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Home My WebLink About08-5267MICHELE MORROW, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW CRAIG A. MORROW, SR., : NO. b8' Sa&17 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. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 MICHELE MORROW, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW CRAIG A. MORROW, SR., NO. CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Michele Morrow, an adult individual currently residing at 106 Grant Street, Enola, Cumberland County, Pennsylvania. 2. Defendant is Craig A. Morrow, Sr. an adult individual currently residing at 106 Grant Street, Enola, 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 June 26, 2003, in Dauphin County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. 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. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing 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, Wendy J. F. Cn Attorney for P1 P.O. Box 4302 Harrisburg, PA 17111 (717) 576-0549 Fax (717) 558-8439 " , ! 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 unworn falsifications to authorities. DATE: MICHELE MORRO , Plaintiff n CO ?c 4 MICHELE MORROW, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW CRAIG A. MORROW, SR., : NO. 08-5267 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this day of September, 2008, comes Wendy J. F. Grella, Esquire, counsel of record for Plaintiff, Michele Morrow, and states that a copy of the Complaint in Divorce was forwarded to Craig Morrow, c/o Bureau of Vehicle Management, 2221 Forster Street, Harrisburg, Pennsylvania 17125, by certified mail, return receipt requested. A copy of said receipt is attached hereto indicating that service was made on September 5, 2008. Wendy J. F. Grell Attorney for Plai P.O. Box 4302 Harrisburg, PA 17111 (717) 576-0549 C3 Return Receipt Fee .20 C3 (Endorsement Required) ep C3 Restrk led Delivery Fee 0 (Endorsement Required) rl r?- Total Postage & Fees O .... - . 7orpoout Ift i A • Cow 40% Mallla 1. & and & AYo onnipi Nam 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ A flsch this card to the back of the mailpiece, or on the front if space permits. A. X B. ? AgwR 1. ArWe Addressed to: c rn1 /4? a C. Dete of D. Is delivery address different from item 19 ? Yes If YES, enter delivery address below: ? No 3. Service Type .f,?ertlfled Mali O E>pea mail 0 Registered Racelpt for Meoo WKb* I ? C.O.D. (Eicfra Feel 1341. 2. Article Number - (OWr.f.ftM- W roo 7007 0710 0001 3173 4562 ft Form 3811, FdxWy 2004 Dorneeft Rom. Flaosipt t , _ 1 Y I? 77, D CD MICHELE MORROW, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW CRAIG A. MORROW, SR., :NO. 08-5267 CIVIL TERM Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Craig A. Morrow, Sr., acknowledge that on September 5, 2008, I received a certified and true copy of a Complaint in Divorce in the above captioned action. Date: 9 ?S C Sworn and subscribed to befor me this ? day of , 2008. NOTARY PUBLIC Cam( ?i?ie/ Craig A. Morrow, Sr. c/o Bureau of Vehicle Management 2221 Forster Street Harrisburg, PA 17125 r?KATHERINE MONWEALTH OF PEivtv?? ,:?' : ,4 NOTARIAL SEAL M. NEOROOWa ota Cou??k,i quehanna Twp•, Commission Expires Oct?6, 20 CZ) . . . t l i \ . C-n ? r ?i MICHELE A. MORROW vs CRAIG A. MORROW, SR. In the Court of Common Pleas of Cumberland County, Pennsylvania No. 08-5267 Civil Term IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF SAID COURT: nter the appearance of MICHELE A. MORROW, Plaintiff, pro se. i? .yyrr eMr' ?? David D. Buell, Prothonotary Attorney Info: N/A • Plaintiff, pro se Michele A. Morrow 20 we Plaintiffs Pro 5e, 400 Pine Street West Reading, PA 19611 f-, ,may, (610) 374-3552 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs A a, Sr- Oro Defendant V 1 C? ? ? File No. ?O - 5Q &-7 IN DIVORCE • ?..?-mil II ,.? f =3SP.? I !!?W 16 CaS L NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that a Plaintiff defendant in the above matter, [select one by marking "x"] Z prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce ated , hereby elects to resume the prior surname of ives this P S76A. written not'ce av wing his / her intention pursuant to the prov' ' MW Date: J4 Signature Signature of name being resumed COMMONWE LTH OF PENNSYLVANIA ) COUNTY OF On the Lit6day of A ) yx?c n.?'i,.??, 20J, 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. Prothonotary or Notary Public MICHELE A. MORROW In the Court of Common Pleas of Cumberland County, Pennsylvania a$-5267 Civil Ter No. m IN DIVORCE vs CRAIG A. MORROW, SR. PRAECIPE '- --' TO THE PROTHONOTARY OF SAID COURT: On behalf of Plaintiff, Michele A. Morrow, please withdraw the above-captioned divorce action. David D. Bull, Prothonotary Attorney Info: Michele A. Morrow, pro se 20 Attorney or Plaintiff ` 221 Chester Road Enola, PA 17025