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MERLE J. CRUMLICII
Plainti tt
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 95- qLH CIVIL TERM
IN DIVORCE
SUZANNE E. CRUMLICH
Defendant
NOTICE TO DBFEND AND CIJAIH RIGHTS
You have been sued in court, It you wish to defend against the claims set forth in
the foregoing pages, you must take prompt action. You are warned that if you fail to do'
50, 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 the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling, A list of marriage counselors is
available in the OffLce of the Prothonotary at:
Office of the Prothon()tary
Cumberland County Court House
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 IIAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPIIONE TilE OFFICE SET FORTH llEWW TO FIND OUT WHERE YOU
CAN GET LEGAL HEIJP,
Court Administrator, ~'ourth Floor
cumberland County Court House
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
l
MERLE .1, CRUMLICII
Plaintiff
IN TilE COURT OF COMMON Pl,EAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
SUZANNE E. CRUMLICH
Defondant
CIVIL ACTION - LAW
NO. 95- (1'1'1 CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTION 330I(c) OR 3301(d) OF THE DIVORCE CODE
AND NOW comos the above-named Plaintiff, MERLE .1. CRUMLICH, by his attorneys,
Andes, Vaughn & Bangs, and makes the following Complaint in Divorce:
1. The Plaintiff is MERLE J. CRUMLICII, an adult individual IIho currently resides
at 364 Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is SUZANNE E, CRUMLICH, an adult individual who currently
resides at 364 Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of
this Complaint.
4, The Plaintiff and Defendant were married on 17 July 1964 in Mechanicsburg,
Pennsylvania,
5. There have been no prior actions of divorce or annulment between the parties.
6, This marriage is irretrievably broken.
7, Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to partici-
Ipate in counseling.
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8, The Plaintiff requests this Court to enter a Decree of Divorce,
III1RRBFORB, Plaintiff requests this Court to enter a decree in divorce pursuant to
the Divorce Code of Pennsylvania,
I verify that the statements made in this Complaint are trlle and correct. I
understand that any false statements in this Complaint are sUbject to the ponalties of
18 Pa, C.S. 4904 (unsworn falsification to authorities),
;'~7''l.)
Date
J 1>>d/~
HERI,E J. ti(UHLICII
ANDES, VAUGIlN & BANGS
r~~~Q
Samuel L. Andes
Attorney {or Plaintiff
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