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Home My WebLink About03-2646RICHARD ARTHUR BARRICK, Plaintiff V. HEATHER ANN BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM 1N DIVORCE NOTICE TO DEFEND 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, High and Hanover Streets, Carlisle, PA. 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, PA 17013 Phone: (717) 249-3166 or (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas ofxxx County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. RICHARD ARTHUR BARRICK, Plaintiff HEATHER ANN BARRICK, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301 c OF THE DIVORCE CODE 1. Plaintiff is Richard Arthur Barrick, who currently resides at 11 Peiper Court, Carlisle, Cumberland County, Carlisle, Pennsylvania, 17013. 2. Defendant is Heather Ann Barrick, her current address is unknown. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 28, 2002, in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for mmulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & BAYLEY Mark F. Bayley, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Plaintiff VERIFICATION I ver/fy 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 unswom falsification to authorities. Oate~¢, ~ ~ff RICHARD ARTHUR BARRICK, Plaintiff HEATHER ANN BARRICK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 03-2646 CIVIL TERM IN DIVORCE; AFFIDAVIT OF SERVICE COMMONWELATH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Mark F. Bayley, Esquire did serve by a Process Server to Heather Ann Barrick, the Plaintiff's Complaint in Divorce at his address, 11 Peiper Court, Carlisle, PA 17013. Service was executed on June 6, 2003 at the above address. An Affidavit of Service is attached. Respectfully submitted, ROMINGER & BAYLEY lyf'ark F. BayleyrF~fi~e 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 87663 Attorney for Plaintiff .AFFIDAVIT OF SERVICE Commonwealth of Pennsylvania Case Number: 03-2646 County of Cumberland Common Pleas Court Plaintiff: Richard Arthur Barrlck VS. Defendant: Heather Ann Barrick For: Mark Bayley Rominger & Bayley Law Off'~es Received by ROMINGER LEGAL on the 5th day of June, 2003 at 11:43 am to be served on Heather Ann Barrick at: (place of employment) Carlisle Diner - High~, Carlisle, PA 17013. I/A)//J/,,~O ~./[//¢b/~_..~ x"l~, being du y sworn, depose and say that on the c/r; day of ~--'7"c/.,~J~-- ,20C~'_'~ at,Z~_: ~-..~.m,, executad service by delivering a true copy of the Notice to Defend -in Divorce, Complaint Under Section 3301 (c) of the Divorce Code, Verification in accordance with state statutes in the manner marked below: (~) suDIVIDUAL SERVICE: Served the within-named person. BSTITUTE SERVICE: By serving as ( ) POSTED SERVICE: After attempting service on __/__ at __ and on __/__ at __ to a conspicuous place on the proped7 described herein. ( ) NON SERVICE: For the reason detailed in the Comments below. Military Status: ( ) Yes or ( ) No If yes, what branch? Marital Status: '~arried or ( ) Single Name of Spouse COMM~EN~S!,/~/:<~.~,~_~(~//4),4/ ,,/7/~'/.~/_/~'~/~'--..///~? c~'~-..z?~,~ / c~ ~', / / / ' I certify that I have no intarest in the above action, am of legal age and have proper authority in the jurisdiction in which this service was made. Subscribed and Sworn to before me on the,~'z~ day of ,~J ~t/~, , ~ by the affiant who is personally known to me. PROCESS SERVER # Appointed in accordance with State Statutes ~ ~,)'-.' ~ ROMINGER LEGAL I Llada J. J~, ~ ~ 155 S. Hanover St. NO'I'ARY PUE~C ~ ' i~;,~. .... ~' P.O. Box 1148 IC,~leBem, C. xrr~oedand~ Carlisle, PA 17013 ~My Cmmmk~ Expir~ July E3. 2006 (7t7) 960-9260 l~mf0ar, p.,w~da~aocia~.O~No~es Our Job Serial Number: 2003000124 RICHARD ARTHUR BARRICK., Plaintiff HEATHER ANN BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2646 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on June 4, 2003. 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 '['HE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 P'a.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. RICHARD ARTHUR BARRICK., Plaintiff HEATHER ANN BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2646 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Diivorce Code was filed on June 4, 2003. 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. Dante HEATHER ANN BJ~::~Ri(~K RICHARD ARTHUR BARRICK., Plaintiff HEATHER ANN BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2646 CIVIL TERM 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. RICHARD ARTHUR BARRICK. RICHARD ARTHUR BARRICK., Plaintiff HEATHER ANN BARRICK, Defendant IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2646 CIVIL TERM 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 '['HE 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. D~te HEATHER ANN BARRICK RICHARD ARTHUR BARRICK., Plaintiff HEATHER ANN BARRICK, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-2646 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divome decree: 1. Grounds for divome: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Jrme 6, 2003 was served on Defendant by Process Server. 3. Date of execution of the affidavit of consent required by § 3301 (c) or The Divorce Code: by the Plaintiff January 15, 2004; by the Defendant January 15, 2004. 4. Related claims pending: None 5. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: January 21, 2004. Date: January 21, 2004 155 South Hanover Street Carlisle, PA 17013 (717) 241-,5070 Supreme Court ID No. 87663 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Richard A. Barrick VERSUS Heather A. Barrlck N o. 0,3-2646 civil AND NOW, DECREED THAT DECREE IN DIVORCE Richard A. Barrick , IT iS ORDERED AND , PLAINTIFF, AND Heather A. Barrlck , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; ATTEST: 'HONOTARY ~ + ~+++++++++++++++++++++++++++++ ++++++++++++++++