The URL can be used to link to this page

Home My WebLink About06-1814 II Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06- /~/f CIVIL TERM Helen L. Crouse alkJa Kelly Crouse, 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 will proceed without you and a decree in divorce or annulment may 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 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 at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 Street Carlisle, PA 17013 (717) 249-3166 II i Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06- I r If CIVIL TERM v. Helen L. Crouse a/k1a Kelly Crouse, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Mike Crouse, an adult individual, currently residing at 218 S. Gettle Ave, Shippensburg, Cumberland County, Pennsylvania. 2. Defendant is Helen L. Crouse, a/k1a Kelly Crouse, an adult individual, currently residing at 15309 Ridge Road, Waynesboro, Franklin County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on April 8, 2003 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the pa rties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since August 24, 2005 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. II WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted TURO LAW OFFICES --'.', c3~~ /06 Date a n R. Waltz, uire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II II VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and i correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. 94904 relating to unsworn falsification to authorities. G>h8/JOOG Date ' M;k!!:J C /Vl.,'--i14f II CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Complaint in Divorce, upon Helen L. Crouse a/kla Kelly Crouse, by depositing same in the United States Mail, certified return receipt, postage pre-paid on the .::Jq~./ . day of March, 2006, from Carlisle, Pennsylvania, addressed as follows: Helen L. Crouse 15309 Ridge Road Waynesboro, PA 17268 TURO LAW OFFICES - c= en R. Waltz, Esquir 28 South Pitt Stre Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 t\..:l C;; .(' lr, ~;'. ~ >.-'"' C' 0'\ ..c 1" ;t,j - ,'0 /-. "::2.:: '" ~ '.,' Co <~) ~'n __-I, , \.,>;...' ,-,", (}\ . ,; r--.. '\:J;:.-...' ", Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1814 CIVIL TERM Helen L. Crouse a/kla Kelly Course, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Complaint in Divorce filed in the above captioned case upon Helen L. Crouse, by certified mail, return receipt requested on March 29, 2006 addressed to: Helen L. Crouse 15309 Ridge Road Waynesboro, PA 17268 and did thereafter receive same as evidenced by the attached Post Office receipt card dated April 5, 2006. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES 94 ~c- Date c '" Galen R. Waltz, Esquir 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery 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 mailpiece, or on the front If space permits. 1. Article Addressed to: He~en l.CrCOSe \ 1)3::>9 \2.,o1}(dh1d \)0~y(\e~o) ~(l 1, Q08 2. Article Number (Transfer from WVIce I8beI) PS Form 3811, February 2004 A. Signature ~ L c.....-..~ 8, Received by ( Printed Name) H-d en 00 u..4L. 0, Is delivery address different from item 1? If YES, enter delivery address below: 3. ... Sej:Yice Type ~ Certified Mail 0 Express Mall o Registered .BAetum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7001 2510 0009 2826 9767 ~Ic Return ReoeIpt 1 02595-02-M-l, ('") t---> c:::..} 1.._J C C:,";:l 11 s:: c""'\ -0 CO if} :.? nl r< f""': In E -'7JI" :r,l .c.~.~ ,,' Z N I" ~ 'J,> Q ~".,~'" ~ ~ t~] ',-~;J , ...,..,,: 0 ::r~.. .." , ,r- :-.Jt Z ) .> 0 .' , rn c: \{J ,-,../ ~ :J~1 ::1:1 -, -< II Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1814 CIVIL TERM Helen L Crouse a/k/a Kelly Course, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 9330 1 (c) of the Divorce Code was filed on March 29,2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. ~-IAf ~o /AtXl6 Date I I' ~CJr:~ Mike ouse () G; ufi~, ITlp. .~/< ",. ~;., ~~> :1i~~: ~? "':w"i --< ,...." c::::> = 0'" c.I? j"t., -0 N -.J o 'T1 ~-n mfTi :gO ~'~*i ':>-0 "-m C:J --I ~ =< ;pa ::g '-" .. -.J II Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1814 CIVIL TERM Helen L Crouse a/kla Kelly Course, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 (Q) 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 with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. J~ 06/~~06 Date tl!j. h (;}- C~ Mike Cr se r-..> = 0:-= c:>"'> (/) rr1 V o -n :i! mil -oFTi :09 :::.;.c ~.2~~ '::} (') ,o"rn -.) ---1 ):> Xi -< N -.J :l> :3: If? -,I II Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1814 CIVIL TERM Helen L. Crouse a/k1a Kelly Course, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on March 29, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. q-d.-O-OU Date '-1~~ L ~~-O~ Helen L. Crouse () c ..,... ~ "L) CD IT1 r1~ 5i. ~~~- ~~ ~. ~,~, ~:~-; ~.......; ~:;.~~.. :::--1 -<. ,...., = = <::T" (/) 1'1 -0 ~ ~-n rn-" -ofT; -IJO ;~)i-\ ~'''-. , -1"\ :.-SS :-!:~ '-.-.0 ;::"rn o .~ ~ N -J :P" :x \..Q .. -.J II Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1814 CIVIL TERM Helen L. Crouse a/k1a Kelly Course, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST gNTRY OF A DIVORCE DECREE UNDER ~ 3301 ~ 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 with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. s - d-.O - ou Date .~ L ~Q0V~ Helen L. Crouse (") r- 'h ~s U("n ell r7 ( ~7,; r:;~'~ u'> --,,';' ,"" .c- ,7:~: t~ .~~ ....... .-( -.J f"-.J C;:;) = ~ (/) rr, V N ~ :b> ::;: o ., 5i! fn :n r- -.-.m :r''JQ C) f ~~:10 ;J::n , )~- '70(") om -..f :::t> :J:J -< \.0 I' Mike Crouse, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1814 CIVIL TERM Helen L. Crouse a/k1a Kelly Crouse, Defendant : CIVIL ACTION - LAW : 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: 1. Ground for divorce: irretrievable breakdown under 9 (3301 (c)) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of Service, by Helen L. Crouse, Defendant, Certified Return Receipt Requested Mail delivered on or about April 5, 2006. 3. Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce Code. By Plaintiff: September 26, 2006 By Defendant: September 20, 2006 4. Related claims pending: None. Date the Waiver of Notice in 93301 (c) divorce was filed with the Prothonotary: By Plaintiff: September 27,2006 By Defendant: September 27,2006 (') c S ''''lC n;:'!~' ~ ~>,,~" r;:.: , '~(.'.) ):> c: -7 =3 .-..~ ,...., = = c;ro C/) rr1 -0 N -J o -n ~:D rn- -oF. :-99 ~~~:J ~~ --;~ --{', ~=~? ~ ~ 'J> ~ :x:so ::P:': UJ .. -.J ;+; ;+; ;+; lti lti lti ltilti ;+;;t; ltilti lti lti ;t; ltilti lti f€ lti lti f€f€ f€f€f€f€f€f€f€f€f€ f€f€ f€ ltif€f€ f€ ;t;f€if.f€ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Mike Crouse Plaintiff VERSUS Helen L. Crouse a/k/a Kelly Crouse Defendant PENNA. ;t;if."'if. if. if. if. if. if. ;t; if. if. if. if. if. if. if. AND NOW, OchJ I:. tV- ,,-- ,2006 , IT IS ORDERED AND if. if. Mike Crouse if. DECREED THAT , PLAINTIFF, if. if. if. AND Helen L. Crouse a/k/a Kelly Crouse , DEFENDANT, if. if. No. 06-1814 DECREE IN DIVORCE 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; Ai ov € Am ~ ~ Co PROTHONOTARY if. if. if. if. J. if. if. if. if. if. if. if. if. if. f€ ~~~~~~~~~~~~~~~~~~~~~~~~ if. if.if.if. if. if. if. if.if.if.if. if. if. if. if.;t; if.if.if.if.if.if.;t;if. if.if.if. if. if. if. if. if. if. if. if. ;:fy P' ~ ~ '7~' II ,,?/ W i?:3 ~ Me yr{J %7' )/17/ .~ .~ .... .. . .. ..... "