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HomeMy WebLinkAbout04-1659SHARON M. CRANE, Plaintiff VS, MAURICE S. CRANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO.O~f'-/~"~ CIVIL TERM 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 foregoing 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 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; Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S --EES 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH 3ELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 1 7013 Telephone: (717) 249-3166 SHARON M. CRANE, Plaintiff VS, MAURICE S. CRANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this ist is kept as a convenience to you and you are not bound to choose a counselor from this ist. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. 2 SHARON Mo CRANE, Plaintiff VS. MAURICE S. CRANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW N O. ,~ z'/-/~,~"~'~' CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, SHARON M. CRANE, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is SHARON M. CRANE, an adult individual who currently resides at 928 Allenview Drive in Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is MAURICE S. CRANE, an adult individual who currently resides at 1011 North Front Street, Apt. 1 in Harrisburg, Dauphin County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Common- wealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 8 July 1995. 5. There have been no prior actions of divorce or annulment between the parties. 6. This marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff 33ay have the right to request that the Court require the parties to participate in counseling. 3 8. The Plaintiff requests this Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the ~)ivorce Code of Pennsylvania. Attorney for Plaintiff Supreme Court ID 17225 525 North 12th Street Lemoyne, PA 17043 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). SHARON M. CR/~NE SHARON M. CRANE, Plaintiff VS. MAURICE S. CRANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.Oq~(G5~ CIVIL TERM IN DIVORCE NOTICE TO 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 in mid April 2002 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, awyer'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 £hat false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to Jnsworn falsification to authorities. :ate: SHARON M. CRANE SHARON M. CRANE, Plaintiff VS. MAURICE E. CRANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1659 CIVIL TERM IN DIVORCE DEFENDANT'S COUNTER./t~FiDAViT UNDER SECTION 3301(D) OF THEDIvORCE CODI 1. Check either (a) or (b): ~ V'~(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 2. years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): /~"f--' I,,""~) I do not wish 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. __ (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relatlng to unsworn falsification to auth I~t~ Date: ~/4-/~ U/R~iC S~.'.~R~NE~ NOTICE IF YOU DO NOT WISH TO OPPOSE A DIVORCE D ECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAViT. SHARON M. CRANE, Plaintiff VS. MAURICE S. CRANE, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1659 CIVIL TERM IN DIVORCE ~WAIVER OF NOTICE OF INTENTION T.O REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 c OF THE DIVORCE CODE 1. I consent to the entry ora final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if/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 fa/sification to authorities. Dated: SHARON M. CRANE SHARON M. CRANE, Plaintiff VS. MAURICE S. CRANE, Defendant ) ) ) ) ) ) 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,CIVIL ACTION - LAW NO. 04-1659 CIVIL TERM IN DIVORCE .WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330 ! (c) OF THE DIVORCE CODE 1. I consent to the entry ora final decree in divorce without 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 bc divorced until a divorce decree is entered by the court and that a copy of thc decree will be sent to me immediately after it is filed with the Prothonotary. I verify that thc statements made in this Affidavit are tmc ~md correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Dated: ' -- SHARON M. CRANE, Plaintiff VS. MAURICE S. CRANE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1659 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVlCF I hereby accept service of the divorce complaint and the Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code, with a Counter-Affidavit attached to it, in the above matter and acknowledge receipt of copies of those docLim~ed~ts.. Date SHARON M. CRANE, Plaintiff VS, MAURICE S. CRANE Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-1659 CIVIL TERM IN DIVORCE .PRAECIPE TO TRANSMIT RF.':CORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Ground for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: Personal service on 3 May 2004 ~Acceptance of Service filed contemporaneously herewith~ 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 ~ (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: Filed 16 .April 2004, served 3 May 2004 (see Acceptance of Service filed contemporaneously herewith~. 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 copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: D~ated ~-/ /'~/¥~ ?-~)o~f, filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: dated 26 Ma 2004 filed contemporaneously herewith. Date: ~/~/ ~)4t( BY_ ,_~-'~,' _~r', Sa~rru~l L. A-nd~ Attorney for Plaintiff IN THE COURT OF COMMON PLEAS SHARON M. CRANE, Plaintiff OFCUMBERLANDCOUNTY STATE Of PENNA. VERSUS MAURICE S. CRANE~ Defendant NO. 04-1659 CIVIL TERM AND NOW, DECREED THAT AND DECREE IN DIVORCE 2004 SHARON M. CRANE MAURICE S. CRANE ARE DIVORCED FROM THE BONDS Of MATRIMONY. , IT IS ORDERED AND , PLA] NTIFF, , 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; NONE PROTHONOTARY