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HomeMy WebLinkAbout00-08847. i BRENDA S. FARBER, Plaintiff VS. DONALD W. FARBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. P-D - F9-'P '? C"- -TO,- ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 BRENDA S. FARBER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 8 8 9 ?i? DONALD W. FARBER, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Bretida S. Farber, an adult individual, who has resided at 98 Schoolfield Drive, Carlisle, Cumberland County, Pennsylvania, since 1998. 2. Defendant is Donald W. Farber, an adult individual, who has resided at 98 Schoolfield Drive, Carlisle, Cumberland County, Pennsylvania, since 1998. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 26, 1984 in Philadelphia, Philadelphia County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have three children together, namely, Rebecca Farber, dob 10/9/85, Cynthia Farber, dob 2/2/87, and Joshua Farber, dob 11/9/88. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Brenda S. Farber, Plaintiff Respectfully submitted, Date:1 Z • 2i c--.'O RaneALgza2ms, Esquire I.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ..I a U 6 f. 1\ n? ri T Q o-? q a BRENDA S. FARBER, Plaintiff vs. DONALD W. FARBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 60 - FS-'l 7 lit t,, ? l T ei l-Y) ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT. AND NOW, this January 15, 2001, I, Jane Adams, Esquire, hereby certify that on January 11, 2001, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Donald Farber 98 Schoolfield Drive Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: Esquire g.Dane 465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF C> c°:; _ c- __, V `f. t? r_. _. ? ?_ r, ?° J ?- . _. .e" ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that eve can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ?& sP?d ?"Jp- PA I-? 6kS 2. Article Number (Copy from service label) Print Clearly) I B. Date of C. Signature ,(?\Jr---/?/ ? Agent x U ?-rr dre. D. Is 6wgr-y address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type A,C fled MaB ? Express Mail ? Regis ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Dellverv? (FNS FBI Ps Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 In The Court of Common Pleas of Cumberland County, Pennsylvania FARBER BRENDA S vs FARBER DONALD W File No. 2000-08847 STATEMENT OF INTENTION TO PROCEED To the Court Qn I `` Icy rC--h l-k Fa r'' o- ? intends to proceed with the above captioned matter. Date: lil Q_ 7 ? (J? ?IUV41/?- _ orneyfor lp?tje440. t• p•c?Va?ec G:> A .--! ?s ?''Ct [? f ? (' y y"1"? ,?* ?r -„ .T. r; ._ ?,„ rr _, .. °a Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Qn - PR 14 7 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573