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BARBARA K. CARPENTER,
Plaintiff
vs.
TARRIN A. CARPENTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. K v3 73CIVIL TERM
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RI HT
You have been sued in Court. If you wish to defendant 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 and a decree in 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 Cumberland County Courthouse, 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 Court Administrator
4'" Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240-6200
BARBARA K. CARPENTER,
Plaintiff
VS.
TARRIN A. CARPENTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99• `/3)s'CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
1. Plaintiff is Barbara K. Carpenter, an adult individual currently residing at 133 West
North Street, Carlisle, Cumberland County, Pennsylvania. Plaintiff has resided at this
residence since January 18, 1999.
2. Defendant is Tarrin A. Carpenter, an adult individual currently residing at 133 West
North Street, Carlisle, Cumberland County, Pennsylvania. Defendant has resided at
this residence since January 18, 1999.
3. Defendant is a bonafide resident of the Commonwealth of Pennsylvania and has been
so for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 7, 1991, in Carlisle, 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 Unites States Armed Forces or its Allies.
7. 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, Plaintiff does
not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that Defendant will, ninety days from
the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce pursuant to Section 3301(c) of the Domestic Relations Code.
UNT II
INDIGNITIES
11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full
text.
12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent
and injured spouse, as to make her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce
pursuant to Section 3301(a) (6) of the Domestic Relations Code.
COUNT III
ADULTERY
13. Paragraphs 1 through 12 are incorporated herein by reference as if set forth in their full
text.
14. Defendant has committed adultery by having sexual relations with a female individual
contrary to his wedding vows and the Plaintiff is the innocent and injured spouse.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant
to Section 3301(ax2) of the Domestic Relations Code.
Respectfully submitted,
GRIFFIE & ASSOCIATES
nffie, Esquire
for Plaintiff
P0000NNooVrrthh Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE:_07 - 5 - 9q y=J / ff. (sue __
BARBARA K. CARPENTER
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BARBARA K. CARPENTER,
Plaintiff
VS.
TARRIN A. CARPENTER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 99-4375 CIVIL TERM
IN CUSTODY
AND NOW, this '-? day of? 1999, comes Bradley L. Griffie,
Esquire, attorney for Plaintiff, Barbara K. Carpenter, and states that the Defendant, Tatrin
A. Carpenter, was served with a true and attested copy of the Complaint in Divorce by
certified mail, restricted delivery on July 29, 1999.
Respectfully submitted,
GRIFFIE & ASSOCIATES
(UPCey L. ie,'Esquir
Attome or Plaintiff
206-orth Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
Sworn and subscribed
to this (o ys day of
64/t. -w
Notary lic
Notarial Seal
FRobln J. Gosttom, Notary Public
lisle Boro, Cumbadz County
mmission Expires Apr. 17, 2003
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