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Home My WebLink About05-2850 Dennis E. Crutcher, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - J'550 CIVIL TERM IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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 or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Dennis E. Crutcher, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - .21.HJ CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Dennis E. Crutcher, an adult individual, whose mailing address is P. O. Box 301, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Shannon K. Crutcher, an adult individual, who resides at 2 I 9 Farm Road, Newville, Cumberland County, Pennsylvania 1724 I. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on March 6, 1998 in Reynoldsville, Jefferson County, Pennsylvania. 5. There was a prior divorce action commenced in the Cumberland County Court of Common Pleas, docketed at 04-3 19; however, said Complaint was withdrawn by 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: Respectfully submitted, ROMINGER, BAYLEY & WHARE ~/t IOJ t , /fa Michael O. Pa ermo, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court LD. # 93334 Attorney for Plaintiff Dennis E. Crutcher, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - CIVIL TERM IN DIVORCE VERIFICATION I verify that the statements made in this Complaint 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. Date: 5- 3/- OS a:~~ z ~Z~ Dennis E. Crutcher, Plamtiff L~ I :s I- --) LI- e) <'J (~') u_ L.'-::) C-.:::, :::":"1 ,~ ,0 r' C. ~ 'U (j ,6 0- a~ - ~s \Q '\::) a -- Q " ;:J-V)~ 'j: "Q (j --=2::\J 0 '-l "'1 Q.... c:L. Dennis E. Crutcher, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - 28:;0 CIVIL TERM IN DIVORCE PROOF OF SERVICE GREEN CARD . Complete nems t, 2, and 3. Also complete Item 4 ff Restricted Delivaly Is desired. . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the mallpiBce, or on the front ff space permits. 1; Article Addressed to: Cl Ves Cl No ...., 'r1 pol._) ,,)h0J'>()(fY', K v0.A..cvflPL (;)/(.1 7{jfJ'(\ f2~ "f\.JZU..'i !,) II L<.. rh- I ~I,:\. <jJ ...' MIIl/ ~ jlXpnls& Mall Cl Reg . Ila'RelumRece/ptforM.- ClIIl9UT8dMIIl/ [] C,O.O. ~ 4. Restricted DeIIvery7 (Extrs FoB) ( ~ 7004 1350 0003 7142 5475 L.____...."_ 2. ArtIcle-Number rrnmsterrrom_IlIbeQ .... PS Form 3811 ,February 2004 Domestic Retum Receipt 102595-02.M.154Q (') c:: -? _...~-'~ '..1.......1 T~t;: ~-?r 1 (l.l;-' :s. ~_'S.~, ~~'(::= :;c:- :2 r' e ~ ~ c.' c..' r' ""' ,,' 0. Q. ~~ 11'[:'-, ~n~.;,,", ,,o,'., (1.,l'-" ~!:\ ',',~(:~ '"" :J> ~ W .r;- Dennis E. Crutcher, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Shannon K. Crutcher, Defendant CML ACTION - LAW NO. 05.2850 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 1,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. ~ 4904, relating to unsworn falsification to authorities. Date: f:/5-()5 /2,-.;. C ~ Dennis E. CrutcherlPlaintiff (') "n~ mI.>.. :'?'~ ~-!, 0~; ,-" "'~- ~E:, c ~ ..... = = <.n (/) ..., -0 N N o " ~:!l :B~ ~6 :::r: -ri c> ::n ~~ ?:6 -< -0 ::Jl: .c- o c- rr Dennis E. Crutcher, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW : NO. 05 - 2850 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce whhout 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! 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 subjectto the penalties of18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: 9- /S- dS (') G ~,~ '"(H::: c:;r<.- ~~f. J_" ~': )::7'~ ~'. L.oC" ;;; C~ -::7 ~ r;;; ~ ~ N N ~ ~:t! ~~ =C7:\1 ~ %~ .r:: =:.t CO ~ .t:'" Dennis E. Crutcher, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - 2850 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 1,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce afte:r service of notice of intention to request entry of the decree. 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. ~ 4904, relating to unsworn falsification to authorities. Date: / 0t.pt. /1' ()5 ~t;() /Shannon K. C tcherlDefendan (') ~ .- '"'ti\';",: IT'n -~'T. ~,7r- 0:~~' r:;C. ~Fj >-e: z ~ ~ = "" (I') fTl -0 N N ~ :?:n mfij -o~ '0 b, g~ .zrn S ~ -0 ::;:: r- ., c:::> .:;- - Dennis E. Crutcher, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - 28S0 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce wi1thout notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl 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. ~4904, relating to unsworn falsification to authorities. Date: 0fpt /7' os / ~p( / Shannon K. Crutc er, efendant o C ~.~':' rgy? -I' , ~l ~~':'. t2 ~-~ ?::;l~_--: .~-( l' 5?"~ ? .-< .... <g "" (/') 1'1 .." t"-' t"-' ~ ~:J:! ~\\ .1=" ~ ;;;, ~ s:- Dennis E. Crutcher, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. Shannon K. Crutcher, Defendant CIVIL ACTION - LAW NO. 05 - 2850 CIVIL TERM : 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: I. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 6, 2005, Certified Mail/Return Receipt, Restricted Delivery. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of The Divorce Code: by the Plaintiff September 15,2005; by the Defendant, September 17, 2005. Related claims pending: None. Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: September 22,2005. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: September 22, 2005. Date: q / Zf fO-:2005 Respectfully Submitted R~~ & Whare Michael O. Palermo, Jr., E quire 155 South Hanover Street Carlisle, PA 1'7013 (717) 241-6070 Supreme Court ID No. 93334 Q ~ .c.._>. .-..) '~:" 1-"'1,.' -:;- " C',/ '0.-; ~' C~~: \- ~;C;: ~2 ~ 't}. <A "" ~ "" -:;$. r:? c.;> :r:' q, ~,~ (I _. ""'0 -0 ;5; ') . """.{ =-\ ~~~ q.~ 1::. "" ~ ::.<::. :+o,+,;+;;+::;+;;+::;+:::Ii . . . . . . . . . . . . . . . . . . . . . . + . . . . . . . . . + . . + . . . . . + . . . . . . . . . . . + . + . . . . . . . . + . + + + . . . . . . . . + + . . . . . + + . . + . + + . . . . . + . + + . ;+;'f'f'f:+''f + . +. ++ . ... 'f+'f'f'f:+''f+;f.:Ii ;f.+;;f.;f. + + . ;+::+;+::+;f.+;f.++;;+::;f.;+::;f.++;f.;+;;f.;+:: ;f.;+::;f.;+;;f.++++;f.'f+ + + . . + . + . + + . + + . + + . + + + + + + + . + + . . . + . + . . + . + + + + + + + + + . . + . + + + + + + . + + + . . . . . + + + . + . + + + + + + . . . + . . . + + + + + + + + + + + . . . . . . . . :+' +:+:++++;f.++' IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. Dennis E. Crutcher Plaintiff No. nc; 7Rc;n VERSUS Shannon K. Crutcher Defendant DECREE IN DIVORCE 43: 33f;Yl ;}O()). IT IS ORDERED AND AND NOW, t>~~ DECREED THAT Dpnnis Crutcher . PLAINTIFF. E. AND Shannon K. Crutcher . 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 ,"" ..: -.~_....-'v..., .' ." .- ~ ~ .. '-' .* ......? ..... ,- . -< / , ::-"..;" , , ~ ~ _W; .... /""0.,.'" -/ . . "- ./J :...........;,.." ~ ..t,:. i"\:;......... ..........._'wr Ams<(1~l PROTHONOTARY . . .. . :++:+:;f. . .. . + .. . :+''t';f.'t' '+';f. +;f. + + .. + :+'+:+':+''+':+:'+':+:+;f.++;f.+ J. .~ ~ ~ ~zt..sv- '9- 0/ "'"'r'" f" $ /Y- -kIN P'l 5'?? 01 . A .~; "~ .. h ~ :... ~~ -- , .