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Home My WebLink About02-5784Ronald L. Barrick, Plaintiff Paula Sue Freer, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- &"/7~¢ CIVIL TERM : 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 will proceed without you and a decree in divorce or annulment may 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Ronald L. Barrick, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02- ..~'~'~ CIVIL TERM Paula Sue Freet, Defendant : CIVIL ACTION - LAW :IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Ronald L. Barrick, an adult individual, currently residing at 1( CIouser Road, SPUR, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Paula Sue Freet, an adult individual, currently residing at 31 Garden Parkway, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth ol Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on October 16, 1999 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. 9. Plaintiff and Defendant are citizens of the United States of America. The parties have lived separate and apart since September 13, 2002 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties. Respectfully Submitted TURO LAW OFFICES Robert J,,~ulde~'ig, E~s~luir~) 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Date Ronald L. Barrick Ronald L. Barrick, Plaintiff Vo Paula Sue Freet, Defendant · IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- b'--z~'YCIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a tnJe and correct copy of the Divorce Complaint filed in the above captioned case upon Paula Sue Freet, by certified mail, return receipt requested on December 4, 2002 addressed to: Paula Sue Freet 3 Garden Park~vay Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated December 5, 2002. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND 'r'HAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES; OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES Date Robert J. Md'lcrerig, ESquirb---' 28 South Pitt Street Carlisle, PA 17013 (717) 245.-9688 Attorney for Plaintiff Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Po~tage & Fees $ ? Postmark Here i ~ ~nt Name) [] Complete tteme ~. ~ 2 for ~ aewices, ing services (for an extra fee): Complete items 3, 40, and 4b. [] Pdnt your name and address on the reverse of this form so that we can return this card to you. 1. ~,ddressee's Address 13 Attach this fora3 to the front of the mailpiece, or on the back if space does not permit. 2. [~ Restricted Delivery [] Write 'Return Receipt Requested' on the mailpiece below the article number. ~ [](.'~e~veRrete~n Receipt will showto whom the arttcle was delivered and the date '~' ~'' 3. Article Addressed to: .J~,~, 14r ................ ,-~ ~- --t'--J~~-~ I 7001 2510 0009 2827 846 '~, F-~ r~A /~ .ad ~ ~ ~~_~cJrC3 Registered I~'Cert'f'ea ~ ,..,-~, (_-~-v ~. ~ u [] Express Mail [] Insured ~, 7 Date of De ivery ~ -- §. Addresseo's Ad~ress (Onl~ ff r~test~l ~ ~ 6. Signature (Addressee orAgent) PS Form ~1 1, D~*ml~r 1004 102595-9g~B-0223 Dome~c Return Receipt Ronald L. Barrick, Plaintiff Paula Sue Freet, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5784 CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed December 4, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree· I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 Ronald L. Barrick, Plaintiff · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVAN v. · NO. 02-5784 Paula Sue Freet, Defendant · CIVIL ACTION - LAW · IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 4, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 Paula Sue Freet Ronald L. Barrick, Plaintiff Paula Sue Freet, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5784 CIVIL TERM · CIVIL ACTION - LAW 'IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 IN THE FOREGOING 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. 3-5--o3 Date Ronald L ~l~arrick Ronald L. Barrick, Plaintiff Paula Sue Freer, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5784 CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(C) OF THE DIVORCE CODI= 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 l 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 THE FOREGOING 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 Pa~Jl~ ~ .... Freet Ronald L. Barrick, Plaintiff Paula Sue Freet, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5784 CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE 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) §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail on December 4, 2002. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. By Plaintiff: March 5, 2003 By Defendant: March 5, 2003 4. Date the Waiver of Notice in §3301(c) divorce was filed Prothonotary: with the By Plaintiff: March 6, 2003 By Defendant: March 6, 2003 Rob ert ~Ju, ZM'u I d~ei'i'g i Es~re Attorney for Plaintiff IN THE COURT OF COMMON Ronald L. Barrick Of CUMBERLAND COUNTY STATE OF ~~ PENNA. N o. 02 VERSUS Paula Sue Freet PLEAS 5784 DECREE IN DIVORCE ow, , IT IS ORDERED AND DECREED THAT Ronald L. Barrick , PLAINTIFF, AND Paula Sue Freet , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE cOUrT RETAINS JurisDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD 1N THIS ACTION For WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ATTEST~/~ Jo PROTHONOTARY