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HomeMy WebLinkAbout05-2933 .- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Susanne C. Crider, v. Defendant CIVIL ACTION - LAW NO. 05- ..2.q33 CIVILTERM IN DIVORCE Randall K. Crider, 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 MAY BE 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. .. Susanne C. Crider, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. Randall K. Crider, CIVIL ACTION - LAW NO. 05 - J..'1.3",3 CIVIL TERM IN DIVORCE Defendant COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Susanne C. Crider, an adult individual, who resides at 12 Kingswood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Randall K. Crider, an adult individual, who resides at 1124 Egret Lakeway, Viera, Florida 32940. 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. Ohio. 4. Plaintiff and Defendant were married on April 25, 1992 in Ashland, Ashland County, 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. - - - Date: (P/I(OO' I WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE Michael O. Pa ermo, Jr., Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court J.D. # 93334 Attorney for Plaintiff . , 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: &'( ~(O~ <::.... .~ ie' ~~~ c. }/~ Susarme C. Crider, Plaintiff ... ~ (') '" c: = ff1 "'" ~ ~ c.n " ._, F "" fTl }:~'-~ <..... :i! ~ F 2':';, c: 8 &r <: m:tJ r- I g2 ..or . 0;) ""'c c:::. 4: ~J '" ;;F? "" 'I'. C> ::l: ~ifJ .- ........ '0 -r.. J.'>c ;S; om 'l:> ""'- -.,.. <::) ""- --, -<: v- ~ ~ ~ W -< Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Susanne Crider, v. Defendant CIVIL ACTION - LAW NO. 05 - 2933 CIVIL TERM IN DIVORCE Randall K. Crider, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on. 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. S 4904, relating to unsworn falsification to authorities. Date: 10 (31 Oe;- I / '- - ~~ (~ Susarme CriderIP1aintiff c; (--. ...., = C:;"l en o C) -., C~ ~;, o Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Susanne Crider, v. Defendant CIVIL ACTION - LAW NO. 05 - 2933 CIVIL TERM IN DIVORCE Randall K. Crider, 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 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 witft 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. 94904, relating to unsworn falsification to authorities. Date: /oI3I()~ I I --- ~ ~ C-- =>~ Susarme CriderIP1aintiff , r-' (") ~ --(\ (:..1'"' S ~/. -- 0) ..,.-:> -;;cf" ~- -:::- .- \.::"::~ -:;\ ..<c :;:" .;:> ------ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Susanne Crider, v. Defendant CIVIL ACTION... LAW NO. 05 - 2933 CIVIL TERM IN DIVORCE Randall K. Crider, AFFlDA VlT OF CONSENT AND ACKNOWLEDGEMENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 8, 2005, and I acknowledge receipt of a copy of the same, for which I signed an Acceptance of Service on June 9, 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. 4. 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. 5. I have been advised of the availability of marriage counseling, and do not request that the Court require that my spouse and I participate in said counseling. 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. ;l4904, relating to unsworn falsification to authorities. Date: / f') - 1':2...... 0'; ~ev,LJj lJrW Randall Crider/Defendant ---------- Q ~? ...., CC', ~ '2":, _. - O? :;-:< ':i;> ,-) ';-;']1 :::;I....... "'~i) ;::-;~ \~.;(:^. , , ::, ;~,' ::;;. - - .' ~;" ',4 ;;:" c:.> - Plaintiff IN THE COURT OF COMMON PLEAS OF. CUMBERLAND COUNTY, PENNSYL VANIA Susanne Crider, v. Defendant CIVIL ACTION ... LAW NO. 05 - 2933 CIVIL TERM IN DIVORCE Randall K. Crider, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 330I(c) OF THE DIVORCE CODE I. 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ;l4904, relating to unsworn falsification to authorities. --- Date: / t.9 - 12 - 0 ~ c))JQ;zd Randall K. Crider, Defendant C) ....., 0 ~ (--~ .= ~.1 <"- c.J'1 CO ,) -. - cc :r.:c::> ~. l.. (' /' ~=~. .:.7~ CJ ... "~":+'f:+:+"':+:+:+:+:+"" + 't;:+ + +.:+ +. '+"+ . . , . . . , . , . . , . . . . . . . . , . , . . . . . . . . . . . . . . , , . . , . , . . . . , , . , . , . . . . , . , . , . . . . . . , . . . . . , . , , +. +. +. +. , +. +. +. , +. , +. +. +. +. +. +. . +. +. . +. +. . ~++.+~'+"++++++++.:+++++++ ""+:+':+~:f.+' .. . +'f+,.'t;+:++.+,.++++:+'f~+ . :+'f.++.+"+.~~+"'f"+ . . . . +. . . . . . . . . . . +. . . . +. . +. . . . . . . . . . . . . . . . +. . . . . . +. . . . . +. . . IN THE COURT OF COMMON PLEAS STATE OF Susanne Crider Plaintiff VERSUS Randall K. Crider Defendant AND NOW, DECREED THAT +. +. . . . . . . . . +. +. +. +. +. +. +. AND OFCUMBERLANDCOUNTY PENNA. No. 05-2933 Civil DECREE IN DIVORCE he-\: . u" , 2e:oS, IT IS ORDERED AND Susanne Crider , PLAINTIFF, Randall K. Crider , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT . +. . +. 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