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HomeMy WebLinkAbout04-1364IN THE COURT OF COMMON PLEAS OF THE ~f,~JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Crane, Plaintiff 402 Herman Avenue, Apt. A Lemoyne, Pennsylvania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Ave., Apt. A Lemoyne, Pennsylvania17043 198-64-9366 CIVIL ACTION - LAW CASE NO. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court for divome. If you wish to defend against the claims set forth on the other side of this page, 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 this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or children. When the ground for divorce is indignities o~: 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 CUMBERLAND County Courthouse, in Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone( ) commencement of this action. 4. Plaintiff married Defendant on June 15, 2002 at Camp Hill, Cumberland County, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments. 6. There has been no pdor action of divorce or for annulment between the Marriage Certificate License No. I-15-0406 2002 (Duplicate) I, REVEREND LINDA HOST1ETTER hereby certify that on the 15TH day of JUNE, 2002 at CAMP HILL PA SHAWN PAUL CRANE and LEIGH SHANNA BENKO were by me united/n marriage, in accordance with License issued by the Clerk of the Orphans' Court Division of the Court of Common Pleas of Dauphin County, Pennsylvania. Certified l}om the record AUGUST 11, 2003 Clerk of the Orphav.s' Court Oivi~i~,, IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT oF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Crane, Plaintiff 402 Herman Avenue, Apt. A Lemoyne, Pennsylvania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Ave., Apt. A Lemoyne, Pennsylvania17043 198-64-9366 CIVIL ACTION - LAW CASE NO, IN DIVORCE TERM COMPLAINT UNDER SECTION 3301(c) OR 330'1(d) OF THE DIVORCE CODE 1. Plaintiff is Shawn Paul Crane who resides at; 402 Herman Avenue, Apt. A; Lemoyne, Pennsylvania 17043. 2. Defendant is Leigh Shanna Crane who resides at: 402 Herman Ave., Apt. A; Lemoyne, Pennsylvania 17043. 3. [] Plaintiff and/or [] Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on June 15, 2002 at Camp Hill, Cumberland County, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments. 6. There has been no prior action of divorce or for annulment between the parties. Complaint for Divorce; Page 1 7.The marriage is irretrievably broken. 8. After 90 days have elapsed from the date of filing of this Complaint, Plaintiff intends to file an affidavit consen~ng to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in mardage counseling. 10. There are no children born to or adopted by the parties to this marriage and none are expected. 11. There is no property or debt of the marriage. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between the Plaintiff and Defendant. Shawn Paul Crane I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unswom falsifica~~ Date: ~.~1 t'l~v-c)// ~.Ooc/ ./'-.,/~'--"~'~'~/b~ ~- _ _ ~/~ Shawn Paul Crane, Pro Per License No. I- 15-0406 2002 Marriage Certificate (Duplicate) REVEREND LINDA HOSTIETTER hereby certify that on the 15TH dayof JUNE, 2002 CAMP HILL PA SHAWN PAUL CRANE and LEIGH SHANNA BENKO were by me united in marriage, in accordance with License issued by the Clerk of the Orphans' Court Division of the Court of Common Pleas of Dauphin County, Pennsylvania. Certified fi.om the record AUGUST 11, 2003 Clerk of the Orphans' Court Division REVEREND L1NDA HOST1ETTER Officiant IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Crane, Plaintiff 402 Herman Avenue, Apt. A Lemoyne, Pennsylvania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Ave., Apt. A Lemoyne, Pennsylvania17043 198-64-9366 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM COUNSELING NOTICE RULE 1920.45(a)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301 (a)(6) Indignities Section 3301 (c) Irretrievable breakdown Mutual Consent Section 3301 (d) Irretrievable breakdown Two/Three year separation A list of qualified professions is available for inspection in the Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone( ) IN THE COURT Of COMMON PLEAS Of THE Of PENNSYLVANIA COUNTY CUMBERLAND ShawnPaul Cmne, Plaint~ 402 Herman Avenue, Apt. A Lemoyne, Penns~vania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Ave., Apt. A Lemoyne, Pennsylvania17043 198-64-9366 JUDICIAL DISTRICT CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM AFFIDAVIT OF NON-MILITARY SERVICE Shawn Paul Crane, being duly sworn according to Law, deposes and says that Plaintiff knows by Plaintiff's own personal knowledge and therefore avers that the defendant, Leigh Shanna Crane, is 27 years of age and that Defendant is not in the military service of the United States or its allies, or otherwise within the provision of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments and that the defendant is employed by none, not employed. rane, Plaintiff Sworn to and subscribed before me this the~I~%l day of NOTARIAL SEAL ¢ODY S SMITH, NOTARY PUBLIC Carlisle Boro, Cumberland County ;¢,y Commission Expires April 4, 2005 Notary Public IN THE COURT OF COMMON PLEAS OF THE""(-'/~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND ShawnPaul Cmne, Plaint~ 402 Herman Avenue, Apt. A Lemoyne, Penns~vania 17043 207-58-80O0 Leigh Shanna Crane, De~ndant 402 Herman Ave., Apt. A Lemoyne, PennsCvania17043 198-64-9366 CIVIL ACTION - LAW o¥-tzM CASE NO. IN DIVORCE TERM ACCEPTANCE OF SERVICE I, Leigh Shanna Crane, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divorce filed in the above-captioned matter. Date Le'igh Shanna Crane, defendant IN THE COURT Of COMMON PLEAS Of THE H'"' JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Cmne, Plaintif 402 Herman Avenue, Apt. A Lemoyne, Penns~vania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Ave., Apt. A Lemoyne, Pennsylvania17043 198-64-9366 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM AFFIDAVIT AS TO SIGNATURE Shawn Paul Crane, being duly sworn according to law, deposes and says that Shawn Paul Crane is the Plaintiff in the above-captioned divorce action; that Shawn Paul Crane is familiar with the signature of the Defendant; and that the signature on the Acceptance of Service attached hereto as Exhibit "A" is the signature of the Defendant, Leigh Shanna Crane.  Shawn Paul Crane, Plaintiff Sworn to and subscribed before me this the ,.~J day of Notary Public NOTARIAL SEAL CLAUDIA A. BREWBAKER, NOTARY PUBLIC Carlisle Boro, Cumberland County My Commission Expires April 4, 2005 IN THE COURT Of COMMON PLEAS OF THE"~'/'~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Crane, Plaintiff 402 Herman Avenue, Apt. A Lemoyne, Pennsylvania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Av~., Apt. A Lemoyne, Pennsylvania 17043 198-64-9366 CIVIL ACTION ~ LAW CASE NO. IN DIVORCE TERM AFFIDAVIT OF CONSENT on ~g~/~ 1. A complaint in Divorce under 3B01(c) of the Divorce Code was filed 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of~e 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 v~-ify that the statements made in this affidavit are tree and correct. I understand that false statements contained herein are made subject to penalties of 1 $ Pa. C.S. §4904, relating to unsworn falsification to authorities. DATE:'}tx~t~"°C~')°~'90~/ WAIVER OF NOTICE TO INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without any notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI 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 this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18. Pa. C.S. §4904 relating to unswom falsification to authorities,t Paulg~~~ Crane IN THE COURT OF COMMON PLEAS OF THE'~''~1~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Crane, Plaintiff 402 Herman Avenue, Apt. A Lemoyne, Pennsylvania 17043 207-58-8000 Leigh Shanna Crane, Defendant 402 Herman Ave., Apt. A Lemoyne, Pennsylvania17043 198-64-9366 CIVIL ACTION - LAW O~ I:~[~l'~ ~_.l'llt'[ TERM OASE NO. IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under 3301 (c) of the Divorce Code was filed on ]q/~rc_Ja 31~c9OO~/. 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of the complaint. 3. I consent to the entry ora 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 tree and correct. I understand that false statements contained herein are mede subject to penalties of 18 Pa. C.S. §4904, relating to DATE:unsw°m falsification to authorities. ~'~ ~x~x ~ %~--~x~. ~ Leigh Sh~nna Crane WAIVER OF NOTICE TO INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without any notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18. Pa. C.S. §4904 relating to unswom falsification to authorities. ~~ ~ Dated: , ~'X~,~o'-~ ' ' ~ Leigh ~anna Crane IN THE COURT OF COMMON PLEAS OF THE'~'~'~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND ShawnPaul Crane, Plaint~ 402 Herman Avenue, Apt. A Lemoyne, PennsCvania 17043 207-58-8000 Leigh Shanna Crane, De~ndant 402 Herman Ave., Apt. A Lemoyne, Penns~vania17043 198-64-9366 CIVIL ACTION - LAW CASE NO. IN DIVORCE TERM ACCEPTANCE OF SERVICE I, Leigh Shanna Crane, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divome filed in the above-captioned matter, Date Le~Jh Shanna Crane, defendant IN THE COURT OF COMMON PLEAS OF THE '/-' JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Shawn Paul Crane, Plaintiff 402 Herman Avenue, Apt. A Lemoyne, Pennsylvania 17043 207-58-8000 Leigh Shanna Crane, De~ndant 402 Herman Ave. Apt. A Lemoyne, Penns~vania17043 198-64-9366 § CIVIL ACTION - LAW § , § ~q /~¢~_/I/f/ TERM § CASE NO. § IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. DateandmarmerofserviceofComplaint:the ~ dayof ~'F-~ , 2004 by Acceptance of Service 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 Shawn Paul Crane; by Defendant Leigh Shanna Crane. (b)(1) Date of execution of the affidavit required by Section §3301(d) of the Divorce Code: (b)(2)Date of filing ap.d service of the P, laintiffs affidavit upon the respondent: 4. Related claims pending: 5. (Complete either (a) (b).) (a) date and manner of service of the notice of intention to file to transmit record, a copy of which is attached: (b) (1) Date Plaintiffs waiver of notice in §3301(c) Divorce was filed with the prothonotary: ,.. }Lo~, o,~L'°i ) c2 DO ~I (b) (2) Date Defendant's waiver of notice in §3301(c) Divorce was filed with the prothonotary: 0t~ o~C~) o2OOc/ 6. Attached hereto are: (a) A copy of the docket entries, certified by counsel ( or by clerk of courts - civil) to be a true and correct copy of the original docket entries; (b) The original proposed divorce decree (including a copy of the pre-nuptial agreement, which is requested to be incorporated by reference in said decree); (c) The completed form required by the commonwealth of Pennsylvania, Department of Health, Bureau of Vital Statistics; (d) The completed affidavit of non-military service under the Soldiers and Sailors Civil Relief Act of 1940, 50 U.S.C.A. App. See. 520, if required by rule 1920.46. ~Crane, P~itioner IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE"- OF _~J~.. PENNA. Shawn Paul Crane Plaintiff N O. 04-1364 Civ~ VERSUS Leigh Shanna Crane Defendant DECREE IN DIVORCE AND NOW, ,-/-u ( ~ 12 DECREED THAT Shawn Paul Crane AND Leiqh Shanna Crane , Z~I~LL, IT IS ORDERED AND , PLAINTIFF, , 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; None BY THE COURT: /~ ~, / PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : Vs : File No. Defendant : IN DIVORCE 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 cfa Final Decree in Divorce, or 'Y,,, affer the entry of a Final Decree in Divorce dated ~,~,~ jo.,~op, hereby elects to resume the prior surname of ~ ~.~ ~-. o , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: I .x- I o-[ o ~' x- r,D'~ ~ ~,,.)~ ~ Signature of name being resumed COMMONWEALTH OF EENNSYLVANIA ) COUNTY OFCory//z;O~/~2 ~d On the ~__r';D day of'7' /2e F ,200~:~, before me, the Prothonotary orthe 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 Wimess Whereof, I have hereunto set my hand hereunto set my hand and official seal. I JODY S. SMITH, NOTARY PUBLIC / Protl~not~ or Notary Public Car isle Boro, Cumberland County / My Commission Expires April 4, 20051