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Home My WebLink About00-00905 ... REVENNA C. BARRICK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2000- tJO,S' CIVIL TERM HARRY C. BARRICK, 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 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 Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 -' REVENNA C. BARRICK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- q{J~ CIVIL TERM HARRY C. BARRICK, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301 IC) AND 3301 (0) OF THE DIVORCE CODE 1. Plaintiff is Revenna C. Barrick, an adult individual who currently resides at1441 Cockleys Meadow Drive, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant is Harry C. Barrick, an adult individual who currently resides at 455 Center Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 29, 1964, in Cumberland County, Pennsylvania. COUNT I - DIVORCE UNDER SECTIONS 3301 (c) AND 3301(d) OF THE DIVORCE CODE 5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above. 6. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States. , , , 8. Plaintiff avers that the marriage between the parties is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. COUNT II -EQUITABLE DISTRIBUTION 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. 11. The parties have acquired real and personal property, including real estate, automobiles, bank accounts, interests in businesses and other items of miscellaneous property during tne course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. COUNT III - ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES. COSTS AND EXPENSES 12, Plaintiff hereby incorporates by reference all of the averments in paragraphs 1 through 11 of this Complaint. 13. Plaintiff has employed counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. d II Ii L i ,. , ! " if' 14. Plaintiff is unable to sustain herself during the course of this litigation. i ~ ~: WHEREFORE, Plaintiff requests your Honorable Court to enter an award of ~: alimony pendente lite and to further award such additional counsel fees, costs and expenses as are deemed appropriate. Respectfully submitted, O'BRIEN, BARIC & SCHERER Date: 2.-. 10. 1>00 ~I(.~~ Michael A. Scherer, Esquire 1.0. #61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/divorce/barrick.com VERIFICATION I verify that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. JZM/Y'la, C! el~~ Revenna C. Barrick Date: d-q-no <:::! () co ). :>0 ~ ';;:j m ~ ~ z '" r;: co :; r:;;; --l > t! ?; 0 :::0 0 L C _ ..,., ~ -I ~ R r- ;; R- D:: ;:: :I C/l z ~ ~ :> -I ::c - m " :>0 o m w :>0 , , ~ ~ ~' Rf \Ii; .~~ i z0 'a. -f: ".,. . o~i, :ti~~ Q. . ~.~.~ ~~;~ '(. :& \ ' - . . ,~ ~. ~ ~ ~ ~ ~ '\ ~ VI, ~ ......... CA. ~~~ ~ G I;:>,h .1 SJ ~~iA !c- r, \.' \j. j ~;~ v ~ );:'c S;1 !. . \ ~ '~k~ t( ~ , i -r,,? C'.. .' " ' , ;;:-J " ;'; "::] u; . ? :~~~ ~~~? ~~i'~ ~ Xl -< ~a Ul f'.:> '~,~ ,. . . I SHERIFF'S RETURN - REGULAR CASE NO: 2000-00905 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BARRICK REVENNA C VS BARRICK HARRY C BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon BARRICK HARRY C the DEFENDANT at 0010:06 HOURS, on the 15th day of March 2000 at 455 CENTER ROAD NEWVILLE, PA 17241 by handing to HARRY C. BARRICK a true and .attested copy of COMPLAINT - DIVORCE together with NOTICE (REINSTATED) and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 7.44 .00 10,00 .00 35,44 S~~~~ R. Thomas Kline Sworn and Subscribed to before 03/15/2000 0' BR'::' 7:i;) h:""R . w,r~ . Deputy Sheriff me this f., ~ day of ~:l<nrO A.D. q';tLa~ # r thonotary , '/,' , ~ . ~,' , .' -, " . -, -, ,'" .-., ';;-~,' , "",;.- ""-_'"i' ~I ",.,,,'" ..',0 "~.,,"'''-'''-~-', , -'.1;, '" ~,;<-d'~',''''''- "'. ~ ~V&1nh (. !Jb.rr,e.!c. .P/q..~J.., 1+ In the Court of Common Pleas of Cumberland County, Pennsylvania V$. /'fArr, (. fSArr.L. Ie.. P-4c...d 4-._ f-- N 2o!>'-Cto~ O. I Civil. 19 7? f7...I.C' f(2P 17-1 () N.!) rA~ jQroul'-j (-GiroJ h h. rfh'C.. d;"or~ ,,,....,, /~:_ \- ,.~ 1l:)- -"^, ~ .J-<-. , To ProthonoUlry 19 ~!~~ Attorney for Plaintiff '. ~ ~ .. ~ ~ I ! f, [ !. ~: ~ I. f I' I' t: I I ~j ~ I , i ! " " I ~ idllII' "" ~ j' ." '.- " -I.. FILED-OFFICE F -',~ --'--1' '''''','nTARY o ! h.- :'~;"i) r-,\..d -!...." II"'" 00 NM I 4 flll 8: 37 CUI"",r:::.! /''.T; '-'()Ui~!n' 1~/JL.......1 ,,~..r<, ,.... 1...1.... I ~ PENNS\lVANIA u No. Term, 19 vs. PRAECIPE Filed 19_ , Atty. . ~ ,,, , ~'"", ""-,,. ~.. ,~ "~ "~'",.,-~~.." .'<,..;"I~"",:"-', ,-_''-, ~ REVENNA C. BARRICK, PlaintifflPetitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS, CIVIL ACTION - DIVORCE HARRY C. BARRICK, DefendantlRespondent NO. 00 - 905 CIVIL TERM IN DIVORCE DR# D29,573 PacseS# 221102208 ORDER OF COURT AND NOW, this 13th day of April, 2000, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav onMav 1. 2000 at 9:00A,M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.IHei (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge ..n Date of Order: Auril13. 2000 fR' ~ '"!.~::::u YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU, 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 MAY GET LEGAL HELP. Petitioner < Respondent Michael Scherer, Esquire CUMBERLAND COUNTY BAR ASSOCIATION 2LIBERTY AVE. CARLISLE, PENNSYL V ANlA 17013 (717) 249-3166 . O~( " /'J,;tf;.{ (\0 ~,pq \ 1 u t',~ h . ,~", .... - \- ;'l"\ ,i: :-):) ClltfIBEJiEf,"'\0 COUNT{ PENNS'ILW\N\i\ ~ ., . .. " '. REVENNA C. BARRICK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-905 CIVIL TERM HARRY C. BARRICK, Defendant CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes Plaintiff Revenna C. Barrick, by and through her attorney, Michael A. Scherer, Esquire, and respectfully represents as follows: 1. Plaintiff, Revenna C. Barrick, is an adult individual who resides at 1441 Cockleys Meadow Drive, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant, Harry C. Barrick, is an adult individual who resides at 455 Center Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff's Complaint In Divorce containing a claim for alimony pendente lite was filed on February 15, 2000. 4. The Plaintiff is employed at Ashcombe's in Mechanicsburg, Cumberland County, Pennsylvania and at the rate of $7.00 per hour at the rate of 38-40 hours per week. 5. The Defendant is self-employed and earns a substantial income through retail sales and rental income. . 6. Plaintiff requires alimony pendente lite in Order to prosecute this action and to maintain herself during the pendency of this litigation. i ."'-'. -.', ,__O""."'_~_"" : <' " . WHEREFORE, Plaintiff is in need of alimony pendente lite in order to sustain herself and to meet her financial obligations during the pendency of this divorce. Respectfully submitted, O'BRIEN, BARIC & SCHERER ~~re I.D. #61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 i . "~ JAN-27-00 THU 03:09 PM .' "" ,- 0' ~'"H"..'- 'J,' ., ; \,',' ,- .,'{,-'.' ",~..' ~. CUMB CTY DRO FAX NO. 717 240 8248 p, 01 " '.- .' IN THE COlffiT OF COMMON PLEAS OF CUMBERl,AND COUNTY, PENNSYLVANIA REVENNA C. BARRICK Plaintiff 2000-905 NO. v, CIVIL ACTION - LAW !N DIVORCE HARRY C. BARRICK Defendant PRS ATTACHMENT POR APL PROCEEDINGS PETITIONER NAME Revenna C. Barrick ADDRESS \~1.~ Coc~~eYs Mea~~w ~~~ve B . ,~~ .,~" _ .. ,;'in>; ..~ BIRTH DATE: May 23, 1946 SOCIAL SECURITY NUMBER 172-36-0509 HOME PHONE (717) 766-7611 WORK PHONE (717) 258-4624 EMPf"OYER NAME Ashcombe's EMPLOYER ADDRESS 906 Grantham Road Mechanics-hurn P"nn"v1,,~~'~ ,-~ JOB TITLE/POSITION Sales Associate DATE EMPLOYMENT COMMENCED May 1, 1998 GjWSS PAY $273.00 per week NET PAY $223.86 OTHER INCOME None ATTORNEY'S NAME Michael A. Scherer, Esquire A"I'TORNEY' S ADDRESS O'Brien's~aric & Scherer 17 West outh S;':;:;;;,.1;",0 D. 1 ATTORNEY'S PHONE NUMBER ( 717) 249-6873 013 '~_"W~~""""~'~_"""'."""""""'""""""'__'~""""_""_'-"--"'___ JAN-27-00 THU 03: 10 PM ,", '< . "'~-:"-~ i_~' ,_. -:,. , -," ~,; I", _: ,,",,;;' ~- , CUMB CTY DRO , P. 02 .. RESPONDENT NAME Harry C. Barrick ADDRESS 455 Center Road Newville. PennRV'''~-'- 17741 BIRTH DATE February 1 , 1943 SOCIAL SECURITY Nl~BBR 197-34-2155 HOME PHONE (717) 776-5762 WORK PHONE (717) 776-5762 EMPLOYER NAME Barrick Tire Sales E:1JlPLOYBR ADDRESS 455 Center Road 1'7')41 Newville. PennRvlvan;~ JOB TITLE/POSITION Self-Employed DATE EMPLOYMBNT COMMENCED 1965 GROSS PAY UNKNOWN NET PAY UNKNOWN OTHER INCOME UNKNOWN ATTORNEY'S NAME UNKNOWN ATTORNEY'S ADDRESS UNKNOWN ATTORNEY'S PHONE ~~~BER UNKNOWN MARRIAGE INFORMATION DATE OF tJI.ARRIAGB November 29, 1964 PLACE OF' MARRIAGE Cumberland County, Pennsylvania DATE OF SEpARATION April 22, 1998 ADDRESS OF LAST MARITAL 455 Center Road HOME Newville, Pennsylvania 17241 DESCRIPTION OF DOCUMENT Petition For Alimony Pendente L' RAISING APt CLAIM " DA,E APL DOCUMENT FiLED February 15, 2000 -- te , v_" "..,~.,.",.,c"""""^'''''' '.,';'i"''"''''~''''''''.''''"'''"'_''''''''~''';I'_....,",n'''''' ~.~_, ,," '--~' .,,'-.-.,~:' '/" , ~" -,,---,"--'~;,-, _._ :';, -,<"c,' ~,,<,:,,_-.' ,,' " VERIFICATION I verify that the statements made in the foregoing Plaintiff's Petition For Alimony Pendente Lite 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. Y;Zh\~' C ~'(ll~ Revenna C. Barrick DATED: C? - 'J - 00 ~ ~'- . .. o ,., ,~ ..----- . .:0,.... , . ~ ., I' <:;! i 0; Cl en :::0 15 ;:;; c: :z: --1 >: ~ :I: ~ :I: " > Q z 0 ("l :!) ~ < () m .. ~ ~ '" '" . ~ 5= --1 ("l ~ = "i ~ 0 ~ c:; :::0 , I II C) c:! c:: h- C.::, . , .;::'c~ ,[, r+? ,~~ ~''l1 {PI jI~I~,' C;.:) ','; " ,,,-, :"$ .,L ~--. !~'~~~;-- ~;! c- :2 ( ) --I :.., ::'~":i "" (,..) .~6 ....._<: L L' ,,' ." DR 29,573 PACSES ID 221102208 REVENNA C. BARRICK, Plaintiff/Petitioner vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CIVIL ACTION - LAW HARRY C. BARRICK Defendant/Respondent : NO. 00-905 CIVIL TERM ORDER OF COURT AND NOW, this 20th day of June, 2000, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $1,103.81 per month and Respondent's monthly net income/earning capacity is $3,296.17 permonth, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $1,000.00 a month payable monthly as follows; $877.00 per month for alimony pendente lite and $123.00 per month on arrears. First payment due within five days upon receipt of this order. Arrears set at $3,508.00 as of June 20, 2000. The effective date of the order is February 24, 2000. Husband is to make a lump sum payment of$I,754.00 within five days upon receipt of this order and thereafter monthly payment is due on or before the last day of each month. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.g 3703. Further, ifthe Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Revenna Barrick. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: PASCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's P ACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. ..., L,-~ < ", Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the respondent and 100% by petitioner. The plaintiff is responsible to pay the first $250.00 annually in unreimbursed medical expenses. Petitioner to provide medical insurance coverage. Within thirty (30) days after the entry ofthis order, the Petitioner shall submit written proof that medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist, at a minimum, of: I) the name of the health care coverage provider(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. This Order shall become final ten days after the mailing ofthe notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRG: R. J. Shadday Mailed copies on I(J)-Xl#) to: < Petitioner Respondent Michael Scherer, Esquire BY THE COURT, ~~~ Edgar B. Bayley J. __iiIIiilOliUJr J ""''"'''''=----~Il\lfjlil[''~ :u:,Il>J~~..,-~"< ~ '1iIiI__ ~~~ -~ ...'"'~--~" (,- .... 0 Cl C '::l "-.J ;;"";T -f'i u ru '- ::.=~ ril r' , ---,'. .' ;:.: -'-' ! -- Z ~'-.) ,.. UJ ~. f-_] -' 1'-;' 1_: <- " .-":' C. L ~; C) C',) C'- ""~ en " :<~ Cl :u -c 10 --..~_o . ~, " I- ... In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELAtIONS SECTION REVENNA C. BARRICK ) Docket Number 00-905 CIVIL Plaintiff ) vs. ) PACSES Case Number 221102208 HARRY C. BARRICK ) Defendant ) Other State ID Number CONSENT ORDER AND NOW, to wit, on this 19TH DAY OF MARCH, 2004 IT IS HEREBY ORDERED that theAPL. order in this case be 0 Vacated or <i)Suspended or o Terminated without prejudice or 0 Terminated and Vacated, effective APRIL 1, 2004 , due to: THE PLAINTIFF REQUESTING THAT THE ALIMONY PENDENTE LITE ORDER BE SUSPENDED, EFFECTIVE APRIL 1, 2004. THERE IS NO BALANCE DUE THE PLAINTIFF, DRO: RJ Shadday xc: plaintiff defendant Michael Scherer, Esquire ~"" -ILED t. <,'i1hU ~"..e.~l~_ <.f 3.;;J..t)-O BY JUDGE March 22 )004 Date Service Type M Form OE-503 Worker ID 21005 ,~- ~ _. "''''''-, Revenna C. Barrick 1441 CocIdey's Meadow Or. Boiling Springs, Pa 17007 ... . . .. - March 2, 2004 RE: Case#221102208 R.J, Shadday c/o Domestic Relations 13 N. Hanover St. p.a.Box 320 Carlisle, Pa. 17013 Dear R.J. Shadday: Subject: Discontinuing ~nthly payments Mer careful consideration. I have decided to slop the monthly payments that Harry has been sending to me. I am not I1GW nor do I for-see in the future obtaining a divorce. This and the fact that th~ pay~ have Caused me to pay out more each year in taxes have influenced my decision. My daytime work number is 697-1884 and my home number is 258-4624 if you want to verify that I have made this decision of my free will. I thank you for your attention to this matter. If any anears are due me please see that I receive those, I realize that this may take a few weeks so I am requesting that paytTients stop on April 1 st.. Sincerely yours, Revenl18 C. Banick ".J ~~. ,f'; i" cuvv = .~. ;.u~Iili~~~~_~it~ .4 Mt4. . ,_......","~ ~'" .' ..... ""il~ '-'. S'_C ..30. n-n'e'd o ~; ...,....._- r-(ii- ---,,~ '-- tf,[~~' -,"'- . c--: .:3c: i~'>~ ~ :::,::' '-:..' ~ ~' e_ - - ,.- ..... ~ ~ r-.., "'" co. .c- ~ '-f :::r:~ nl-!..J c- -Of71 :OD OT '---I() -:;: +i 90 i"')rn --=:I "c.....} :b "< ::?-: :::-",.. ...."'~ "'"'J 1'0 W .~ "" G~ II