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HomeMy WebLinkAbout06-3739STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 211-4436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW RICHARD S. CRAMER, : NO. 06 - 2739 _ CIVIL TERM Defendant : IN DIVORCE NOTICE 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 in 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 rights important to you, including custody or visitation of your children. When the ground for 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 17013. 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 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, Pennsylvania 17013 717-249-3166 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF PATRICIA & CRAMER, Plaintiff v. RICHARD S. CRAMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW j? CIVIL TERM : NO.06 - RCE : IN DIVO COMPLAINT IN DIVORCE PURSUANT TO SECTION 33010 OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Patricia A. Cramer, an adult individual residing at 135 Lower Bailey Road, Duncannon, Perry County, Pennsylvania 17020. 2. The defendant is Richard S. Cramer, an adult individual residing at 5 South Market Street, Duncannon, Perry County, Pennsylvania 17020. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on January 24, 1976, in North Royalton, Ohio. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. 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. Section 4904, relating to unswom falsification to authorities. 2006 A - C ^O?` Patricia A. Cramer, Plaintiff WOLF & WOLF Yl C? ,2006 BY: STACY B. OLF, ESQUIRE Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff r?? ?,? ?? .-{ L -y . "?,. ? ? J ? ? :. O ?- rry r? -.? _h V ?.?, ?` _' STACY R. WOLF, ESQUIRE ATTORNEY In NM 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, Plaintiff v. RICHARD S. CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06 - 3729 CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotarys Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. - , 2006 Patricia A. Cramer, Plaintiff ?_, (:..3 '.7 C? --I C.J ?i ? ?? C? ? -• ? ? 17 J?? -' +_ _ _ri :.i t STACY B. WOLF, ESQUIRE ATTORNEY In NO. 89732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF PATRICIAA. CRAMER, Plaintiff v. RICHARD S. CRAMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06-J??3 CIVIL TERM IN DIVORCE DEFEND NTIS MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly swom according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotarys Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. CS. Section 4904 relating to unswom falsification to authorities. 2006 z el, endant RECEIV ED JUL 0 3 I* n, CJ C 4 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PATRICIAA. CRAMER, Plaintiff v. RICHARD S. CRAMER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO.06- 3237 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE I, Richard S. Cramer, certify that I am the defendant in this matter. Furthermore, I hereby certify that on :T&, L? 2006, I received a certified copy of the divorce complaint filed in this action. 2006 am /???? G'?as*Pr Defendant RECEIVED JUL 03 cn t fir, .< PATRICIA A. CRAMER, Plaintiff V. R. SCOTT CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06 - 3739 CIVIL TERM IN DIVORCE STIPULATION FOR THE ENTRY OF DOMESTIC RELATIONS ORDER sT AND NOW, this day of :Ta n i/a r y , 2008, the parties, Patricia A. Cramer, Plaintiff, and R Scott Cramer, Defendant, do hereby Agree and Stipulate as follows: 1. The Defendant, R. Scott Cramer (hereinafter referred to as "Member") is a member of the Perry County Employee Retirement System (hereinafter referred to as "Plan"). 2. Member's date of birth is July 18, 1948, and his Social Security number is 206-38-8172. 3. The Plaintiff, Patricia A. Cramer (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is July 13, 1949, and her Social Security number is 300-42-9716. 4. Member's last known mailing address is: 5 South Market Street Duncannon, PA 17020 5. Alternate Payee's current mailing address is: 135 Lower Bailey Road Duncannon, PA 17020 It is the responsibility of Alternate Payee to keep a current mailing address on file with the Plan at all times. 6. The Alternate Payee is entitled to all of the Member's benefits under the Plan as set forth below. The Plan is hereby directed to pay all benefits directly to Alternate Payee. 7. The Member is currently receiving a monthly annuity for his lifetime pursuant to the terms of Option 4C. The parties acknowledge that the Member's retirement option election is final and irrevocable. 8. The Alternate Payee is awarded 100% of the Member's gross monthly annuity together with the Option 4C survivor annuity. The Alternate Payee shall receive 100% of any scheduled or ad hoc increase that is applied to Member's gross monthly annuity. 9. Payments to the Alternate Payee shall commence as soon as administratively feasible on or about the date the Plan approves a Domestic Relations Order incorporating this Stipulation and Agreement. 10. Payments shall continue to Alternate Payee for the remainder of the Member's lifetime. 11. If the Member dies before the Alternate Payee, the Alternate Payee shall be provided a survivor benefit in accordance with Option 4C elected by the Member upon his retirement. Member reaffirms his selection of Alternate Payee as his survivor annuitant and waives his right to select a new survivor annuitant by reason of his divorce from the Alternate Payee. 12. If the Alternate Payee dies before the Member, the Alternate Payee's share of the Member's pension shall QL=. 13. Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to the Plan, which will authorize the Plan to release to Alternate Payee all relevant information concerning Member's retirement account. Alternate Payee shall deliver the authorization to the Plan which will allow the Alternate Payee to check that she has been and continues to be named as the survivor annuitant under Option 4C. 14. The Plan shall issue individual tax forms to Alternate Payee for amounts paid to her. 15. In no event shall Alternate Payee have greater benefits or rights other than those which are available to Member. Alternate Payee is not entitled to any benefits not otherwise provided by the Plan. The Alternate Payee is only entitled to the specific benefits offered by the Plan as provided in this Order. 16. It is specifically intended and agreed by the parties hereto that this Order. (a) Does not require the Plan to provide any type or form of benefit, or any option not otherwise provided; (b) Does not require the Plan to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living or increases based on other than actuarial values. 17. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 18. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment shall require the Plan to provide any type or form of •! . V benefit, or any option not otherwise provided by the Plan, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. 19. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon the Plan immediately. The Domestic Relations Order shall take effect immediately upon the Plan's approval and the Plan's approval of any attendant documents and then shall remain in effect until further Order of the Court. WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. BY THE COURT N?o,?X M IN C-A a^>- Plaintiff/Alternate Payee Attorney f Plaintif /Ake ayee J. eWitness for Defendant/Member 2 rra c? -n IL STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, Plaintiff v. R. SCOTT CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06 - 3739 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about June 30, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. f, 2008 R. S OTT CRAMER r?a Kw CID X m; r r+`t 33 i ?' STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, Plaintiff v. R. SCOTT CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06 - 3739 CIVIL TERM IN DIVORCE 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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: :3 c2- (967 9' SCOTT C 2 NC 'C7 cacr ? rT C ?E ? r1` ?M Y # L -a _1 u ? FEB 0 5 2008 y' PATRICIA A. CRAMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW R. SCOTT CRAMER, : NO. 06 - 3739 CIVIL TERM Defendant : IN DIVORCE STIPULATION FOR THE ENTRY OF DOMESTIC RELATIONS ORDER sT AND NOW, this day of :Ta,? vary , 2008, the parties, Patricia A. Cramer, Plaintiff, and R. Scott Cramer, Defendant, do hereby Agree and Stipulate as follows: 1. The Defendant, R Scott Cramer (hereinafter referred to as "Member'') is a member of the Perry County Employee Retirement System (hereinafter referred to as "Plan"). 2. Member's date of birth is July 18, 1948, and his Social Security number is 206-38-8172. 3. The Plaintiff, Patricia A. Cramer (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is July 13, 1949, and her Social Security number is 300-42-9716. 4. Member's last known mailing address is: 5 South Market Street Duncannon, PA 17020 5. Alternate Payee's current mailing address is: 135 Lower Bailey Road Duncannon, PA 17020 It is the responsibility of Alternate Payee to keep a current mailing address on file with the Plan at all times. 6. The Alternate Payee is entitled to all of the Member's benefits under the Plan as set forth below. The Plan is hereby directed to pay all benefits directly to Alternate Payee. 7. The Member is currently receiving a monthly annuity for his lifetime pursuant to the terms of Option 40 The parties acknowledge that the Member's retirement option election is final and irrevocable. 8. The Alternate Payee is awarded 100% of the Member's gross monthly annuity together T with the Option 4C survivor annuity. The Alternate Payee shall receive 100% of any scheduled or ad hoc increase that is applied to Member's gross monthly annuity. VI i"'i N3 ? 'Z d L- 93J 8802 A) *j uivU j, `-?d 3H I t JO D'Dil ID C.,i iLl 9. Payments to the Alternate Payee shall commence as soon as administratively feasible on or about the date the Plan approves a Domestic Relations Order incorporating this Stipulation and Agreement. 10. Payments shall continue to Alternate Payee for the remainder of the Member's lifetime. 11. If the Member dies before the Alternate Payee, the Alternate Payee shall be provided a survivor benefit in accordance with Option 4C elected by the Member upon his retirement. Member reaffirms his selection of Alternate Payee as his survivor annuitant and waives his right to select a new survivor annuitant by reason of his divorce from the Alternate Payee. 12. If the Alternate Payee dies before the Member, the Alternate Payee's share of the Member's pension shall o he Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to the Plan, which will authorize the Plan to release to Alternate Payee all relevant information concerning Member's retirement account. Alternate Payee shall deliver the authorization to the Plan which will allow the Alternate Payee to check that she has been and continues to be named as the survivor annuitant under Option 4C. 14. The Plan shall issue individual tax forms to Alternate Payee for amounts paid to her. 15. In no event shall Alternate Payee have greater benefits or rights other than those which are available to Member. Alternate Payee is not entitled to any benefits not otherwise provided by the Plan. The Alternate Payee is only entitled to the specific benefits offered by the Plan as provided in this Order. 16. It is specifically intended and agreed by the parties hereto that this Order. (a) Does not require the Plan to provide any type or form of benefit, or any option not otherwise provided; (b) Does not require the Plan to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living or increases based on other than actuarial values. 17. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 18. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that no such amendment shall require the Plan to provide any type or form of ,L'* ,* T benefit, or any option not otherwise provided by the Plan, and further provided that no such amendment or right of the Court to so amend will invalidate this existing Order. 19. Upon entry as a Domestic Relations Order, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon the Plan immediately. The Domestic Relations Order shall take effect immediately upon the Plan's approval and the Plan's approval of any attendant documents and then shall remain in effect until further Order of the Court. WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. Plaintiff/Alternate Payee Attorney f Plaintif /Ahe ayee Witness for Defendant/Member BY THE COURT r.3 nm c CJ .._ ? VV' STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, Plaintiff V. R. SCOTT CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 06 - 3739 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about June 30, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. 2008 ? -Ca - Q, PATRICIA A. CRAMER rv -; STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, Plaintiff' V. R. SCOTT CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 06 - 3739 CIVIL TERM IN DIVORCE 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 m this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: Z 1101 4t PATRICIA A. CRAMER C? ?a t;; ?° C7 T1 ' w t- • ? =;? ? Ct? fI3 , ?: y C, ?. r- ? _.; ?;. f S•; , ? C: ? ? : ? " . A ? STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF PATRICIA A. CRAMER, Plaintiff V. R. SCOTT CRAMER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 06 - 3739 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about July 1, 2006, defendant was served with a copy of the divorce complaint. (See Acceptance of Service previously filed July 5, 2006) 3. Complete either paragraph (a) or (b)c (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: February 10, 2008. By the defendant: January 31, 2008. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b) (2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary. February 11, 2008. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary. February 4, 2008. .//,? February- k2008 STACY B. OLF Attorney for Plaintiff 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ir4h STATE OF PENNA. Patricia A. Cramer VERSUS R Scott Cramer No. 2006 DECREE IN DIVORCE AND NOW, Z Za°O IT IS ORDERED AND Patricia A. Cramer DECREED THAT , PLAINTIFF, AND KScott Cramer 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; The Marital Settlement Agreement dated October 9, 2007 is incorporated herein by reference but is not merged into this Decree. BY THE COURT: ATTES v J. ' 7 PROTHONOTARY A'r -46V 5o- i?