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HomeMy WebLinkAbout94-01738 J J ~ (.j J U' ~ ~! J-- ~i d, ! ! i I ()ol rY) ('- .......... . r~-~-~-~-----~~~---~~-~~~~~-~~~ - . ~ ~ 8 ~ ~ ~ J . RUTH H. CRAWFORD imm .......... ... . ..mm Ii ~ ...!?;\.~.~...~~...~~~~~i{J).~...~R.... ......... ,................. I ~ .... "'''''. ........................l?efendal1.t....... ............ i , l I ~ I ~ ~ ~ i l . ~ j , ~ ft _ ny The Courl: ;1 / / @ A .... J' ," /kL.;.J:::~/1 .c?~ ...t. . ...... ! ~ Ileal: U' J, ~ ~ --------------------------__J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '*' PENNA. ............ ........ .......... ........ .P.1aJI1~g~....... ................. N (). ,~.~~,~,?~.~...... .,?~~,~~...,. 1994 Versus DECREE IN DIVORCE AND NOW, . .. ~~~Y.. . .. ~.l... . ..... . .... 19. ?~.. '. it is ordered and decreed that.... ~~:~.~:. ~~~~?~......, ....,..,.......,.. ...,. plaintiff, and.......,..... .G.^,R,Y, ."!'. .~~"!~~~~~ .~~:,. .. .,.,............ ... 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 ..... ................................ ........ .............., .... ,..... ...... .... II ................ ............... - , . . . . . . . . .. i l . . I . . . l ~ i . ~ . ~ ~ ~ ~ , 8 ~ :;, l:< . . ,\ , - 1~d 1?1d.JM.. 1,/z-, It? tf .iM.4- IN nlE COURT OF ~ PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RUTH M. CRAWFORD. NO. 94-1738 1994 CIVIL Plaintiff vs. IN DIVORCE GARY M. CRAWFORD, JR., Defendant 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: April 8, 1994 via certified mail 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff July 9. 1994 by the defendant July 9, 1994 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) Date of service of the plaintiff's affidavit upon the defendant: N/A 4. Related claims pending: None -- NO CLAIMS PENDING -- . 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code N/A '-- - ~ Lt......., /I. Attorney for Plaintiff BRUCE A. GROVE. JR., ESQ. (717) 763-4167 "''''-'.,-,-,, , i' I I' i, I' , I ":7- 0, - :- ",,'" -T .- 'T-= ..- .:;j ~~: ~::-3: -~;> -I ~ '. . . , .... r-f "" .,-" .1"'-' .. = - ,- :.'1 ~ :::0 -, :",; ~:. ; " , t~ y \ . . '~'/;{tf~~~~>z~;-' 6RUCe A GROVe\~,"jf'-"'~\~.,.'.I. -,' "- /':#~, :j>;'7~J<:'~' ATfOaN"""'I' LAW",:;;;;;",\,;1/!iW;' .'. ,- ,-:..h"-.".:',ifA....,-~ t!1.~~.lH~..'''''..T.l.lj ...... .. -"-""~'~- I ~, . ..~1.~;~.:-- ,,:;l:::~:,I'i\'\h . .' ,},--..".-. "4'4 ' RUTH M, CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW NO. CIVIL 1994 No. qtf- 1738 till;' (t.rlt1 IN DIVORCE GARY M. CRAWFORD, JR., Defendant NOTICE TO GARY M. CRAWFORD, JR. 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 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 at the Office of the Prothonotary in the Cumberland County Court House, 3 South Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. Court Administrator Fourth Floor Cumberland County Court House Carlisle, PA 17013 Telephone: (717) 240-6200 Pa!=le 1 of 1 . ~ . RUTH M. CRAWFORD, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL 1994 IN DIVORCE GARY M. CRAWFORD, JR., Defendant COMPLAINT AND NOW, comes the Plaintiff, RUTH M. CRAWFORD, by her Attorney, Bruce A. Grove, Jr., and files this her Complaint in Divorce against the Defendant, GARY M. CRAWFORD, JR., upon the grounds hereinafter more fully set forth: 1. The Plaintiff, RUTH M. CRAWFORD, is an adult individual and she currently resides at 348 Black Latch Lane, Camp Hill, CUmberland County, Pennsylvania 17011. 2. The Defendant, GARY M. CRAWFORD, JR., is an adult individual and he currently resides at 417 North Third Street, Steelton, Dauphin County, Pennsylvania 17113. 3. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the commencement of this action. , J ! 4. The parties hereto have been separated continuously since September, 1993. S. The Plaintiff and Defendant were married on August 3, 1991, at Marysville, Perry County, Pennsylvania by the Mayor of the Borough of Marysville, PA. ;. v , , Page 1 of 3 , . } L : . ~ 6. There have been no prior actions in Divorce or for Annulment of the marriage between the parties hereto in this or any other jurisdiction, 7. The Plaintiff avers that this action is not collusive, as defined by Section 3309 of the Divorce Code. 8. Neither party to this action in divorce is a member of the Armed Forces of the United States of America or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff or Defendant has the right to request the Court to require the parties to participate in such counseling. The Plaintiff herewith waives her right to request Court Ordered counseling. COUNT I COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 hereof are hereby incorporated herein as if fully set forth. 11. The marriage is irretrievably broken. Page 2 of 3 ~ - WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Dated: April 6, 1994 - -R...,~~ ()~~jr BRUe!E' A, GROVE, JR. I I.D. No. 15502 1513 Cedar Cliff Drive Camp Hill, PA 17011 (717) 763-4167 Page 3 of 3 . . ' ~ VERIFICATION I, RUTH M. CRAWFORD, hereby verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 5 4904, relating to unsworn falsification to authorities. x,lZv-!J1 ~l.P~ RUTH M. CRAWFORD, Plaintiff Dated: April 6, 1994 , ~ * 1~~ . ~ ~~ a; ...~ ~ . ""... IE .~z h'<"t;";J~ C/Q N U:cc.'7 ~-;) ~~ l&:OU_1 ~ h. X,,":)> ~ :),_... _.1 . ~ ... B, ~J N -: :(>- V)"" Q I", ,': _,Ul , .' .~.r.Z 0 . IIJI.J:.t: -...9 &3 u::>> ""W - - r' Xn.. 0: 0.. -- ... 0(.,'\ -=z ~ . , ~ ., ~; RUTH M. CRAWFORD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs, GARY M, CRAWFORD, JR., Defendant CIVIL ACTION - LAW NO. 94-1738 CIVIL TERM IN DIVORCE , , J ; . I Ii J 1 ;! , I ;) 'j ., ;/ VERIFICATION OF SERVICE OF PLAINTIFF'S DIVORCE COMPLAINT ON DEFENDANT I, BRUCE A. GROVE, JR., ESQUIRE, do hereby verify that a copy of the Complaint in Divorce, filed to No. 94-1738 Civil Term, was duly served upon the Defendant by sending the Complaint to his ~~R address of 417 North Third Street, Steelton, Dauphin County, , 1 I I ! Pennsylvania 17113, via Certified Mail No. P415609758, and by depositing the same in the United States Mail, postage paid, at Carlisle, Pennsylvania on April 6, 1994. The said certified articles are attached to this Verification, i , . ; the return receipt card being signed by the Defendant, Gary M. Crawford, Jr., and indicating his receipt of the Complaint to be on April 8, 1994. I verify that the statements made in this Verification are true and correct. r understand that false statements herein are made subject to the penalties of 18 Pa. C. S, !i 4904 relating to unsworn falsification to authorities. Dated: July 18, 1994 Bruce A. Grove, Jr., Esquire 1513 Cedar Cliff Drive Camp Hill, PA 17011 (717) 763-4167 Attorney for Plaintiff -;r en ;c . - r- -t C"") .",., ~ -, -=, ';,.. -.- .- . l-" - . ~ Uf.,.' ~->t -- . . P 4 1 S...l.illl 7 5 8 Receipt for ~ Certified Mal!. . P,ovld.d - x::." No Inlurane,' crn~:rn~tjOn81 Mail - Do not u., Dr laIIr.&m IS.. R.v....1 C.,ttllCtd r.. Spec..l o.l~., f.. ""trCI.d o.llV~ f.. -,. " [";c, ..' :".~."::L.J aj", ~~ j~~;~ ! I \ , I \ I , , " i '. ,. L...-......-" , . i?~Gi3rr~=' ;":c"Ii' -:::- en - ~:- ..~ '": c.,. ~-1't' =- '- ~:~ .. ........ . :Cr';,. .... ..... C"? (':':':) -. :::,., -, '.:" ~~ ~~ , ,.:..,....".... ~; .. ~i ~. ," . RUTH M. CRAWFORD, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94-1738 CIVIL TERM IN DIVORCE Plaintiff '1. vs. GARY M. CRAWFORD, JR., Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT RUTH M. CRAWFORD, Plaintiff, being duly sworn according to law, deposes and says: 1. That a Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 6, 1994. 2. That a certified copy of the Complaint was mailed to the Defendant by certified mail, return receipt requested, on April 6, 1994. 3. That 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. 4. That I understand that the Court maintains a list of marriage counselors in the Cumberland County Prothonotary's Office, which list is available to me upon request. 5. require divorce That being so advised, I do not request that the Court that my spouse and I participate in counseling prior to a decree being handed down by the Court. 6, That I understand that if a claim for alimony, alimony pendente lite, marital property or counseling fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 7. That my marriage with GARY M, CRAWFORD, JR" Defendant, is irretrievably broken. Page 1 of 2 .-j> l-,.~,.;', ,',' iIIIUii";, " .. 8. That ninety days have elapsed from the date of filing the Complaint. 9. That I consent to the entry of a Decree of Divorce on the grounds that the marriage is irretrievably broken. 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, 5 4904 relating to unsworn falsification to authorities. Date: ~/~/cjJl ~7lt~ ;RUTH M. CRAWFORD Plaintiff Page 2 of 2 ....,.~....._"'" -:r c:n --~ or ",.~ -, :c .., ., <- 'I.' ~~? <.: .' .... " .... ., C"'") v, . = '" .... ~,-, => -, ~ ... f ..- DEFENDANT'S AFFIDAVIT OF CONSENT GARY M. CRAWFORD, JR., Defendant, being duly sworn according to law, deposes and says: 1. That a Complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 6, 1994. 2. That I was served with a copy thereof by certified mail, return receipt requested, on April 8, 1994. 3. That 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. 4. That I understand that the Court maintains a list of marriage counselors in the Cumberland County Prothonotary's Office, which list is available to me upon request. 5, require divorce That "being so advised, I do not request that the Court that my spouse and I participate in counseling prior to a decree being handed down by the Court. 6. That I understand that if a claim for alimony, alimony pendente lite, marital property or counseling fees or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 7. That my marriage with RUTH M. CRAWFORD, Plaintiff, is irretrievably broken. Page 1 of 2 .'.' .........-.-."..,-< ,,,- , . 8. That ninety days have elapsed from the date of filing the Complaint. 9. That I consent to the entry of a Decree of Divorce on the grounde that the marriage is Irretrievably broken. I verify that the statements made in this Affidavit are true and correct. I understand that false scatements herein are made subject to the penalties of 18 Pa. C.S. '!i 4904 relating to unsworn falsification to authorities. Date: /:1rtj1 ~~. GARY . CRAW RD, JR., Defenaant Page 2 of 2 ......"---'^"~,. .,."'''''','....0..- "::ro O"l - >-,.. ~- "..- ::t:: o_ r-- .... (V) \~I ' '1 ~'. ., = - ... .. ,0', I,j -' ~ o~, '. .