HomeMy WebLinkAbout08-3886GEOFFREY W. KRAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2008.3 CIVIL TERM
WENDY J. KRAMER,
Defendant. IN DIVORCE
NOTICE
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 in 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, Carlisle, Pennsylvania 17013.
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 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas 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 our office. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing.
GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 3M CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301(C) AND -D OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Geoffrey W. Kramer, by and through his attorneys, Irwin,
& McKnight, and files this Complaint in Divorce against the Defendant, Wendy J. Kramer,
representing as follows:
1. The Plaintiff is Geoffrey W. Kramer, an adult individual residing at 202 Forge
Road, Boiling Springs, Cumberland County, Pennsylvania 17007.
2. The Defendant is Wendy J. Kramer, an adult individual currently residing at 163
"D" Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff and Defendant have been residents of the Commonwealth of
Pennsylvania at least six months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on June 10, 1978, in Philadelphia,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
By:
Respectfully submitted,
IRWIN & McKNIGHT
Marcus k. McKnig"I, Esquire
SupremekC-ourt I.D. No. 25476
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Date: June 30, 2008
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
GEOFFREY W. KRAMER
Date: June 30, 2008
GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 -3 M CIVIL TERM
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
GIEOFFR.Ei(W. KRAMER
Date: June 30, 2008
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GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 - 38t6CIVIL TERM
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file a counter-
affidavit within twenty (20) days after this affidavit has been served on you or the statements will
be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1.
The parties to this action separated on or about April 15, 2005, and have continued to live
separate and apart for a period of at least two years.
The marriage is irretrievably broken.
2.
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. of 4904 relating to
unworn falsification to authorities.
Date: June 30, 2008
GE FFRE W. KRAMER
Plaintiff
GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 -CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF 3301(d) DIVORCE DECREE
To: WENDY J. KRAMER
You have been sued in an action for divorce. You have failed to answer the Complaint or file a
Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after July 21, 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 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 economic claims.
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. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE
A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
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GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 -3ff(-CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
To: WENDY J. KRAMER
GEOFFREY W. KRAMER intends to file with the Court the attached Praecipe to
Transmit Record on or after July 21, 2008, requesting that a final Decree in Divorce be entered.
IRWIN & McXNIGHT
By: 0,,-' - U 0
Marcus At McKnigh l
60 West mfret Get
Carlisle, ylvania 170
(717) 249- 353
At rnev for Plainti
Date: June 30, 2008
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GEOFFREY W. KRAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2008 -3886 CIVIL TERM
WENDY J. KRAMER., ,
Defendant. IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA RCP RULE NO 1920A (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: SS:
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the
defendant, Wendy J. Kramer, on July 1, 2008, by certified, restricted delivery mail, addressed to
her at 164 "D" Street, Carlisle, Pennsylvania 17013, with Return Receipt Number 7006 0810
0000 7875 5590.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of,,18 Pa. C. S. Section 4904, relating to
unsworn falsification to authorities. // _
Date: July 3, 2008
3 A. M!RNf6flPV?Ift, ESQUIRE
for Plaintiff \\
On this, the 3rd of July 2008, before me, the undersigned officer, onally appeared Marcus A.
McKnight, III, Esq., known to me to be the person whose name is subscribed to the above instrument and
acknowledge that he executed same for the purposes therefco
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GEOFFREY W. KRAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2008 - 3886 CIVIL TERM
WENDY J. KRAMER,
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 Section 3301(c) and or (d) of the Divorce Code.
2. Date and manner of service of Complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Wendy J. Kramer, on or about July 1, 2008, by certified, restricted delivery mail, addressed to her at 163 "D"
Street, Carlisle, Pennsylvania, 17013, with Return Receipt Number 7006 0810 0000 7875 5590.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by plaintiff: ; by defendant:
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
June 30, 2008.
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: Filed on June 30, 2008
and served on July 1, 2008.
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 time-stamped copy of the Notice of Intention to file Praecipe to Transmit Record was served upon the defendant, Wendy
J. Kramer, on or about July 1, 2008, by certified, restricted delivery mail, addressed to her at 163 "D" Street, Carlisle,
Pennsylvania, 17013, with Return Receipt Number 7006 0810 0000 7875 5590.
(b)
Date plaintiffs Waiver of Notice in Section 3301(c)
Prothonotary:
Date: July 21, 2008
Date defendant's Waiver of Notice in Section 3301(c
the Prothonotary:
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GEOFFREY W. KRAMER
V.
WENDY J. KRAMER
AND NOW, this
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
08-3886 CIVIL TERM
ORDER OF COURT
day of July, 2008, the request for the entry of a
Divorce Decree, IS DENIED AT THIS TIME.'
VMarcus A. McKnight, III, Esquire
/For Plaintiff
? Wendy J. Kramer
163 "D" Street
Carlisle, PA 17013
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' Pa. Rule of Civil Procedure 1920.72(d) requires that a Section 3301(d) affidavit
notify the other party to file a counter-affidavit within twenty (20) days of service,
or the statements in the affidavit will be admitted. Rule 1920.73, providing for a
notice of intention to request the entry of a Section 3301(d) divorce decree,
requires that it include a statement that, "You have failed to ... file a counter-
affidavit to the § 3301(d) affidavit. Therefore, on or after (a date), the other party
can request the court to enter a final decree in divorce." (Emphasis added.)
Here, the complaint, the Section 3301(d) affidavit and the notice of intention to
request the entry of a Section 3301(d) divorce decree were all served on
defendant on the same date, July 1, 2008. Because defendant has twenty days
from service of the Section 3301(d) affidavit to file a counter-affidavit, defendant
cannot be notified on the same day it is served that there has been a failure to
file a counter-affidavit.
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GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAME11,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 -3°86 CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF 33010 DIVORCE DECREE
To: WENDY J. KRAMER
You have been sued in an action for divorce. You have failed to answer the Complaint or file a
Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after July 21, 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 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 economic claims.
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. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE
A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
s %
GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 -30b CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
To: WENDY J. KRAMER
GEOFFREY W. KRAMER intends to file with the Court the attached Praecipe to
Transmit Record on or after July 21, 2008, requesting that a final Decree in Divorce be entered.
IRWIN & IGHT
By:
Marcus . MclCnigh I ,Esquire
60 Wes Pomfret Street
Carlisl , Pennsylvania 17013
(717) 2 9-2353
ttornev for Plaintiff
Date: July 24, 2008
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GEOFFREY W. KRAMER,
Plaintiff,
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008,3& CIVIL TERM
WENDY J. KRAMER,
Defendant.
IN DIVORCE
COUNTER-AFFIDAVIT
UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
X (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 separate and
apart for a period of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) I do not with to make any claims for economic relief. 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.
X (b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the Prothonotary in writing and serve them on the other party. If I fail 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 and correct. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section
4904 relating to unsworn falsification to authorities.
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WENDY J. ER
Defendant
Date: / '.-? `7( dj>
NOTICE
IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND
YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU
SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
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GEOFFREY W. KRAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
2008 - 3886 CIVIL TERM
WENDY J. KRAMER,
Defendant. IN DIVORCE
To the Prothonotary:
PRAECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information, to the court for entry of a divorce decree:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code.
2. Date and manner of service of Complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Wendy J. Kramer, on or about July 1, 2008, by certified, restricted delivery mail, addressed to her at 163 "D"
Street, Carlisle, Pennsylvania, 17013, with Return Receipt Number 7006 0810 0000 7875 5590.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by plaintiff: ; by defendant:
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
June 30, 2008.
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: Filed on June 30, 2008
and served on July 1, 2008.
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 time-stamped copy of the Notice of Intention to file Praecipe to Transmit Record was mailed to the defendant, Wendy J.
Kramer, on or about July 26, 2008, by certified, restricted delivery mail, addressed to her at 163 "D" Street, Carlisle,
Pennsylvania, 17013, with Return Receipt Number 7006 0810 0000 7875 5545.
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
Date defendant's Waiver of Notice in Section 3301(/ Divorce was filed with the Prothonotary:
McKnight, III, Esquire
K Plaintiff
Date: August 1, 2008
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GEOFFREY W. KRAMER
V.
WENDY J. KRAMER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
08-3886 CIVIL TERM
ORDER OF COURT
AND NOW, this day of August, 2008, the request for the entry
of a Divorce Decree, IS DENIED AT THIS TIME.'
Edgar B. Myley, J.
' Pa. Rule of Civil Procedure 1920.42(d)(1) provides that a notice of intention to
request entry of divorce decree must be mailed or delivered to the party "at le
twenty days prior to the date of the filing of the praecipe to transmit the record."
Therefore, the form of the notice set forth in Rule 1920.73 must include a date in
which plaintiff intends to file a praecipe to transmit the record which is at least
twenty days forward from the date the notice is sent. Plaintiff sent a Section
3301(d) notice to defendant on July 24, 2008, with a statement that he "intends to
file with the Court the attached Praecipe to Transmit Record on or after July 21,
2008, requesting that a final Decree in Divorce be entered." Defendant filed a
counter-affidavit dated July 24, 2008, in which she did not oppose the entry of a
decree in divorce but checked subsection (b) which stated: "I wish to claim
economic relief which may include alimony, division of property, lawyer's fees or
expenses or other important rights." The counter-affidavit contained the following
language:
I understand that in addition to checking (b) above, I must also file
all of my economic claims with the Prothonotary in writing and
serve them on the other party. If I fail 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.
(Emphasis added.)
Because the date set forth in the notice of intention to request divorce
decree had already passed before the notice was even sent, defendant did all
she was told she could do to protect her interest which was to state in the
counter-affidavit that she sought economic relief. That, however, is not enough
to pursue an economic claim. Plaintiff must now send a proper notice of intention
to request divorce decree with will allow defendant, if she wishes, not only to file
a counter-affidavit seeking economic relief, but also, within a twenty day period of
the date of the notice, file an economic claim of record which is necessary to
protect her right to seek economic relief.
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,Marcus A. McKnight, III, Esquire
For Plaintiff
,Wendy J. Kramer
163 "D" Street
Carlisle, PA 17013
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GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 - 3886 CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF 3301(d) DIVORCE DECREE
To: WENDY J. KRAMER
You have been sued in an action for divorce. You have failed to answer the Complaint or file a
Counter-Affidavit to the Section 3301(d) affidavit. Therefore, on or after August 25, 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 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 economic claims.
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. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORT TO HIRE
A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2008 - 3886 CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO REQUEST
ENTRY OF DIVORCE DECREE
To: WENDY J. KRAMER
GEOFFREY W. KRAMER intends to file with the Court the attached Praecipe to
Transmit Record on or after August 25, 2008, requesting that a final Decree in Divorce be
entered.
By:
IRWIN & McKNIGHT
(rcus A. cKnight, III, Esquire
West Pom et Street
lisle, Pe svlvania 17013
49-2353
Attorney for Plaintiff
Date: August 5, 2008
GEOFFREY W. KRAMER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
2008 - 3886 CIVIL TERM
WENDY J. KRAMER,
Defendant. IN DIVORCE
To the Prothonotary:
PRAECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information, to the court for entry of a divorce decree:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code.
2. Date and manner of service of Complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Wendy J. Kramer, on or about July 1, 2008, by certified, restricted delivery mail, addressed to her at 163 "D"
Street, Carlisle, Pennsylvania, 17013, with Return Receipt Number 7006 0810 0000 7875 5590.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by plaintiff: ; by defendant:
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
June 30, 2008.
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: Filed on June 30, 2008
and served on July 1, 2008.
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 time-stamped copy of the Notice of Intention to file Praecipe to Transmit Record was mailed to the defendant, Wendy J.
Kramer, on August 4, 2008, by certified, restricted delivery mail, addressed to her at 163 "D" Street, Carlisle,
Pennsylvania, 17013, with Return Receipt Number 7006 0810 0000 7875 6535.
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
Date defendant's Waiver of Notice in Section 3301(c) vorc as filed 'th the Prothonotary:
Mar s cKnight, wire
Atto ey for Plaintiff
Date: August 26, 2008
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GEOFFREY W. KRAMER,
Plaintiff,
V.
WENDY J. KRAMER,
Defendant.
CIVIL ACTION - LAW
2008 - 3886 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
PURSUANT TO PA. R.C.P. RULE NO 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
. SS:
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That the Notice of Intention to file Praecipe to Transmit Record filed on August 5,
2008 was served upon the defendant, Wendy J. Kramer, on August 6, 2008, by certified,
restricted delivery mail, addressed to her at 163 "D" Street, Carlisle, Pennsylvania 17013, with
Return Receipt Number 7006 0810 0000 7875 6535.
3. That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to
unsworn falsification to authorities.
Date: August 26, 2008
MARCUS A. c IGHT, III, ESQUIRE
Attorney for tiff
On this, the ?f August 2008, before me, the undersigned officer, personally appeared
Marcus A. McKnight, III, Esq., known to me to be the person whose name is subscribed to the above
instrument and acknowledge that he executed same for the p os t rei contained.
COMMONWEALTH OF PENNSYLVANIA
NotarYai Seal
Martha L Noel, Notary Public No ry Public
Cadide Boro, Cumberland County
My Commission E*m Sept. 18, 2011
Member. Pt
: IN THE COURT OF COMMON PLEAS OF
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1. Article Addressed to:
INSWEWJ11RM=
163 "D" SYIREET
CARLISLE PA 17013
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PS Form 38111 February 2004 Oernaallc no" f AOW t ozss-W-nn.t sac
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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Aft all
STATE OF PENNA.
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GEOFFREY W. KRAMER.
PLAINTIFF
VERSUS
WENDY J. KRAMER,
DEFENDANT
N O. 2008 - 3886 CIVIL TERM
DECREE IN
DIVORCE
AND NOW, Qpjla? it ','-;?f
IT IS ORDERED AND
DECREED THAT GEOFFREY W. KRAMER
AND
WENDY J. KRAMER
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
,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; WAQ,
The Marriage Settlement Agreement dated April 23, 2007, and signed by the
rties is hereby incorporated into this Divorce Decree, but not merged.
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