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HomeMy WebLinkAbout08-6143IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Teresa L. Crum, : No. ?g - 4r?3 ?l v? Plaintiff Civil Action - Law VS. In Divorce Allen B. Crum Defendant 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 in divorce or annulment may be 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 the custody or visitation rights 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 at the Franklin County Courthouse, Chambersburg, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOUR CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Teresa L. Crum, Plaintiff VS. Alan B. Crum Defendant :No. 03-(aly3 Civil Action - Law In Divorce COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Teresa L. Crum who currently resides at 2774 Jamestown Road, Morganton, Burke County, North Carolina. 2. Defendant is Alan B. Crum who currently resides at 1266 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania. 3. Defendant has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on June 11,1988 at Mongul, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. Wherefore Plaintiff requests that she be granted a divorce from the bonds of matrimony. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 ?l ? ?. c?. ? "?" O ,?°. ? ? ?-' ?" C -Z -? ' t?7 .?"' .? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA 02-1.193 Teresa L. Crum, : No. Civil Term Plaintiff Civil Action - Law vs. In Divorce Alan B. Crum Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Date: 1-36-07 Alan B. Crum f .e..4r.. ? Y t 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA D8• G ?1!3 Teresa L. Crum, : No. Civil Term Plaintiff . Civil Action - Law VS. Alan B. Crum Defendant : In Divorce 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. 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. 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 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. Date: / 3o' Az zz? Alan B. Crum Defendant w ttt''Cv r ?y r, -4 sr, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Og • '!?'/Z/3 Teresa L. Crum, : No.-05-844Civil Term Plaintiff Civil Action - Law VS. In Divorce Allen B. Crum Defendant AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Allen B. Crum, of 1266 Ritner Highway, Shippensburg, Pennsylvania, 17257 by certified mail and was accepted on delivery by Alan B. Crum, on October 18, 2008. i? 0 0 en k-j an ti 0 0 0 0 to Cr W W Ul A L-i a i .l H. Anthony Adams, Esq- Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this day of ZW)L GU( 200:5: U/ WC, 6?d Notary Public My Commission Expires: COMMONWEALI d 017 PENNSYLVANIA NOTARIf SEAL MICHELE R. C'Rf, Notary Public 8M of Shippemu ig, Cumberland County My Commission Expi - July 16, 2012 f Ca ...? ?L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA o6- 4 jq3 Teresa L. Crum, : No. 05-844 Civil Term Plaintiff Civil Action - Law VS. In Divorce Alan B. Crum Defendant STIPULATION TO AMEND COMPLAINT Now come the Plaintiff and Defendant and do state and agree as follows: 1. The complaint and caption have the Defendant's first name spelled Allen. 2. The correct spelling of the Defendant's first name is Alan. 3. The Plaintiff and Defendant agree that the complaint and the caption of all subsequent filing be and is by this stipulation amended to correct the spelling of Defendant's first name from Allen to Alan. The parties further agree that no amended complaint is required to be filed. H. Anthony Adams Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 VERIFICATION I verify that the statements made in this Complaint 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. I further acknowledge, stipulate and consent to the amendment. Date:c Alan B. Crum VERIFICATION I verify that the statements made in this Complaint 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. I further acknowledge, stipulate and conse to the amendment. Date: Teresa L. Cru c-n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA o8- Teresa L. Crum, ? 6114-3 No. 86-844 Civil Term Plaintiff Civil Action - Law VS. In Divorce Alan B. Crum Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 14, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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. Date: 12 Teresa L. C t ? ?: t? bra ' t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA ola--(o 193 Teresa L. Crum, : No.-65-844 Civil Term Plaintiff : Civil Action - Law VS. Alan B. Crum Defendant : In Divorce 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. 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. 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 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. 'AITIA Date: Teresa L. Cr Plaintiff C) P,4 Y.. ZVI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Teresa L. Crum : No. 08-6143 Civil Term Plaintiff : Civil Action - Law vs. : In Divorce Alan B. Crum Defendant 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: Service was made by Certified Mail Return Receipt Requested on October 17, 2008 and received by Defendant on October 18, 2008. An affidavit of Service was filed. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff February 2, 2009; by Defendant January 30, 2009. 4. Related claims pending: None. 5. Plaintiffs Waiver of Notice was signed on February 2, 2009 and is filed herewith and Defendant's Waiver of Notice was signed January 30, 2009 and was filed February 3, 2009. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 0 ? tea . w cri z `. • Y CJ't Teresa L. Crum V. Alan B. Crum IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6143 Civil Term DIVORCE DECREE AND NOW, it is ordered and decreed that Teresa L. Crum plaintiff, and Alan B. Crum , defendant, re divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by t e parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None • By tkm Court, Attest: Prothonotary rllwtvr ,env