.: -=~ ~a ~; ~;: ~ ~ ' ~~; rrt t r~ ~ ~ , - ..c LEONARD W. CRUMB, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 07-5075 Civil Term PAMELA A. CRUMB, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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, lawyer'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 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. Date: 12 • 2 / • ~ Leonard .Crumb, Plaintiff ~:` N ~. { ~: ~.,. N "~. ~" LEONARD W. CRUMB, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 07-5075 Civil Term PAMELA A. CRUMB, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 24, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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: ~ U 7 ~~G~yV ~t,~(,~i~/ Pamela A. Crumb, Defendant ...~ ~ ~` ~ c's ~';, -, '~ ~' ~- ~ .,,,~ ..c LEONARD W. CRUMB, : IN THE COURT OF COMMON PLEAS OF Plairrtiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 07-5075 Civil Term PAMELA A. CRUMB, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST 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, lawyer'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 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. ll ~/(- Date: ~ o~ ~ d Pamela A. Crumb, Defendant s•? - ca n .-a ~ ~ "~~' ~ ~ ' ~ f~~~; -~`~ ' ~~~ ~ -, ~ ~~y' i '~ -e ~ __„ " .t~ ~ UIrt~1 bf,/'~ r M ~ LEONARD W. CRUMB, : IN TH$ COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :Civil Action- Law No. 07-5075 Civil Term PAMELA A. CRUMB, Defendant : IN DNORCE 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 § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Filed August 24, 2007, was served on the Defendant by certified mail, endorsed restricted delivery-return receipt requested and signed on September 8, 2007 (attached hereto as proof of service). 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: by the Plaintiff on December 21, 2007; by the Defendant on December 21, 2007. 4. Related claims pending: None. 5. (b) Date Plaintiff s Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: December 27, 2007. a ~ 1r ,~ ~ Date Defendant's Waiver of Notice in § 3301 (c}Divorce was filed with the Prothonotary: December 27, 2007. Respectfully submitted, Date: ~~ g' ~~ ~~~ Michael J. Whare, squire 37 East Pomfret Street Carlisle, Pa 17013 (717) 243-3561 Supreme Court ID # 89028 Attorney for Plaintiff c-~ c~ .. ~~ ~ :~ ~ L~ ~ Gv !`: .... ~ _ r 1 _ ('+ ~ _ } ~ LNARD W. CRUMB, Plaintiff v. PAMELA A. CRUMB, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil Action- Law No. 07-5075 Civil Term IN DIVORCE PROOF OF SERVICE ^ Complete items 1, 2, and 3. Also complete item 4 'if Restricted Delivery is desired. ^ Prlnt your Warne and address on the reverse SO tt1St YVe C8R fetUrR th@ Card t0 you. ^ Attach this card to the back of the mailpiece, or on the frontrf space permits. 1. Article Addressed to: Parhe~~ A . Crvw.~ . '~3``'4 ~wir~t5~ f~wnQ ~h~ni~~ilt7 . p~ P~Q~'~ a x y- ^ AQent l~ p~ ressee e..~G(~~l/ 1 ~ ~v 7 D. Is delNery address different from Item 1? ^ ~ If YES, enter delivery address below: ~No 3. Type Grdfied Mail ^ Express Mail ^ Registered ~ Retum Receipt far Merohandbr: ^ Insured Mail ^ C.O.D. 4. Res4lcted De1Neh/1(Extre Fee) Yes 2. Article Number (iansserfromsewk;e 7007 1490 ODD1 7951 4184 PS Form 3811, February 2004 Domestlc Return Rracelpt to25e~oz-nMtsao C~ ,~ =r~ T-T 111('' 1'{l ~~'1 E3'i~..~ C, -: ""i ~ . .!~ ~` 1 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. EnNKRt~ W. CR~~r~nR~ , ~~ . -~; ~1.~rN-rL~~ VERSUS ~/4P'IEL/4 /~.~uM N o . ~ Ot~7 --S'd 7~ Csyre. TEaM DECREE IN DIVORCE AND NOW, ~a,~,~~,,.,~ L3'° ~ Zs,o$ ~ IT IS ORDERED AND DECREED THAT L~•.G!/~~Q~,~~,/1/• C./~~/~y(f~ PLAINTIFF, AND ~/gME~iA ~ GRVpt1~ 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; BY THE ATT E T:n '/ PROTHONOTARY ~.~ ~. ~