HomeMy WebLinkAbout08-7348Rebecca E. Crum, : IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. D 7 3 Gds; f -c?M
George D. Crum, ;
DEFENDANT CIVIL ACTION -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 may
proceed without you and a decree of divorce or annulment may 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, 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, PA 17013
(717) 249-3166
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 of business before the
Court.
Rebecca E. Crum, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
George D. Crum, ;
DEFENDANT CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, Rebecca Elizabeth Crum, pro se, and represents as follows:
COUNTI
DIVORCE UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Rebecca Elizabeth Crum, who currently resides at 1610 Newville Road,
Carlisle, PA 17015 and has resided there since on or about March 1, 2003.
2. Defendant is George Derek Crum, who currently resides at 1610 Newville Road,
Carlisle, PA 17015 and has resided there since on or about March 1, 2003.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for
at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September 7, 2002, at Carlisle, PA,
Cumberland County.
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.
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8. Plaintiff avers that there are children of the parties under the age of 18, namely: Laci
Georgia Crum, age 5.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce.
Date: December 17, 2008 By;
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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 falsification to authorities.
Date: /0?- / 7 O ??
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REBECCA E. CRUM, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 08-7348 CIVIL TERM
GEORGE D. CRUM,
Defendant : IN 6-U8T-19DYX>1vo-mCE_ ?-
AFFIDAVIT OF SERVICE
I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a
copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead
was personally served on the Defendant, George D. Crum, hand delivered, signed by the
defendant below. Said service on the day of January, 2009.
Signe
G rge D. Crum
a??,cJ
Lj9d'say D. aird Esquire
?'_' Attorney for P aintiff
37 South Hanover Street
Carlisle, PA 17013
717 - 243-5732
Sworn and Subscribed to
before me this 1 y day COMMONWEALTH OF PENNSYLVANIA
of January, 2009. NOTARUL SEAL
JENNIFER L. MARTEK, Notary Pcibk
Boro of Cadsle, Cw"jaW CowAy
My CO"s*n Expires Oct. 23, 2011 L=4i?s?
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