HomeMy WebLinkAbout09-3206STEPHANIE E. CHERTOK, ESQUIRE
PA Supreme Court ID: 52651
61 West Louther Street
Carlisle, PA 17013
(717) 249-1177
Attorney for Plaintiff
ALAN L. CROMER,
Plaintiff
V.
VICKI M. CROMER,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. y' - ,?aD? C?Cu
CIVIL ACTION - LAW
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 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 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, One
Courthouse Square, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYERS'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 St.
Carlisle, PA 17013
(717) 249-3166 OR (800) 990-9108
STEPHANIE E. CHERTOK, ESQUIRE
PA Supreme Court ID: 52651
61 West Louther Street
Carlisle, PA 17013
(717) 249-1177
Attorney for Plaintiff
ALAN L. CROMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
VICKI M. CROMER,
Defendant
( .( ^-
NO. 0 9. 3 2-06
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Alan L. Cromer, who currently resides at 180 Quarry Hill Rd.,
Shippensburg, Cumberland County, Pennsylvania.
2. Defendant is Vicki M. Cromer, who currently resides at 33 South High St,
Newville, Cumberland County, Pennsylvania.
3. The Plaintiff and Defendant have been living separate and apart since
October 2005.
4. The 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.
5. The Plaintiff and Defendant were married on October 7, 1994 at the
Trinity United Methodist Church, in Walnut Bottom, Pennsylvania.
6. No children were born to this marriage.
7. There have been no prior actions of divorce or for annulment between the
parties.
Neither Plaintiff nor Defendant in this action are a member of the Armed
forces.
9. The marriage is irretrievably broken.
10. 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 such
counseling.
11. Plaintiff and Defendant are each in possession of all of the property that is
owned by each parry and there shall be no additional claims for equitable distribution of
marital property, spousal support, or alimony due to the terms of a prenuptial agreement
that was signed by the parties on October 7, 1994.
12. Plaintiff requests the Court enter a decree of Divorce.
WHEREFORE, the Plaintiff requests that this Honorable Court enters a Decree
of Divorce under 3301(d) of the Divorce Code.
Res ctfully submitted,
Stephanie E. Chertok, Esq.
PA Sup. Ct. ID# 52651
61 W. Louther St.
Carlisle, PA 17013
717-249-1177
Counsel for Plaintiff
VERIFICATION
I, Alan L. Cromer, verify that the statements made in this Divorce Complaint are
true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities.
Date ALAN L. CROMER
STEPHANIE E. CHERTOK, ESQUIRE
PA Supreme Court ID: 52651
61 West Louther Street
Carlisle, PA 17013
(717) 249-1177
Attorney for Plaintiff
ALAN L. CROMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V.
VICKI M. CROMER,
Defendant
NO.
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Stephanie E. Chertok, counsel for Plaintiff hereby certify that a copy of the
Complaint for Divorce, directed to Defendant, or served upon Defendant's attorney,
James A. Miller, Esquire, 765 Poplar Church Road, Camp Hill, Pa 17011, this o?! day
of , 2009, by regular mail, postage prepaid, and certified mail, return
receipt requested, pursuant to Pa. R.C.P. 1930.4(c).
tephanie E. Chertok, Esq.
PA Sup. Ct. ID# 52651
61 W. Louther St.
Carlisle, PA 17013
717-249-1177
Counsel for Plaintiff
ILFC;.
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