HomeMy WebLinkAbout99-03584i
HOWARD E. BARRICK, II, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - DIVORCE
NO. 99- 3 T9Y CIVIL TERM
BETH ANN BARRICK,
Defendant IN DIVORCE
NOTICE
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, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR
EXPENSES BEFORE A DECREE OF 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
(717) 249-3166
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By
ID N 4693
11 E t Street
Carlisle, PA 17013
(717) 243-5513
Date: u 3 /, Ct 1 j
barrick howard complaint in divorce June 1, 1999
HOWARD E. BARRICK, II,
Plaintiff
VS.
BETH ANN BARRICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 99- 3 S Y CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
HOWARD E. BARRICK, II, Plaintiff, by his attorneys, FLOWER, FLOWER & LINDSAY, P.C.,
respectfully represents:
1. The Plaintiff is Howard E. Barrick, II, who currently resides at 55 Fickes Road, Newville,
Cumberland County, Pennsylvania, where he has resided since 1995.
2. The Defendant is Beth Ann Barrick, who currently resides at c/o Richard Fetterman,
3571 Ritner Highway, Newville, Cumberland County, Pennsylvania, where she has resided since
May, 1999.
3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 24, 1990 at Carlisle, Pennsylvania
5. That there have been no prior actions of divorce or for annulment between the parties in
this or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is
irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce
Code.
barrick howard complaint in divorce June 1, 1999
7. Plaintiff has been advised of the availability of marriage counseling and of the right to
request that the Court require the parties to participate in marriage counseling, and does not request
counseling.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:-
vu? / Carol J. Lindsay, Esquire
ID # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Date: Clw 3
0
VERIFICATION
I, the undersigned, hereby verify that the statements made herein 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.
4"'.1 e 4"?°
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