The URL can be used to link to this page

Home My WebLink About08-2161RICHARD L. RUSSELL, JR. Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - -7- I1- / CIVIL TERM 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 are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 (717) 249-3166 4 RICHARD L. RUSSELL, JR. Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - z /4! CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Richard L. Russell, Jr. an adult individual who resides at 52 Monarch Drive Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Crystal R. Russell, an adult individual who resides at 52 Monarch Drive, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 13, 2005, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The 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, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since January 15, 2008, and continue to live separate and apart as of the date of this Divorce Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. b Q? Date Respectfully Submitted, TURO LAW OFFICES glen R. Walt?f 28 South Pitt Stree Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION correct Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Richard ssell, Jr. I verify that the statements made in the foregoing Divorce Complaint are true and . I understand that false statements herein made are subject to the penalties of CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Complaint in Divorce, by certified, return receipt requested, postage pre-paid and depositing same in the United States Mail, first class, postage pre-paid on the _0Q 11 day of 2008, from Carlisle, Pennsylvania, addressed as follows: Crystal R. Russell 52 Monarch Drive Carlisle, PA 17015 TURO LAW OFFICES en R. Waltz, Esqui 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 a ? ? ? ? ?' r - ? ??? Nil V,, ? ` V 4::j j_ t °? ? -c (,r RICHARD L. RUSSELL, JR. Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 2161 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE C,t ¦ Cw0M* tome 1, 2 and 9. Also Complete item 4 N ResbiCbs!d : ivory on s Paint your Warne the revem you. d to a that we r Vrc?r f Mich this cod to the back of the meJipiece, or on the front If spttoe permits. 1. Mile Addressed to: 4 gStaJ tL e I I 5a 'Bona rah 'br v t Car I t 51e , Pa, 1-7D15 A. 3lgrahrs • 'A Q;? 0 Agent X C B. ReAnd by (Prided Name) C. Date of Deklwy C.r,64C, I KISS-` U Y- S- Y D. is dk,.y addr.w dfm0 from item l? ? Yes if YES, enter delivery addreea below: ? No 30 Ty" VW Man O Exp Mail ? Registered ? Retum Remit for M.rctmrri/1. E3 immw ma ? C.O.D. 4. RestrkW DeNvery? (Extra Fee) ? Yes 2. MtldsNtgr er (>trrahrth `ssivke/ 7006 0100 0007 1051 8330 PS Form 9811, Fetxtmty 2W De mmft ftown m - ipR ,oases oz M t 1 'xl 1 l r f y, f^- 8 fl "'f RICHARD L. RUSSELL, JR. Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08 - 2161 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 4, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in 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. 78"TwNzo$ Date Richar ell, Jr. a C7 RICHARD L. RUSSELL, JR Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 2161 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 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 fees or expenses if I 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. 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. Z??UU?e?3 Date Richard L ell, Jr. r? ° . cc? ? " ? t`t't rr= ?%.: ? ?.?. ? ... ?C , ? ? ? °?? RICHARD L. RUSSELL, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 2161 CIVIL TERM CRYSTAL R. RUSSELL : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 4, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in 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. -?--3 - s" Date C tal R. Russell gn {?`> s t' RICHARD L. RUSSELL, JR Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 2161 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 fees or expenses if I 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. 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. &Ow/ &"Jj -3- Date C stal R. Russell m QC- 5- C. RICHARD L. RUSSELL, JR. Plaintiff V. CRYSTAL R. RUSSELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 2161 CIVIL TERM 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: Certified, Returned Receipt mail delivered on or about April 5, 2008. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. By Plaintiff: June 28, 2008 By Defendant: July 3, 2008 4. Related claims pending: None. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: July 11, 2008 By Defendant: July 11, 2008 Gy96n R. Waltz, Esc Attorney for Plaintiff ? ? C?`d -t7 ? ?,- ?' f ?. ?f, _t:. .._. -?? , .. ?? ?. ,? -r, Cam ?U ...? , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Richard L. Russell, Jr. Plaintiff No. 08-21 61 VERSUS Crystal R. Russell Defendant DECREE IN DIVORCE AND NOW, Y ??r 2008 , IT IS ORDERED AND Richard L. Russell Jr. DECREED THAT ? PLAINTIFF, AND Crystal R. Russell 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; ROTHONOTARY x* IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA , ?uSSf hc,r-A " SC . Plaintiff Vs File No. ? ? IN DIVORCE sS { l S4 eu - Defendant • ;,? - f_. -V CTS ?p cn 01 NOTICE TO RESUME PRIOR SURNAME r . I a - C- Z Notice is hereby given that the Plaintiff / defendant in the above m atter,` c.n [select one by marking "x"] 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 6 etc k-e r , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: Signature ?4;u1?.Q1i ignature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 0,L4- A On the k5 day of_ =C'f 2011 , 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. IJI')4 ?CQ Q . ?? ? Prothonotary or Notary Public a? ? lI.?DPd rr,owriw,?w? Cash ?. MI?.?Ib io N?irw?ierl