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Home My WebLink About04-2623IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Darren Craine, Plaintiff V. Denise Craine, Defendant No. CIVIL ACTION - LAW NOTICE TO DEFEND AND CLAIM RIGHTS You h ave been sued in Court t o obtain custody, partial custody, or visitation of the children herein named. If you wish to defend against the claims set forth in thc following pages, you mast take prompt action. You are warned that if you fail to do so, the case may proceed without you and you may lose rights important to you, including custody or visitation of your child. 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. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Center 32 South Bedford Carlisle, PA 17013 Telephone: (717) 249-3166 AVISO PARA DEFENDER USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en la paginas siguientes, debe romar accion antes de la audiencia fijada en la Directiva anexa. Se le avisa que si no se defiende, el caso puede proceder sin usted y una Orden puede set emitida por la Cone en su contra sin mas aviso por cualquier queja o compensation recLamados en la Peticion. Usted puede perder propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO DE UNA VEZ. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO. VAYA O LLAME A LA OFIC1NA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL. Lawyer Referral Service of the Cumberland County Bar Association Cumberland Cotmty Bar Center 32 South Bedford Carlisle, Pennsylvania 17013 Telefono: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARREN CRAINE, : Plaintiff : DENISE CRAINE, : Defendant : No. V q' ,Z CIVIL ACTION - LAW DIVORCE COMPLAINT UNDER §3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes Plaintiff, DARKEN CRAINE, by and through his attorney, Nathan S. Henriksen, Esquire, and states as follows: 1. Plaintiff is DARREN CRAINE (hereinafter "Husband"), who currently resides at 506 Miller Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is DENISE CRAINE (hereinafter "Wife"), who currently resides at 144 Meadow Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Husband and Wife have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. Husband and Wife were married on February 29, 1992, at Lewisberry, Pennsylvania. 5. 6. allies. 7. There have been no prior actions of divorce or for annulment between the parties. Wife is not a member of the Armed Services of the United States or any of its Husband has been advised counseling is available and that Wife may have the right to request that the court require the parties to participate in counseling. 8. The marriage is irretrievably broken. WHEREFORE, Husband respectfully requests your Honorable Court to enter a Decree in Divorce dissolving the marriage of the parties. e~~ks~emitted' Attorney I.D. No. 90830 145 East Market Street York, Pennsylvania 17401 (717) 843-8046 Attorney for Plaintiff, DARREN CRAIN VERIFICATION I verify that the statements made in this ~'~N~rD~,~O,ff ~.~l/O ~P~ t4,15~are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Darren Craine, Plaintiff : No. (_.~t _..2& ~.~ : V. : CIVIL ACTION - LAW Denise Craine, : Defendant : : ACCEPTANCE OF SERVICE I, _ J)e~l isa ~--/~Z~r~ _, 'the Defendant in the above captioned matter did accept service of the Notice and Corn laint in the above captioned matter, on _g/~/ ,at /¥q /14~.....1.. /.-_ ,L, Denise Craine IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARREN CRAINE, : No. 04-2623 Plaintiff : : v. : CIVIL ACTION - LAW : DENISE CRAINE, : Defendant : DIVORCE AFFIDAVIT OF CONSENT UNDER 23 Pa. R.C.P. 3301(c) l. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 10, 2004. 2. The mamage of Plaintiffand Defendant is irretrievably 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 Divome after service of notice of intention to request entry of the decree. 4. 1 understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. I affn-m that I am not in the military service of the United States of America, and that my spouse is also not in the military service of the United States of America. 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.A. §4904 relating to unsworn fa~ations to authorities. Date: WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(e) OF THE DIVORCE CODE 1. I consent to 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 Waiver are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unswom f~ to authorities. RECEIVED SF.? 2 7 21}0~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARREN CRAINE, : NO. 04-2623 Plaintiff : : v. : CIVIL ACTION - LAW : DENISE CRAINE, : Defendant : DIVORCE AFFIDAVIT OF CONSENT UNDER 23 Pa. R.C.P. 3301(c) 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 10, 2004. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed fi.om the date of filing and service of the Complaint. 1 consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the decree, I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. I affirm that I am not in the military service of the United States of America, and that my spouse is also not in the military service of the United States of America. 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.A. §4904 relating to unswom falsifications to authorities. DENISE CRAINE COMMONWEALTH OF PENNSYLVANIA COUNTY OF /---~$ght/c~ ~2 SS.: On this S2 ~ day of .ff2~. ,2004, before me, a Notary Public, the undersigned officer, personally appeared DENISE CRAINE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that executed the same for the purposes therein contained. In Witness Whereof, 1 hereunto set my hand and official seal. NOTARY PUBLIC I Notarial Seal My commission expires: I Christine F. Stewart. Notary Publte 1 I Palmyra Boro, Lebanon County [ My Comn~ission Expires May 17, 20071 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARREN CRAINE, : No. 04-2623 Plaintiff : : v. : CIVIL ACTION - LAW DENISE CRALNE, : Defendant : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2, I unders~nd ~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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S.A. §4904 relating to unswom falsifications to authorities. DENISE CRAINE COMMONWEALTH OF PENNSYLVANIA : ~-~TX~tc) : SS.: COUNTY OF : On this o~ ,~ day of ~ ,2004, before me, a Notary Public, the undersigned officer, personally appeared DENISE CRAINE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. NOTARY PUBLIC My commission expires~l - ' ' Notarial $??1 / CSwisiSne F. Stewart, Notary / Palmyra B0ro, Lebanon Couaty ~2~1~ Co~nnli~sion Exph'es May IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DARREN CRAINE, Plaintiff V. DENISE CRAINE, Defendant No. 04-2623 CIVIL ACTION - LAW DIVORCE PRAECIPE TO TRANSMIT RECORD 1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code. Date and Manner of service of the Complaint: The Defendant accepted service of the Complaint and executed and Acceptance of Service on June 20, 2004. The Original Acceptance of Service was filed with the Court on July 6, 2004. 3. (Complete either paragraph (a) or (b).) (a) (b) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divome Code: by Plaintiff September 23, 2004; by Defendant September 28, 2004 Date of execution of the Affidavit required by 3301(d) of the Divorce Code: and, date of filing and service of the Plaintiffs Affidavit upon the respondent: 4, Related claims pending: No economic claims were raised. 5. Complete either (a) or (b) a. Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: b. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 5, 2004. c. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 5, 2004. ~aman'~. taermKsen, lzsqulre MENGES, MCLAUGHLIN, CUNNINGHAM t~; KALASNIK, LLP Attorneys for Plaintiff Sup. Ct. I.D. No. 90830 145 East Market Street York, PA 17401 (717) 843-8046 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ¢~*, DARREN CRAINE, PLAINTIFF N O. PENNA. 0A-2623 PLEAS CIVIL TERM VERSUS DENISE CRAINE, DEFENDANT AND NOW, DECREED THAT AND DECREE IN DIVORCE DARREN CRAINE DENISE CRAINE , IT IS ORDERED AND , PLAINTIFF, ., 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 ATTEST:..~ / PROTHONOTARY