The URL can be used to link to this page

Home My WebLink About07-0535TRACI NICOLE BERI, Plaintiff vs. STEVEN ROBERT BERI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2007 -535 CIVIL TERM CIVIL ACTION -LAW DIVORCE NOTICE TO DEFEND RIGHTS Yo~~ 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 maybe 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 at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 A 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. Pennsylvania Lawyer Referral Line Lawyer Referral Services Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 TRACI NICOLE BERI, Plaintiff vs. STEVEN ROBERT BERI, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2006 - =~ ~ s~ CIVIL TERM CIVIL ACTION -LAW DIVORCE COMPLAINT UNDER SECTION 3301(c OR 3301fd1 OF THE DIVORCE CODE NOW comes Plaintiff and for cause of action against Defendant who says: 1. Plaintiff is Traci Nicole Beri, who resides in CMR 402 ,Box 1048 ,APO AE 09180 with street and mailing address of CMR 402, Box 1048 ,APO AE. 2. Defendant is Steven Robert Beri, who resides in Shippensburg, Cumberland County, Pennsylvania, with a street and mailing address of 23 College Park, Shippensburg, Pennsylvania 17257. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this complaint. 4. Plaintiff and Defendant were married on April 11, 2003, in Philadelphia, Pennsylvania. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. The marriage is irretrievably broken. 6. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the court to require the parties to participate in counseling. 8. Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The causes of action and sections ofthe Divorce Code under which the Plaintiffis proceeding are: A. Section 3301(c): The marriage is irretrievably broken. B. Section 3301(d): The marriage is irretrievably broken and the parties have been living sepazately and apart since January 20, 2006. If the parties do not agree to proceed under Section 3301(c) of the Divorce Code, then Plaintiffwill submit an Affidavit alleging that the parties have lived sepazately and apart for at least two (2) yeazs and that the marriage is irretrievably broken, once the parties have lived sepazately and apart for two years, being January 20, 2008. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a Decree of Divorce, divorcing the parties from the bonds of matrimony. Respectfully Submitted, .~ ~~=- - - Aazon J. Neuharth, Esquire Attorney for Plaintiff, Traci N. Beri Neuharth Law Offices 232 Lincoln Way East Chambersburg, PA 17201 (717) 264.2939 VERIFICATION I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~Q jA~ D'~- - Traci Nicole Beri WITH U.S. ARMED FORCES EUROPE LANDSTUHL, GERMANY TRACI NICOLE BERI, known to me by presentation of a military identification card, subscribed before me, Helen Howard, a military notary with General Power of Notary Public, Title 10, United States Code, Section 1044a, which also states that no seal is required on this acknowledgment on 10 January 2007. HELEN HOWARD SFC, USA My Commission is Indefinite '~ ~. ~ ~ ~~ ~~ ~ ~ ~ ~ ~ ~, ~ ~ ~ cN ~ ii~' ~~ ~_ '~ ~~ ~ ~ ~, . =~ - . ~~ Cl1 ~ ~~ !r r-- - i :_ .. ~.~ -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACI NICOLE BERI, :Civil Action -Law Plaintiff v. F.R. No. 2007 - 535 STEVEN ROBERT BERI, Defendant : In Divorce a.v.m. Affidavit of Service I, Paul M. Ferguson, of the Neuharth Law Offices, hereby state that on January 31, 2007, the defendant, Steven Robert Beri, accepted service of the Divorce Complaint in the above-captioned matter at the offices of the undersigned as evidenced by the attached Acceptance of Service executed by said Defendant. (See Attached Exhibit "A"). ~ ~~ ~y~!s'~ Paul M. Ferguson Neuharth Law Offices P.O. Box 359 Chambersburg, PA 17201 (717) 264-2939 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACI NICOLE BERI, :Civil Action -Law Plaintiff vs. STEVEN ROBERT BERI, Defendant F.R. No. 2007 -535 In Divorce a.v.m. ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint under Sections 3301 (c) or (d) of the Divorce Code filed in the above-captioned matter on January 26, 2007. d Date Steven Robert Beri 23 College Park Shippensburg, PA 17257 Exhibit A o "~? la:) ~ rn S"~'; C't'1 C.D .. ~ . ~ ~ ~ F ' ~' .~ r ~ d ~ y ,. ! fiJ G7 ~ t TRACI NICOLE BERI, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW F.R. No. 2007-535 STEVEN ROBERT BERI, Defendant : In Divorce a.v.m AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 26, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. § 4904 relating to unsworn falsification to authorities Date: !d D -~ Steven Robert Beri ~• 1 TRACI NICOLE BERI, Plaintiff v. STEVEN ROBERT BERI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW F.R. No. 2007-535 In Divorce a.v.m WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) 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 I this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ( 0 V~~~ Steven Robert Beri c~ ~ c7 ~ ~ -~, , _~ L~ "'"t _ - ' r~ l -'~ .~.r R: ~ C.J • 4 / TRACI NICOLE BERI, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW F.R. No. 2007-535 STEVEN ROBERT BERI, Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 26, 20057. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. § 4904 relating to unsworn falsification to authorities Date: ~'~ t-'~~`{ ~'UC%'~" Traci Nicole Beri ~ r-a r.~ ~ `~ . `~ ~ ~ ~x {~ ~_z~ -"~ -~ ~-'~- L o ~ --` 'L" (^i ~T ..{ TRACI NICOLE BERI, Plaintiff v. STEVEN ROBERT BERI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW F.R. No. 2007-535 In Divorce a.v.m WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE 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.s 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 I this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: ~~ !~ ~00'~ Traci Nicole Beri C c.a°- ~ -~, ~ .~ ` :::c ~-rc ~ ~ ~:~ a ..<~ ~ ~ ~c`~~ ~ cJ'3 ~ o TRACI NICOLE BERI, Plaintiff v. STEVEN ROBERT BERI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIIL ACTION -LAW F.R. 2007-535 In Divorce a v.m. 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 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the complaint on January 31, 2007. 3. Date of execution of the Affidavit of Consent required by 3301 (c) of the divorce code: by Plaintiff: May 21, 2007; by Defendant: May 10, 2007. 4. Related claims pending: None 5. Date Plaintiff s Waiver of Notice in 3301 Divorce was filed with the Prothonotary: May 30, 2007. Date Defendant's Waiver of Notice in 3301 Divorce was filed with the Prothonotary: May 17, 2007. __,~ _~ .__... Aaron Neuhart , squire Supreme Ct. ID# 202303 Neuharth Law Offices 232 Lincoln Way East P.O. Box 359 Chambersburg, PA 17201 (717)264-2939 r-a Q ~ ~~ ~ ~~. ~ ~ cF~; ~" p' ~~ ~ rn ~~'~ p I N T'H E COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TRACT NICOLE BERT, -~'' Plaintiff VERSUS STEVE ROBERT BERT, Defendant No. 2007 - 535 DECREE IN DIVORCE AND NOW ~/t~•ri ~ , ~ IT IS ORDERED AND ~ / Traci Nicole Beri DECREED THAT PLAINTIFF, Steve Robert Beri AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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 BY THE OURT: ~/~ ATT E ~- J . ROTHONOTARY ,~~ ~~ ~ ~'~~ ~ -~v ~~ ~ ~~ L p, ~~