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Home My WebLink About05-5031 " KIMBERLEY A CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.O.r - ~D.31 CIVIL TERM MARK E. CRAMER, Defendant : 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 right important to you, including custody or visitation of your children. When the ground for the 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. 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 LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford S1. Carlisle, P A 17013 (717)-249-3166 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. You must attend the scheduled conference or hearing. 4 --. KIMBERLEY A. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.DK- S'611 CIVIL TERM MARK E. CRAMER, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER THE DIVORCE CODE 23 Pa.C.S. && 3301(a)(6). 3301(c) and 3301(d) The Plaintiff, Kimberley A. Cramer, by her attorneys, the Family Law Clinic, set forth the following cause of action in divorce: 1. Plaintiff is Kimberley A. Cramer, who currently resides at 179 East South Street, Carlisle, Cumberland County, Pennsylvania, since 1985. 2. Defendant is Mark E. Cramer, who is currently incarcerated at Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania, and has been incarcerated since September 11,2005. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 31, 2005 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Defendant has offered such indignities to Plaintiff, an injured and innocent spouse, as to render her condition intolerable and life burdensome. 8. A Final Order of Court granting Plaintiff Protection From Abuse was entered against Defendant on August 31, 2005 at docket number 05-4377. 9. The parties have lived separate and apart since August 10,2005. .. -. 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 counseling. Being so advised, Plaintiff does not wish the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce. Respectfully Submitted, Date: t!/)0/C5 I I ~ " e Rl~dlJJ- Angel velant Certified Legal Intern ~f}L o A LACE ROB R E. RAINS LUC OHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PAl 70 13 717-243-2968 , VERIFICA TION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date~ :2.O)D5 ~~.~.5:r~ ~ ""() (j c:: ",' r;:;; c;;:;> Cf\ en ~\ ""-0 f"" ()'> ~ -t ~1" 0"\ ~ -t)f'" _".0 (.:) J.., ~~-~ ~t~ C,-'- ~/ (J :Srr .~~-~ ::::JII ::;. - o cfI t"'J :'b: ...:. I k 0:r92- INS THOMA M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys KIMBERLEY A. CRAMER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO.05:-S'D5{ CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE MARK E. CRAMER, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Kimberley A. Cramer, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date r/:)b/o~ ,. r Respectfully submitted, ill1/~L W.J 0J Angel Rt elant Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 o <;:; ~ = = c,,1 (/) .11 -0 t',,) CJl ~:~ -J::;"" '2 ~ ..-\ :::t:-n rnp -q \:9 :"-.) t C) C) :(~~ S i> ~ ()l N KIMBERLEY A. CRAMER, Plaintiff, v. MARK E. CRAMER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-5031 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE ACCEPfANCE OF SERVICE I, Mark E. Cramer, accept service of the Divorce Complaint. Date q - ~& --0-5 ~~/~~ Mark Eugene Cramer, Defendant .-> = = "-" o C'~ , ( ~ c. ;;: :2 \ W o -n -..... '"J: -r\ i~~) . ~,:,.:..;,~- -q <2-(~, ?:;;.,r\; ;:"-\ -'-."" '>::..'1 :..,; --," ,-.' .' o -' -~ ~ KIMBERLEY A. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 05 - 5031 MARK E. CRAMER, Defendant CIVIL ACTION - LAW DIVORCE AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under ss 3301(c) and (d) of the Divorce Code was filed on September 26, 2005. 2. The marriage of Plaintiff and 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 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. S4904, relating to unsworn falsification to authorities. Dati'fbrch 17 0 G ) <t. ~ Kimberley Cramer Plaintiff () f~ 1",-":." ~ :::J Tl =;1 ~-r' rll t~,; =::::: :c.'" ;u ,,~) fj"' a C :-r1 j~~) C" 0') , . ~~~ :1J .< ~ Kimberly A. Cramer, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LA W F.R. No. 2005-5031 CIVIL TERM Mark E. Cramer, Defendant : In Divorce AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under S 3301( c) of the Divorce Code was tiled on September 26,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date offiling and service of 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. I verify that the statements made in this Affidavit are true and correct. I understand that lillse statements herein are made subject to the penalties of 18 Pa,C,S. ~ 4904 relating to unsworn falsification to authorities Dale: --5 - Ie!) -!)~ ~L-!/ ~~~ 1\1ark E. Cramer '^",._._..,.~-~~ c co.. ~-." C:.::> coo <.:,.... o ., ~ n,:D r- ;I: C." 2I: -~ ;:::::0 -' {,-:1 ,:~ .? i'~;, ~i'" -< N .r:- C) "'-"~ ~ KIMBERLEY A. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 05 - 503l MARK E. CRAMER, Defendant CIVIL ACTION - LA W DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE l. 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 liled 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 I 8 Pa.C.S. S4904 relating to unSWorn falsification to authorities. Date hi ()( i~/I~ ,...' f:~'-_1 0 c:::> -d cr" _f,~ .-\ ~ _;....-n ::;0 nip N ..0 []~~, ")1...-/ C! c:) p -r -;) .~;':", N ~~~I\CC" ) .r- ~J 0:: ~< Kimberly A. Cramer, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LA W F.R. No. 2005-5031 CIVIL TERM Mark E, Cramer. Defendant : In Divorce WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 ( 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! 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 verily that the statements made I this Waiver are true and correct. I understand thai false statements herein are made subject to the penalties of 18 Pa,C,S. !i 4904 relating to unsworn falsification to authorities. Date:_ ~ - )(0 - /)/0 ~A/A~ >_~ -- - Mark E. Cramer - C? ...~ 0 G,'::" ( <:~::.l ., - , C)<~ -''''- ::C-n :::;..--" il'P :;:0 ~g~ -l " ,''') ::\ -t,J 1;;1-12":' -' ;~., I'll l',) -, ",,-:" :n C'J -', ~,~--",.;<,-,.". ~ KIMBERLEY A. CRAMER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 05 - 5031 MARK E. CRAMER, Defendant CIVIL ACTION - LA W 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 !l3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant, Mark Cramer, personally on September 26,2005. An Acceptance of Service was signed on September 26, 2005 and filed on October 3,2005. 3. Date of execution of the affidavit of consent required by !l3301 (c) of the Divorce Code: by plaintiff- March 17,2006; by defendant- March 10,2006. 4. Related claims pending: None. 5. Date plaintiff's Waiver of Notice was filed with the Prothonotary: March 20, 2006, Date defendant's Waiver of Notice was filed with the Prothonotary: March 17,2006, 3/2.D { 06 Date ~- Lucy Johnston- Walsh, Esquire Robert E, Rains, Esquire Ann MacDonald-Fox, Esquire Thomas M. Place, Esquire William G. Martin, Esquire Supervising Attorneys F AMIL Y LA W CLINIC 45 N. Pitt Street Carlisle, PA 17013 7l7-243-2968 Fax: 717-243-3639 --- h' ..:"__J C::l u-' :'1= :::.:.'" ;:CJ r~,.' C) (.-) ::-:'1 .-\ ..,- ;-;l,::n I r:;: " C.::" ,~-) -~'- , r'_'_ . ~" ,- ::-;) .-<: 0'" ~Of +:+.:+.:+.:+.:+. + Of.:+' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +'f+++++ .. . . :+:+.:+.:+. . :+'Of.+'+ . +.:+.+:+. . + +.:+.:+. ~:+. +.:+. +. Of.:+ +. IN THE COURT OF COMMON PLEAS :+.+ Of +. +. +. +. +. +.Of +. +. +.:+. +:+. +. ++ +. ++ '+ + . . . . . . OFCUMBERLANDCOUNTY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++++++++++++++'1'+ STATE OF KIMBERLEY A. CRAMER, Plaintiff VERSUS MARK E. CRAMER, Defendant AND NOW, DECREED THAT AND PENNA, No. 503] 700'1 DECREE IN DIVORCE fl/\ V C-4 .23 , 2~b, IT IS ORDERED AND KIMBERLEY A. CRAMER , PLAINTIFF, MARK E. CRAMER , 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 NONE AT BY THE COURT: ST~ . ~.~ ~. ;tROTHONOTARY + ++ + + + +. + + + + + 'f.+ +;F.+ + + + + + + + + + + +:+. + + + + 'l'++ +'+'f.+++'I-:++++ +'+++'I-:'I-:'f J. ~rrL fl" ~ ~' ry".,t, * 5<" p 7::i 1-- /f/-17W 4hv -r?? W- Jf- E . ','. . '1;'