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HomeMy WebLinkAbout08-1377ORIGINAL Adrienne D. Banko-Crawford IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08-1 3') CIVIL TERM David M. Crawford Defendant 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 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. 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, 1 Courthouse Square, Carlisle, Pennsylvania. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 JANICIRO Adrienne D. Banko-Crawford Plaintiff V. David M. Crawford Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- ?j71 CIVIL TERM . IN DIVORCE ,? fCOMPLAINT UNDER §3301(c9) or (d) OF THE DIVORCE CODE 1. Plaintiff is IW Wk I f u1 fIC b040 - ?aAPA , who currently resides at Cumberland County, Pennsylvania. 2. Defendant is -PAdl d CgGO?o , who currently resides at o 0 0 Cooks E54-FAss &Vp 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ?We4 ew- 7 , col at ?} . -?atKLC-K- CGl. , C? ?lislsL. 1 5. The marriage is irretrievably broken, and the parties separated on J ?,1? I ?ZoaS" 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 4 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. -212006 4LI? ea?g - ( 'x-4JJr"'J . Date Plaintiff, Pro Se I, ?Rlek1ne iK4 - ? car al 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 subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: Plaintiff, Pro Se Assisted by: Diane Radcliff, Esq. Law Firm of Diane Radcliff 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 . V c:a ..al i C. fl Ir• ORIGINAL Adrienne D. Banko-Crawford IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- ?37?7 CIVIL TERM David M. Crawford Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Adrienne D. Banko-Crawford, Plaintiff, to proceed in forma au eris. I, Diane Radcliff, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. f , squire rn :rc Law Firm of Diane Radcliff 3448 Trindle Road Camp Hill, PA 17011 (717) 737-0100 JAM10120 r?y Ts e _ :-tt Adrienne D. Banko-Crawford IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- I3-) CIVIL TERM David M. Crawford Defendant IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER §3301 (d) OF THE DIVORCE CODE and continued to 1. The parties to this action separated on J L4 IU I . ZOOS- live separate and apart for a period of two year. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of marital property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. I, "tZ(-(WX54A4 " [RaW r d, verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 P.S. Section 4904. -7-/2*JWC02. 1?1,Lryt - Date Plaintiff, Pro Se C"? v.k; r-" ,_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. 0'3- IN DIVORCE Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking 'V] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of dR i e ?n e, and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: 3114(05 /Ut?? 6et'?tz' - Signature /:/1" I?7 Signature of name being resumed COMMONWE LTH OF PENNSYLVANIA ) COUNTY OFC" On the I l VK day of , 200, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. t my hand and official In Witness Whereof, I have hereunto set my hand hereunt7/---4 seal. // n Prothonotary or Notary Public NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 O rl -Tj P-1 rrt 77, M W ? n ?wo N ADRIENNE D. BANKO-CRAWFORD Plaintiff V. DAVID M. CRAWFORD : Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-1377 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on March 10, 2008, 1 served a true and correct copy of the Complaint in Divorce and Plaintiff's 3301(d) Affidavit upon David M. Crawford, the Defendant, by Certified Mail, Restricted Delivery, addressed as follows: David M. Crawford 10001 Coors By Pass Blvd. Apartment 2124 Albuquerque, NM 87114 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. DC IFF, ESQUIRE ad Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff ¦ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. ¦ print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailplece, or on the front if space permits. 1. Article Addressed to: :DQIlld M. (21/'Qa)4rd /coo/ ay P --?S '61kc a4 u aju e, /O U S'711 X 77??I JJ 7/ v 13 nda % Receive, by (Printed Nag*). I C. Date of [Jell D. Is delivery address different from Item 14 0'Ym If YES, enter delivery address below: 0 No 3, ke Type road Mail 0 Express Mail Registered 0 Return Receipt for Merchandise 0 Insured mail 0 C.O.D. 4. Restricted, Wlpwrl(1 XwftFeyl Y. 2• ArrideNumber 7007 0710 0003 9223 9165 ( wwfer font servios Ps Form 3811, February 2004 Domestic Retum Rscsipt 102ros-0¢.M_1540 EXHIBIT "A" CERTIFIED MAIL RETURN RECEIPT CARD c n?; r? , ' ? ??r,_4 ,? .- ? `?' r.-_ ?',, _? .? ?--. -?, _, , >tJ , .. r ?- ° ? ^ ,-_ . ? E"?,i ?:,, .".?C ADRIENNE D. )-CRAWFORD Plaintiff D Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v DAVID M. CRA NO. 08-1377 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Diane G. Radcliff, Esquire, hereby certify that: On April] 9, 2008, 1 served a true and correct copy of the 33010 Notice of Intentiob to Request Entry of Divorce Decree and 3301 (d) Counter-Affidavit upon th person(s) and in the manner indicated below, which service satisfies the require rr ents of the Pennsylvania Rules of Civil Procedure: Service by First Class Mail Addressed as Follows: David M. Crawford 10001 Coors ByPass Blvd. Apt. 2124 Albuquerque, NM 87114 _, ESQUIRE tion No 32112) Camp Hill, PA 17011 Email: dianera cliff comcast.net Phone: (717) 7.17-0100 Fax: (717) 975-10697 Counsel for Plaintiff, Adrienne D. Banko-Crawford Dated: Aril 9' 2008 C7 ?p ; 3s Q.i ADRIENNE D. BANKO-CRAWFORD Plaintiff V. DAVID M. CRAWFORD Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-1377 CIVIL TERM . IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE State of Sou Carolina County of Before me, the undersigned Notary Public, personally appeared Adrienne D. Banko-Crawford, Plaintiff in the above entitled case, who being duly sworn or affirmed according to law, deposes and says that the Defendant or respondent above named is not in the military service of the United States of America, that she has personal knowledge that the said Defendant or Respondent is: 1. Now residing at 10001 Coors By Pass Blvd., Apt. 2124, Albuquerque, NM 87114. 2. Employed but employer is unknown. Sworn to and subscribed before me this 2 day cr f i , 204 NOTARY PUBLIC li4l& c &,", - 1-0? Adrienne D. Banko-Crawford F? ZZ w r' f.? t i ADRIENNE D. BANKO-CRAWFORD Plaintiff IN THE COURT OF CUMBERLAND COL MON PLEAS OF , PENNSYLVANIA V. DAVID M. CRAWFORD Defendant TO THE PROTHONOTARY: NO. 08-1377 CIVIL : IN DIVORCE PRAECIPE OF TRANSMIT RECORD Transmit the record, together with the following information, to the court f 1. GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. DATE OF FILING AND MANNER OF SERVICE OF THE COMPLAINT: a. Date of Filing of Complaint: March 3, 2008 b. Manner of Service of Complaint: Certified Mail/Restricted C. Date of Service of Complaint: March 10, 2008 for entry of a divorce decree: 3. DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTIC CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT U a. Date of Execution: 2/27/2008 b. Date of Filing: 3/3/2008 C. Date of Service: 3/10/2008 4. RELATED CLAIMS PENDING: No issues have been raised in this case, and there are no issues outsta 3301(D) OF THE DIVORCE )N THE DEFENDANT: 5. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE NTERED UNDER SECTION 3301(D)(1)(1) OF THE DIVORCE CODE: a. Date of Service: April 9, 2008 b. Manner of Service: First Class M it DIANE G. RADrLIFF, Camp Hill, PA 17011 Supreme Court ID # 321 2 Phone: (717) 737-0100 f DIANE G. RADCLIFF, ESQUIRE 3448 Trindle Road, Camp Hill, PA 17011 Phone: 717-737-0100 Fax: 717-975-0697 E-mail: dianeradcliff@comcast.net r(LE COPY April 9, 2008 David M. Crawford 10001 Coors ByPass Blvd. Apt. 2124 Albuquerque, NM 87114 Re: Adrienne D. Banko-Crawford vs. David M. Crawford Cumberland County Divorce No. 08-1377 Dear Mr. Crawford: I am enclosing with this letter a revised Notice of Intention to Request Entry of 3301(d) Divorce Decree and Counter-Affidavit under Section 3301(d) pertaining to the above referenced divorce action. Please note that if you do not file an answer to the divorce complaint or counter-affidavit by April 30, 2008, a divorce decree wi l be entered by the Court. Very truly yours, DIANE G. RADCLIFF, ESQUIRE DGR/dr Enclosure: Revised Notice of Intent Counter-Affidavit Transmission to Addressee by Mail cc: File No. 27-08-D-LS ADRIENNE D. BANKO-CRAWFORD Plaintiff ; V. DAVID M. CRAWFORD Defendant OTIC TO: DAVID M. CRAWFORD, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-1377 CIVIL TERM IN DIVORCE _ENTRY OF 3301 d) DI REE You have been sued in an action for divorce. You have failed to an wer the complaint or file a counter-affidavit to the 3301(d) affidavit. Therefore, on or after April 30, 2008, 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. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for E do so by the above date or the court may grant the divorce and you will lc for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH TH COURT IS ATTACHED TO THIS NOTICE. The filing of the form counter-affid? your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS 0 WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFC THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABO OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR I Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249-3166 DIANE G. RA CLIFF, ESQUIRE 3448 Trindle Road Camp Hill, PA 17011 Supreme Court ID # 32112 Attorney for Plaintiff onomic relief, you must forever the right to ask PROTHONOTARY OF THE it alone does not protect F YOU DO NOT HAVE A =FICE CAN PROVIDE YOU RD TO HIRE A LAWYER, 1T AGENCIES THAT MAY 10 FEE. ADRIENNE D. BANKO-CRAWFORD IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08-1377 CIVIL TERM DAVID M. CRAWFORD IN DIVORCE Defendant UNTER- 1. Check either (a) or (b): [ ] (a) I do not oppose the entry of a divorce decree. [ ] (b) I oppose the entry of a divorce decree because Check (i ), (ii) or both: [ ] (i) The parties to this action have not lived separ of at least two years. [ ] (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): [ ] (a) I do not wish to make any claims for economic relief lose rights concerning alimony, division of property, if I do not claim them before a divorce is granted. [ ] (b) I wish to claim economic relief which may include alirr lawyer's fees or expenses or other important rights. ate and apart for a period I understand that I may .awyer's fees or expenses , division of property, I understand that in addition to checking (b) above, I must also file 11 of my economic claims with the Prothonotary in writing and serve them on the other party. If I fa I to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-affidavit are true nd correct. I understand that false statements herein are made subject to the penalties of 18 Pa. S. Section 4904 relating to unsworn falsification to authorities. Date: David M. Crawford, Defen t NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE D CREE AND YOU DO NOT WISH ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS ?OUNTER-AFFI DAVIT. cam, ? c,D.. 'OFF C tl,,,+?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS DAVID A. CRAWFORD, Defendant No. n-i 77 (,TVTT, TRRM DECREE IN DIVORCE AND NOW, 13 ,2_0_0Z_, IT IS ORDERED AND DECREED THAT ADRIENNE D. BANKO-CRAWFORD , PLAINTIFF, AND DAVID A. CRAWFORD ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; issues have been raised in this case, and no issues are,outstanding. - Al?w ?x /7 y`° -1' Ik°.