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Home My WebLink About02-6186BETH A. CLOUSE, BARRY L. CLOUSE, TO: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGtIT£ Barry L. Clouse 300 Grahams Woods Road Carlisle, PA 17013 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. 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, One 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 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, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #: 242636.1 BETH A. CLOUSE, Plaintiff Vo BARRY L. CLOUSE, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0,2 - 6/~¢ IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff, Beth A. Clouse, is an adult individual currently residing at 599 Old Quaker Road, Apartment H, Lewisberry, York County, Pennsylvania. 2. The Defendant, Barry L. Clouse, is an adult individual currently residing at 300 Grahams Woods Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 5, 1998, in Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security number is 164-54-2406, and Defendant's Social Security number is unknown. 7. There have been no prior actions for divorce or annulment between the parties. 8. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. Document ti: 242636~ 1 10. 11. 13. Defendant. There were no children born of the marriage. The marriage is irretrievably broken. The parties have been living separate and apart since June 1, 2002. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and WHEREFORE, Plaintiff requests that this Court enter a decree in divorce, and enter such other Orders as are appropriate and just. By Andre~v~. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 242636.1 VERIFICATION I, Beth A Clouse, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: /,5/-ovr_D Beth A. Clouse Document #.- 242636.1 BETH A. CLOUSE, Plaintiff VS. BARRY L. CLOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION--LAW NO. 02-6186 IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO PROTHONTARY: Please enter my appearance on behalf of the Defendant, BARRY L. CLOUSE, in the above- captioned matter. Respectfully submitted, Dated: January 9, 2003 HANFT & KNIGHT, P.C. Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-.5373 F:\User Folder~irm Docs\Gendocs2002\1740-4praecipe.enter.wpd BETH A. CLOUSE, Plaintiff VS. BARRY L. CLOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CWIL ACTION--LAW NO. 02-6186 IN DIVORCE ACCEPTANCE OF SERVIC~E. I, Michael J. Hanft, Esquire, accept service of the Plaintiff's Complaint in Divorce in the above-captioned matter on behalf of my client, BARRY L. CLOUSE, and I certify that I am authorized to do so. Date: January 9, 2003 HANFT & KNIGHT, P.C. Mi~Jl J ~ Attorney ID No. 57976 19 Brooloafood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-.5373 Attorney fbr Defendant F:\User Folder'tFirm Docs\Gendocs2003\1740-4acc-service-wpd BETH A. CLOUSE, BARRY L. CLOUSE , Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6186 - CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 30, 2002, and served upon Defendant's counsel on January 9, 2003. Acceptance of Service filed January 13, 2003. 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 after service of notice of intention to request entry of the decree. 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 unswom falsification to authorities. Dated: Beth A. Clouse Document #: 265476.1 BETH A. CLOUSE, Vo BARRY L. CLOUSE, Plaintiff · Defendant ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6186 - CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIvoRcE UNDER § 3301(c) OF THE DIVORCE CODE I consem to the entry of a final decree of divorce without notice· division of property, 2. I understand that I may lose rights concerning alimony, 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 this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Beth A. Clouse Document #: 265477.1 BETH A. CLOUSE, BARRY L. CLOUSE, Plaintiff ' Defendant ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6186 - CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 30, 2002, and served upon Defendant's counsel on January 9, 2003· Acceptance of Service filed January 13, 2003. 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 after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. '' ' -- B se Document #: 265476.1 BETH A. CLOUSE, Vo BARRY L. CLOUSE , Plaintiff · Defendant ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6186 - CIVIL IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER ,q 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 ifI 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 this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Barry L. Clouf Document #: 265477.1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. Defendant File No. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the I~ dh day of ~)Cil ) ~.~ , hereby elects to resume the prior surname of---~ ~Yh~ ~\~uq..'~ , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: Signature Signature of name being-resumed COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND : On the 20~'-' day of ~/)~ · ~0~, before me, a Notary Public, personally appeared ~he above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. seal. In Witness Whereof, I have hereunto set my hand and official ~ Carlisle Bor°, Cumberia~ County ~ ~ My Commission Expires April 4, 2005 ~