HomeMy WebLinkAbout08-0969
IN
NICHOLAS P. CROMLEY SR.
PLAINTIFF
VS.
JACQUELINE S. CROMLEY
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION-DIVORCE
NO. 0$- qA civil lerv%
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take action within twenty (20) days after this Divorce
Complaint and Notice are served, by entering a written appearance personally or by
attorney and filing in writing with the Court your defenses or objections to the case may
proceed without you and a judgment may be entered against you by the Court without
further notice for any money claimed in this pleading or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to
you.
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
(717)249-3166
NOTICA
Le han Demando a usted en la corte. Si usted guiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al patrir de la
fecha de la demanda y la notification. Usted debe presenter una apariencia escrita o en
persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones
a las demandas en contra usted sin previo aviso o notificacion y por cualquier queja o
alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus
propiedades o ostros derechos importantes para usted.
LLEVEESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGANDO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL
SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA
CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717)249-3166
NICHOLAS P. CROMLEY SR.
PLAINTIFF
VS.
JACQUELINE S. CROMLEY
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION-DIVORCE
:NO. 01- 96 9t-(
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, Nicholas P. Cromley Sr., by his attorney, Codi M.
Tucker, Esquire, and pursuant to Section 3301 (d) of the Pennsylvania Divorce Code,
seeks to obtain a Decree in Divorce from the Defendant, Jacqueline S. Cromley, upon the
grounds set forth:
COUNTI
DIVORCE
1. The Plaintiff, Nicholas P. Cromley Sr., is an adult individual residing at 94 2nd
Street, Enola, PA 17025.
2. The Defendant, Jacqueline S. Cromley, is an adult individual residing at 7801
Chestnut Avenue, Parkville, MD 21234.
3. Plaintiff have been bona fide resident of the Commonwealth of Pennsylvania for
at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married in March 17, 1998 in Camp Hill,
Pennsylvania.
5. Plaintiff has been advised of the availability of counseling and that Plaintiff may
have the right to request that the Court require the parties to participate in counseling and
does not request the same.
6. There have been no prior actions of divorce or annulment between the parties in
this or any other jurisdiction.
7. The Plaintiff and Defendant are both citizens of the United States of America.
8. The Defendant is not a retired member of the Armed Services of the United
States.
9. The parties have no minor children together.
10. The Plaintiff avers that the grounds on which the action is based are:
(a) That the marriage is irretrievably broken under 23 Pa. Const. Stat. § 3301(d).
(b) The parties have been separated since February 23, 2002.
11. The plaintiff requests this Honorable Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests your Honorable Court enter a Decree as
follows dissolving the marriage between the parties.
Respectfully submitted
r Codi M. Tucker, Esquire
Attorney for Plaintiff
Guida Law Offices, P.C.
111 Locust Street
Harrisburg, PA 17101
(717) 236-6440
Supreme Court ID # 205158
.. •
NICHOLAS P. CROMLEY SR.
PLAINTIFF
VS
JACQUELINE S. CROMLEY
DEFENDANT
: IN THE COURT OF COMMON PLEAS
:4)A4#PKW COUNTY, PENNSYLVANIA
: CIVIL ACTION - DIVORCE
. NO.
NOTICE
If you wish to deny any o the statements set forth in this affidavit, you must file a
counter-affidavit with in twenty days after this affidavit has been served on you or the
statements will be admitted.
AFFIDAVIT UNDER
SECTION 3301 (d) OF THE
DIVORCE CODE
1. The parties to this action separated on February 23, 2002 and have continued to
live separate and apart for a period of at least two years.
2. The marriage of plaintiff and defendant is irretrievably broken.
3. 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.
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 04
Nicholas P. Cromley Sr.
•
>.
I, Nicholas P. Cromley Sr., verify that the statements made in this Divorce Complaint 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.
P. CROMLEY SR.
DATE: d g ) 1
T RNEY FOR PLAINTIFF
-
b4--
!;7
CA <
Codi M. Tucker, Esquire
GUIDA LAW OFFICES, P.C.
111 Locust Street Harrisburg PA 17101
717-236-6440
NICHOLAS P. CROMLEY, SR.
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
V.
JACQUELINE S. CROMLEY
Defendant
No. 08-969 CIVIL TERM
CIVIL ACTION -LAW
DIVORCE
PRAECIPE TO REINSTATE COMPLAINT
To the Prothonotary:
Kindly reinstate the complaint in the above captioned matter.
Date:
Codi M. Tucker, Esquire
Attorney for Plaintiff
Attorney I.D. Number 205158
GUIDA LAW OFFICES, P.C.
111 Locust Street, Harrisburg PA 17101
717-724-0516
1 ?
20 MFR ° '..:?
?c?
-'lo .Oe-?-
Nicholas Cromley, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLAA- LAq -
:g n
y
?r°
V. : CIVIL ACTION-DIVORCE
(-:z
* lc:
Jacqueline S. Cromley, v C
j Q-n
Defendant :NO. 08-969 CIVIL TERM? = w ?,
WITHDRAWAL AND ENTRY OF APPEARANCE
TO THE PROTHONOTARY OF SAID COURT:
PLEASE withdraw my appearance as attorney of record for the Plaintiff, Nicholas
Cromley, at the above captioned docket.
Res ectfully submitted by,
ail Souders, Esq.
Guida Law Offices
Dated:
PLEASE enter my appearance as attorney of record on behalf of the Plaintiff, Nicholas
Cromley, at the above captioned docket.
Respectfully submitted by:
CoMeka Anderson
Certified Legal Intern
-F'6,1W !;?' ?/?
ROBERT RAINS
THOMAS M. PLACE
ANNE MACDONALD-FOX
MEGAN RIESMEYER
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
Fax: 717-243-3639
Nicholas Cromley, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN CUSTODY
Jacqueline S. Cromley,
Defendant NO. 08-0969 CIVIL TERM'.
-ter -n
PRAECIPE TO PROCEED IN FORMA PAUPERIS'?
TO THE PROTHONOTARY:
Kindly allow Nicholas Cromley, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Respectfully submitted,
Date I `? . ?j? )
o i Anderson
Ce Legal Intern
ANNE X!A JONALD-FOX
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
Nicholas Cromley, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION-LAW '
Jacqueline S. Cromley, : DIVORCE
°=
`-
Defendant
No. 08-0969 CIVIL TERM cry --
PRAECIPE TO REINSTATE COMPLAINT
-?
To The Prothonotary:
Please reinstate the Divorce Complaint at the above-captioned docket.
CoCt nderson
Ceregal I ntern
F
A*Mac ald-Fox, Es Suttorney
Date: February 17, 2011
7 F F
Nicholas P. Cromley, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVAIy?
v. rnm
=rn
CIVIL ACTION-LAW C_
z
-rnv
DIVORCE
j rn
Jacqueline S. Cromley, ?--
?
= -4 C:)
-
Defendant C-.
NO. 08 -?96?9 41.q CIVIL TERM
?
4r`?a
CERTIFICATE OF SERVICE
I, Gail Guida Souders , Esq., hereby certify that Guida Law Offices served a true and
correct copy of the Divorce Complaint and Plaintiff's Affidavit under Section 3301(d) of the
Divorce Code on Jacqueline S. Cromley, residing at Summerdale Apartments, 225 Four Seasons
Lane, Enola, PA 17025, by depositing a copy of the same in the United States mail, certified,
restricted delivery, return receipt requested, postage prepaid and a another copy of the same in
the United States mail, first class. Pursuant to Pa.C.R.P. 403 service was complete upon
Jacqueline S. Cromley on the 20th day of May, 2008 , because she refused to accept the
certified mail as evidenced by the attached photocopy of the certified mail envelope (Exhibit A),
and the First Class Mail was not returned within 15 days.
Gail Guida Souders
Attorney
Guida Law Offices
111 Locust Street
Harrisburg, PA 17101
Phone (717) 236-6440
Nicholas Cromley,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION-LAW
Jacqueline S. Cromley, :DIVORCE zrn c Mr
Defendant
No. 08-0969 CIVIL TERM car-
te
?x>
r-
rn
CD
CCD =?
Q C3 -n
; C: '- ` r i
PRAECIPE TO REINSTATE COMPLAINT C_n
To The Prothonotary:
Please reinstate the Divorce Complaint at the above-captioned docket.
Garret J. Brouwer
Certified Legal Intern
Meg Vseismeyer, iEsq.
Supervising Attorney
Date: July 21, 2011
1
Nicholas Cromley; : IN THE COURT OF COMMON PLEAS OF
Plantiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION -- LAW
IN DIVORCE
Jacqueline Cromley,
Defendant NO. 08-969 CIVIL TERM
ORDER OF COURT
AND NOW, this day a 2012, upon consideration of the attached Petition
? ?,??,
and Affidavit Pursuant to Rule 430 for Special Order of Court Directing Method of Service of
Process, it is ordered that service of the Divorce Complaint shall be made by publication of the
attached Notice, once in the Cumberland Law Journal and once in the Carlisle Sentinel.
By the Court,
Judge
> C-D i
c
raot. /7 /00 el;n . G
epy ,Ied &A'//';t
)e4z c
Nicholas Cromley
Plaintiff
V.
Jacqueline S. Cromley,
Defendant
To The Prothonotary:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
DIVORCE
No. 08-0969 CIVIL TERM
PRAECIPE TO REINSTATE COMPLAINT
"c- ca_T
Please reinstate the Divorce Complaint at the above-captioned docket.
U .
arisa Burkett
Certified Legal Intern
_Aj-& 44&1?
Meganeismeyer, Esq.
Supervising Attorney
Date: June 13, 2012
og-
T'
=
PROOF OF PUBLICATION OF NOTICE y
MW C-
IN CUMBERLAND LAW JOURNAL :ZZ C=
n
!Q
C-
COMMONWEALTH OF PENNSYLVAMA -`
COUNTY OF CUMBERLAND cn
I, LISA MARIE COYNE , of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates:
--lo -- 2 012
A.ffaint further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place, and character of publication are true.
2)4v' - ---
to and Subscribed before me this
6 of July, 2012
otary
NOTARIAL SE
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
CUMBERLAND LAW JOURNAL
LEGAL NOTICE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 08-0969 Civil Term
IN DIVORCE
Nicholas Cromley
V.
Jacqueline S. Crowley
NOTICE TO DEFEND
AND CLAIM RIGHTS
To: Jacqueline S. Cromley
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.
YOU SHOULD TAKE THIS PAPER
TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO
OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO
HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES
THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A RE-
DUCED FEE OR NO FEE.
Cumberland County
Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
July 6
4
Nicholas Cromley, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - Divorce
Jacqueline S. Cromley,
Defendant DOCKET # 08-0969
c
r
PRAECIPE TO FILE PROOF OF PUBLICATION cnr' r
-<> "
> cn s
To the Prothonotary: ? ci=).-._-
.-, cn
,,n
Please file the attached proof of publication from The Sentinel and the CumArland
Journal in the above docketed case.
Date:
Marisa Burkett
Certified Legal Intern
Mega Riesmeyer
Supervising Attorney
FAMILY LAW CLINIC
371 West South Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
?-i
r:
vi
ter,
Proof of Publication.
State of Pennsylvania, County of Cumberland
of the Sentinel, of the County and State aforesaid, being duly sworn?
deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of
Carlisle, County and State aforesaid, was established December 13`h 1881, since which date THE
SENTINEL has been regularly issued in said County, and that the printed notice or publication
attached hereto is exactly the same as was printed and published in the regular editions and
issues of THE SENTINEL on the following day(s):
Affaint further deposes that he/she is not interested in the subject matter of the aforesaid notice
or advertisement, and that all allegations in the foregoing statement as to time, place and
character of publication are true.
M ta» court of commw, psa o!
c o?oe-oea°?"" Y. CjW P r? ".ale
IN DIVORCE
Mow" ClOrril" V, Jacqueline S. Grompay
To: Jacqueline 3, Cromlay
NOTICE TO DEFEND AND NTO
You hate 4sen arnsAln court. If yW.wlsh to
In the k-40**W
yo. fog t. d. '90'zt Y*U moo I".
10
'h+tMN" as eOMrWs i ?0 a si li ollpy c?a proon"
p" P''ty by a'r thy ' 66W *40 A ? rd1aY Wso
Huporantto yoa, roft
YOU
00 NOT HD TAKE TNI$ PAPTR TO YOUR LAWYER AT ONCE, IF YOU
ftHj Ej0W. O TO OR TELEP
F 9tOW CAN PROVIDE YOU WITHE OOFFiCrz,
ABOUT HIRING A LAWYER
RMAN
IF YOU CANNOT AFFORD TO HIRE A L*IVYE TH13 OFFICE MAY BE
3?d ir,IF O% UT IICiEMIClES i
ES OELIE4ISLE ERSONOATA
Cw1?eb9+lidpfuF?Bpa?yjpk!
7TP7-248 3 ? 17013
Sworn to and this
__ day of Notary
NOTuIAL S
EK
BAMBI ANN HECKENDORN
Notary Public
CARLISLE BOROUGH, CUMBERLAND CNTY
i+Ay Commission Expires Jan 2; , 2014
C c?
L
C--
C17 -,
Nicholas Cromley, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION-LAW
DIVORCE
C7
Jacqueline S. Cromley -, X -; ;
Defendant NO. 08-0969 CIVIL TERM rte-
221
CERTIFICATE OF SERVICE r??
I, Marisa Burkett, Certified Legal Intern, The Community Law Clinic, hereby certify th it
I served a true and correct copy of the Praecipe to File Proof of Publication, today, July 13, 201 ,
on Jacqueline S. Cromley, whose last known residence is 111 Second Street, Enola, PA 17025,
by depositing a copy of the same in the United States mail, first class.
Ak &t&bl
Marisa Burkett
Certified Legal Intern
Nicholas Cromely,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
M., C--
Jacqueline S. Cromley. cnr`-
1w 1
Defendant : NO. 08-0969 CIVIL TERM ?"..L
2? C> ?
NOTICE TO DEFENDANT
. Y?
If you .Nish to deny any of the allegations set forth in this affidavit, you must file a
counteraffidavit within twenty days after this affidavit has been served on you or the
will be admitted.
c;
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on February 23, 2002, and have continued to live
separate and apart for a period of at least 2 years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property,
fees or expenses if I do not claim them before a divorce is granted.
I verifv 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
falsification to authorities.
Date -7,/Z -YL
Nicholas Cromley Plaintiff
Nicholas Cromley, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION-LAW
DIVORCE
Jacqueline S. Cromley,
Defendant NO. 08-0969 CIVIL TERM
CERTIFICATE OF SERVICE
I, Marisa Burkett, Certified Legal Intern, The Community Law Clinic, hereby certify
I served a true and correct copy of the Notice to Defendant on Friday, Jul 20, 2012, on
Jacqueline S. Cromley, whose last known residence is 111 Second Street, Enola, PA 17025, by
depositing a copy of the same in the United States mail, first class.
4
Marisa Burkett
Certified Legal Intern
THE COMMUNITY LAW CI
371 W. South Street
Carlisle, PA 17013 `"c w c
(717) 243-2968 -? =
Nicholas Cromley, IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION-LAW
DIVORCE
Jacqueline S. Cromley,
Defendant NO. 08-0969 CIVIL TERM
CERTIFICATE OF SERVICE
I, Marisa Burkett ,Certified Legal Intern, Community Law Clinic, hereby certify that I
served a true and correct copy of a Notice of Intention to Request Entry of Divorce Decree and
Defendant's Counter Affidavit on Jacqueline S. Cromley, whose last known addresses are 111
Second Street, Apt 2, Enola PA, 17025 and 7801 Chestnut Avenue, Parkville, MD 21234, by
depositing a copy of the same to each address in the United States mail, first class on Friday,
August 10, 2012.
~~~
Marisa Burkett
Certified Legal Intern
--s rw
C
'"i:7 ~ ° ~
(r7 C."'
i.! i r ---
-G; ;'~ GJ
~r
;v-. (,.
•"n' :-;
_-~.~
1 ~~
:~°
~;~'
"~ 4...-
} ~"
.., I_,, '...
..,,~J
Nicholas Cromley, : IN THE COURT OF COMMON PLE4 O ; Y.+
Plaintiff : CUMBERLAND COUNTY
PENNS VANIA
,
-10
rnrn ran
:
V. : NO. 08-0969 CIVIL TERM -0
70
Jacqueline S. Cromley, : CIVIL ACTION - LAW -o ca{
Defendant ; 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(d)(1)) of the Divorce Code.
2. Date atd manner of service of the complaint: Service by Publication in The Sentinel on June
27, 2012. An additional notice was published in the Cumberland Bar Journal on
July 6, 2012.
3. Complete either paragraph (a) or (b).
(a? Date of execution of the affidavit of consent required by § 3301(c) of the
Divorce code: by plaintiff ; by defendant
(b)
(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code:
July 12, 2012
(2) Date of filing and service of the plaintiff's § 3 301(d) affidavit upon the
respondent opposing party: Filed on July 19, 2012 and served July 20, 20126
4. Related) claims pending: None
5. Complo I te 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: Service by first class mail on August 10, 2012.
(b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: N/A
Date defendant's Waiver of Notice was filed with the Prothonotary:N/A
ttorney for Plaintiff
Nicholas Cromley : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : DIVORCE
Jacquelinq S. Cromley,
Delfendant : NO: 08-0969 CIVIL TERM
NOTIM OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE
TO: DEFENDANT
Yc have been sued in an action for divorce. You have failed to answer the complaint or
file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after August 30, 2012, the
other party can request the court to enter a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature
notarized or verified or a counter-affidavit by the above date,,'-the court can enter a final decree in
divorce. k, counter-affidavit which you may file with the prothonotary of the court is attached to
this notice.
U: ess you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief. The filing of the form counter-affidavit alone does not protect
your ecor jomic claims.
Y U SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NO 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.
I YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court 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 o office. All arrangements must be made at least 72 hours prior to any hearing or
business te-fore the court. You must attend the scheduled conference or hearing.