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HomeMy WebLinkAbout08-22316- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NADINE A. CRAVER, Plaintiff, V. : CIVIL ACTION - LAW : IN DIVORCE KEVIN C. CRAVER, Defendant : NO. 131 C cry 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 indignitites 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 Court House, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 0 AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimoni, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NADINE A. CRAVER, Plaintiff, V. : CIVIL ACTION - LAW : IN DIVORCE KEVIN C. CRAVER, Defendant : NO. ©?' a 3 ui COMPLAINT COUNTI SECTION 3301(c) OF THE DIVORCE CODE OF 1980 1. Plaintiff is Nadine A. Craver, an adult individual who currently resides at 1781 North Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Kevin C. Craver, an adult individual who currently resides at 131 Reeser Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 7, 1998, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties hereto. 6. Plaintiff avers that Defendant is not in any branch of the Armed Services. 7. This action is not collusive. 8. The marriage is irretreivably broken. 1 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. COUNT II SECTION 3301(d) OF THE DIVORCE CODE OF 1980 10. Paragraphs one through nine of this Complaint are incorporated herein by reference as though set forth in full. 11. The parties are now living separate and apart; at the appropriate time Plaintiff will submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretreivably broken. WHEREFORE, Plaintiff request your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. Respectfully submitted: Date: BRATIC & PORTKO By:'?a p a-j-- kAQr- Stephen K. Portko, Esquire 101 South U.S. Route 15 Dillsburg, PA 17019 (717) 432-9706 I.D. No. 34538 Attorney for Plaintiff VERIFICATION I, Nadine A. Craver, hereby acknowledge that I am Plaintiff in the foregoing Divorce Complaint, that I have read the foregoing, and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: °T _, / - 0 Nadi Craver a W IIIVVV??I f-'N N CX3 ril , c , - LV ,1n V C? W "A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NADINE A. CRAVER, Plaintiff, V. KEVIN C. CRAVER, Defendant : CIVIL ACTION - LAW : IN DIVORCE : NO. 08-2231 CIVIL ACCEPTANCE OF SERVICE I accept service of Plaintiffs Complaint in Divorce filed in the above matter. Dated: - 0 r Ke . raver, Defendant e , // (Mailing Address) ?J ?. R a c^F rY? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NADINE A. CRAVER, Plaintiff, V. : CIVIL ACTION - LAW : IN DIVORCE KEVIN C. CRAVER, Defendant : NO. 08-2231 CIVIL AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 8, 2008. 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 this affidavit 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 falsification to authorities. a- ?c t ?2 Dated: 7-0n--d NAne A.. Craver 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. 1 understand that I may lose rights concerning alimony, division of property, lawyers 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 this affidavit 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 falsification to authorities. Dated: L41e??X? 1? - J'4? Na a A. Craver, Plaintiff ? 4? ?..7 t ? , --' ? i ., 4_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NADINE A. CRAVER, Plaintiff, V. : CIVIL ACTION - LAW : IN DIVORCE KEVIN C. CRAVER, . Defendant : NO. 08-2231 CIVIL AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 8, 2008. 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 this affidavit are true and correct. I understand that false statements herein are PROde subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworr, Is" i ti n to authorities. Dated: 7 S bC 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. 1 understand that I may lose rights concerning alimony, division of property, lawyers 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 this affidavit are true and correct. I understand that false statements herein are e j t to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn f is io o uthorities. Dated: 7 ?-? 6& n TN . x IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nadine A. Craver Plaintiff Vs File No. 08-2231 Civil IN DIVORCE Kevin C. Craver _ Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x'] 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 ym and gives this written notice avowing his / her intention pursuant to the provisions o f,54 P.S. 704. Date: 7" o?Jf' D ignature 9 1 Jm- ?- - e of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF Y.aC On the 222' 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. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal, z?/? COMMONWEALTH OF PENNSYLVANIA Notarial Seal Notary Public Ronnetta S. Rider, Notary Pubic Dilisburg Boro, York County MY Conxnission Expires Feb. i2, 2009 Member, Pennsylvania Association of Notaries ?? ==??s t? 1 ,t --? _ ?.? ? r. G"3 c ? ,..... ?.t =' =.j ?,., '6" NADINE A. CRAVER, Plaintiff, V. KEVIN C. CRAVER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : NO. 08-2231 CIVIL PRAECIPE TO TRANSMIT RECORD 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 19, 2008 acceptance of service signed by Defendant; 3. Complete either (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff on July 25, 2008; by the Defendant on July 25, 2008; (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: n/a (b)(2) Date of service of the Plaintiffs affidavit upon the Defendant: n/a 4. Related claims pending: Neither party has raised any claims or other related issues. 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: n/a (b) Date of plaintiffs Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: July 29, 2008 Date of defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothontary: July 29, 2008. .4? Attor ey for Plaintiff r+? ?. >> ? Li:: a ^-6 _.. "`? . i? -t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY a STATE OF PENNA. NADINE A. CRAVER, Plaintiff VERSUS KEVIN C. CRAVER, Defendant N O. 08-2231 CIVIL DECREE IN DIVORCE AND NOW, DECREED THAT NADINE A. GRAVER AND KEVIN C. GRAVER , IT IS ORDERED AND , PLAINTIFF, 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; 'I-'ROTHONOTARY r ? t•