Loading...
HomeMy WebLinkAbout08-1508JUSTIN L. CROZIER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW HEATHER L. CROZIER, NO. 6S ~ f S-6 & CIVIL TERM 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. 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 REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 JUSTIN L. CROZIER, Plaintiff V. HEATHER L. CROZIER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. ?' 1S CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT I . Plaintiff is Justin L. Crozier, an adult individual currently residing at 400 Shed Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Heather L,. Crozier, an adult individual currently residing at 25 Briarwood Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 6, 2007 in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 7. Plaintiff and Defendant are citizens of the United States of America. r The parties' marriage is irretrievably broken. 9. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, caEsfuire Hannah Herman-Snyder, Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: STIN L. &OZIE , Plaintiff i? w -IQ (xi w W l.i C 'v t:a a' N ? ca -n { ?? orn CONSTANCE M. VAN METER, Plaintiff V. MELVIN V. VAN METER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2008-1508 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I confirm that I did this day of _hAh,WkA?-. , 2008, hand deliver a true and attested copy of a Complaint in Divorce, filed March 6, 2008, to Melvin V. Van Meter, at the following address: V A--I ?A ?. 4o u' Sworn and subscribe to before me this = day of _ IlAtCA., , 2008. ry P is NOVAK ow LAft J40 S. lli? 4 IA?Ff= JUSTIN L. CROZIER V. Plaintiff HEATHER L. CROZIER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-1508 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE 1, Hannah Herman-Snyder, Esquire, counsel of record for Plaintiff, state that a true and attested copy of a Complaint in Divorce was sent to Defendant, Heather Crozier, at her address of 507 Factory Street, Carlisle, Pennsylvania, by certified mail, restricted delivery. A copy of said receipt is attached hereto indicating service was made on April 4, 2008. Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this day of r i r , 2008 ??Od?., ? ?u A n, f NOTAR'?PUBLIC NO'I AK an ourl"= NAME f? oNCw?a??w? ?r coon ?M ? ?. !11! N ?? . ?.... _?? .? MMI? ?? ? .? Y U.S. Postal Service, , CERTIFIED I`lllIl;AIL T,, RECEIPT Q (Domestic I In swance Coverage Provided) ^u Ln Postage V $ i? Certified Fee Return Receipt Fee d `"?bstmartq ^' y Here t to t 4? ) (Endorsement Require • Restricted Delivery Fee <i (Endorsement Required) r1i rni Total Postage & Fees O Sent To ?F.z1t? j(- Street, Apt N ?? or POBozNo . . )l I S41 tf ?Cfc _ Crty, State, Z1P+4 ? t I S l ? -- --------- , f ? 1 ?' ,J 3800 ALIgUst rl ¦ Compkft he?1, 2, mild S. 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: Nedker L, SO`I I ac+Dry slarm PA 1-7013 by (Printed ? Agent ' D. Is dellmy address di ferent frown item 12' Yee if YEs, enter delivery address below: ? No 3: Servies Type QM Celled Mull 0 Bpees Mail ? Regbtered ?Redam Receipt for Merchandise f] insured Maii C.O.D. 4. Restricted Dellvery7 (Extra Fee) >VYes 2. AraaeNumber 7007 0220 0002 2526 5820 Ps Form 3811, August 2001 Domestic Retwn Recalpt 102585-02-W154o ? y Fri ? n _ JUSTIN L. CROZIER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW HEATHER L. CROZIER, NO. 08-1508 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 6, 2008 and served on April 4, 2008, as indicated in Affidavit of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 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 FOREGOING 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: _t77-0-3-16Y JUS . CR C? rv w 1 JUSTIN L. CROZIER, Plaintiff vs. HEATHER L. CROZIER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. 08-1508 CIVIL TERM : IN DIVORCE WAIVER OF "`SOT CE-OF INTEN" ION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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: '7- 3- STIN L. ROZIE rv O - rn JUSTIN L. CROZIER, Plaintiff VS. HEATHER L. CROZIER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-1508 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 2. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on March 6, 2008 and served on April 4, 2008, as indicated in Affidavit of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the 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 FOREGOING 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: A P/a HEATHER L. CROZIEiK r IT c..3 ?._. 77 JUSTIN L. CROZIER, Plaintiff vs. HEATHER L. CROZIER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 08-1508 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in 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 THE FOREGOING 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: T '1/ail HEATHER L. CROZIER C: -: ? _,.f .._,__ ?. T ? ^ ^ - 4.? ? , ? ?'? G? ? ...,. " ?,? .. ... .. __... k? { JUSTIN L. CROZIER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION -LAW HEATHER L. CROZIER, NO. 08-1508 CIVIL TERM 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(c) 3301(d)(1) of the Diver-ee Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on April 4, 2008. 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: July 3, 2008 by Defendant: July 27, 2008 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 10, 2008 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 30, 2008 Hannah Herman-Snyder, Esqui GRIFFIE & ASSOCIATES Attorney for Plaintiff e .? ? ?? . y_, T ,^t ? a j ? T- t - _ _ ....,.. 1 f I . C,.7 f- . C..) .. ?,? '-C" ? °? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Justin L. Crozier Plaintiff NO. 2008-1 508 VERSUS Heather L. Crozier, Defendant DECREE IN DIVORCE AND NOW, , - IT IS ORDERED AND DECREED THAT Justin L. Crozier , PLAINTIFF, AND Heather L. Crozier 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; Nnnc r?? ? -'S I? ?ry7 {p:,s.?i -yyfgr?/ 7 v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA us"v? L C,zouew Plaintiff Vs File No. e3RC-d IN DIVORCE C 4,0 ?'-Z se ff Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, n or L-/after the entry of a Final Decree in Divorce dated A u oU , hereby elects to resume the prior surname of 1qe4zqA`& d gives this written notice avowing his / her intention pursuant to the rovisions of 54 P.S. 704. Date: ? 3 ^ ?-'? ignature Signature of name being resumed COMMO LTH OF PENNSYLVANIA ) ?o4aer S?cS` COUNTY OF a On the 3 -'0-' day of o , 200J[, 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. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ay ?m s Notary Pu li BONNIE L COYLL NOTARY PURK Co. PA W CO owwCTOW 17. 20 0 _V^ n ) r? CV l r ?r