The URL can be used to link to this page

Home My WebLink About04-1885 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF DENNIS E. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 04 - Iff';" CIVIL TERM DANETTE .J. CRAMER, Defendant : IN DIVORCE NOTICE 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 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 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, Pennsylvania 17013 717-243-3166 DENNIS E. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 04 - / H 5' CIVIL TERM DANETTE oJ. CRAMER, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. I/Win, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is DENNIS E. CRAMER, an adult individual residing at 1414 Bradley Drive, Apartment G214, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Danette J. Cramer, an adult individual residing at 319 Fairview Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on May 1, 1993, in Carlisle, Cumberland County, Pennsylvania 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. April 28, 2004 2J -a-- ~, (? DENNIS . CRAMER, Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court 10 No. 29920 DENNIS E. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 04 - 19ft CIVIL TERM DANETTE ... CRAMER, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. April 28, 2004 j)~' f" ~:? DENNIS E. CRAMER, Plaintiff n ....., 0 = c ~~ ., .. ~- .... ',.1(" :~ --I ;>.'-" ..,.. -:- .1 :;f) r"r= ~ Jf N -cQ1 ~ 'O'? ~ C> ~~() ""::' ---0 ~,~~~ ~ <>) "" ~~:-' ;-:i::nl f>... r::> .J .., ..!... ::::~ ;". --<: --0 --.j :.u c -< w .-< ..., v, C DENNIS E. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 04 - 1885 CIVIL TERM DANETTE J. CRAMER, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. RoC.P. RULE NO~ NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the amended complaint in divorce was served upon the defendant on or about May 1, 2004, by certified mail, addressed to the defendant at 319 Fairview Street, Carlisle, PA 17013, return receipt No. 7003 1010 0001 12047368. 3. That a copy of the signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsific~~ May 4, 2004 D Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court 10 No. 29920 '" ..JJ rn I'- U.S. Postal Service", CERTIFIED MAIL" RECEIPT (DomestIc Mail Only; No Insurance Coverage Provided) 3' l:J ru ...... lbtaI Postago & F... $ Postage $ g J Rewm::: o (ndorsement Required) CJ Restricted Delivery Fee r-=r (Endorsement Required) l:] ...... rn l:] l:] I'- . Complete Kerns 1, 2, and 3. Also complete Kern 4 ij Restricted Delivery Is deslred. . Print your name and address on the reverse so thet we can return the card to you. . Attach this card to the back of the mailpieca, or on the front if space permits. 1. Artickt Addressec:l to: o Agent o AddlOSll88 C. Date of Delivery J"T-c.<( D.lsdellvelyaddrooa_fromlleml? If YES, enter delivery -. below: o Yes 01 [ Danette J. CLCDUl::L 319 Fairvie-... Street Carlisle, p:\ 17013 3. Service Type D Certified Mail D Express Mall D Registered 0 Return Receipt for Merchandise . I' .. , : ~ ' ;~" ,."w.....~"'..~ . 2. Article Number (Transfer from SMVIce 1sbeI) PS Form 3811 , August 2001 7003 1010 0001 1204 73b8 Domeotlc Rotum Aocoipl 102515...Q2-M.1036 EXHIBIT "A" ~ , { ~ ) ') ,..., ~ (") c::') C c.::? ...- ~-n .>.;-' fll- hi Z~ I :(1 CJ .:0 L ~" .. S~L) 0 -0 -!:::::;::, :.::: (")7";:: ~O ::J: ',,', ;V~ )>0 N c: z .. ~~~: :;t c..: \ ( DENNIS E. CRAMER, Plaintiff : IN THE COURT elF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. II.AW : NO. 04 - 18S5 CIIVIL TERM DANETTE J. CRAMER, Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about April 28, 2004. Service of the complaint was made on or about May 1, 2004, by certified mail (see Affidavit of Service filed on or about May 4, 2004). 2. The marriage of plaintiff and defendant is irrlstrievably broken and ninety days have elapsed from the date of the service of the amEmded complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. JANUARY /1, 2005 1) (0 C' . -<.-. -' <...- - DENNIS E. CRAMER (") "'-, ~:5 <";j"'i ~-- ~".,;t , CD r...) C) DENNIS E. CRAMER, Plaintiff : IN THE COURT (IF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. lLAW : NO. 04 - 1885 CIIVIL TERM DANETTE J. CRAMER, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION ,ro REQUEST ENTRY OF A DIVORCE DECIREE YNDER SECTION 330.tna9F 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to cluthorities. January 111 , 2005 j)....., ~ DENNIS E. CRAMER e <" r<'\ ,- ::, r.:.:5 Co';"1 .,." , ! {,.... C::J -~-'1 0.~' o DENNIS E. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COL.:NTY, PENNSYLVANIA vs. : NO. 04-1885 DANETTE J. CRAMER Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on April 28, 2004. 2. The marriage of plaintiff and defendant is im:trievably broken and ninety (90) days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry ofthe decree. I verify that the statements made in this affidavit an: 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: j4n~/I{ /) ~<X)S-- -iJ) (luh plfJ & GnfU /1 Danette J. Cramer Social Security No. ~I 0- to Lj -'-/; /21 - ~-i ,- ~~ :n ,-J I C':i (" :- DENNIS E. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 04-1885 DANETTE J. CRAMER, Defendant CIVIL ACTION - LAW 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 in 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 wiJI not be divorced until a divorce decree is entered by the Court and that a copy of the decree wiJI 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:)..Al"l-u"",,'1 7; -uoor -ij)/Y AI lit .g ~(j/J[/\ Danel1e J. Crame -41/ () - U-f-41i?7 Social Security No. c': -~-i , , .....}; "_._, C) --" - .-, _r ;-T1 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY 10 NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF : IN THE COURT ()F COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DENNIS E. CRAMER, Plaintiff v. : CIVIL ACTION - ILAW : NO. 04 - 1885 CIIVIL TERM DANETTE J. CRAMER, Defendant : IN DIVORCE 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 Sllction 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about MAY 1,2004, defendant was served with a copy of the divorce complaint (See Affidavit of Service filied on or about MAY 4,2004). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: January 12.., 2005 By the defendant: January 7 ,2005 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Reiated 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: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301 (e) divorce was filed with the Prothonotary: January l!i, 2005 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: January I ,2005 January I Y, 2005 c: c) c,:) ',,- , . C:) ,,' . " " , " , " . . " , . . . " " " " , " " " " " , " . , " , " " " " " " " " " " " " " " " " " " " " " " " " , " " " , " " , " , " " " " , " " " " " " " " " . " " " " " " , " " . " " " " " " " :+':+:'f!'f! "" 'f! :+:'f!'f!'f! 'f! 'f!:f.'+:if.:f. 'f!~'f!+ :f.'f!++'f!T.'f!'f!'f!+'f!++'f!'f!~'f!+ ~'f!+.'f!+++'f!+'f!+++++'f!+++++++'f!+' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Dennis E. Cramer, Plaintiff No. 04-1885 CIVIL TERM VERSUS Danette J. Cramer, " " " " " " " . " " " " . " " " " " " " " " " . " " " " " " " " . " " " " . " " " . " . " " " " " " " " . " " " " . " . . " " " " " " " . " " " " " " ,. '+' l' + +:+: +.:+:+:+:+:+ '+' +:+:+:+:+:+:+:+ 'f!:+ '+' '+' + '+' ++ Defenil;mt DECREE IN DIVORCE ANDNOW,C~ 13. \, 2005 , IT IS ORDERED AND DECREED THAT DENNIS E. , PLAINTIFF, CRAMER AN 0 DANETTE J. CRAMER , 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. , i ~ ,- , , ~ , , , " \,. , , , ... , / - . -~... / , / .".' . . :..................~~~~ ., ......-."'f .. ;; PROTHONOTARY " .. 'f++-'f!'+''fi':f.'f!'+''f'+<+''f! :+'+::+':+: 'i' +'f! +++:++++ " H " . " . . " . " " . . " . . . " " . " " " " " " " . " " J. c'A1 .~, I'f"~p>f ~f., ~JO 7F f./~ ~ fp l' ~nw.;.p:i )0 Y( ( ).II bl.1 , ," '\ , . -------- -