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Home My WebLink About99-06793i L-Lk ti CJ ?D r e ,I CERTIFIED COPY: LAW OFFICES SAIDIS, GUIDO, SHUFF & MASLAND 26 W. HIGH STREET 2109 MARKET STREET CARLISLE. PA 17013 CAMP HILL, PA 17011 PHONE(717)243-6222 PHONE (717) 737.3405 SAIDIS, GUIDO, SHUFF & MASLAND 26 W, High Street Carlisle. PA MARILYN A. BARRICK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, NO. CIVIL TERM i - L 71)3 HENRY H. BARRICK, JR., CIVIL ACTION - LAW 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, High and Hanover Street, Carlisle, Pennsylvania. IF YOU DO NOT PROPERTY, LAWYER'S ANNULMENT IS GRANTED, THEM. YOU SHOULD TAKE DO NOT HAVE A LAWYER THE OFFICE SET FORTH HELP. FILE A CLAIM FOR ALIMONY, DIVISION OF FEES OR EXPENSES BEFORE A DIVORCE OR YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU OR CANNOT AFFORD ONE, GO TO OR TELEPHONE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL Court Administrator 4`h Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 SAIDIS, H= F&?LAND Date: I -4 S By: John n} /J. Dei y,-.2'squire Supr2me Cour ID It 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff MARILYN A. BARRICK, TN THE COURT OF- COMMON PLEAS Plaintiff CUMBERLAND COUN T PENNSYLVANIA • l V. NO.1i"aCriIVIL T_EFRM HENRY H. BARRICK, JR., CIVIL ACTION - LATW Defendant IN DIVORCE IN THE COURT OF' COMMON PLEAS COMPLAINT 1. Plaintiff is Marilyn A. Barric k, adult individual currently resides at 511 Conodogquinet Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Henry H. Barrier., Jr . , adult individual currently resides at 135 South Hanover S t reet, Apartment 5, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 9. The Plaintiff and Defendant were married on June 22, SAIDIS, GUIDO, SIIUFF & NIASLAND 26 W. High Street Carlisle. PA 1973, in Montgomery County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of (marriage counseling and the Plaintiff may have the right to request that the Court require the parties t o participate in counseling. Having been so advised Plain ziiff does not desire Ithe Court to order counseling. 7. The Plaintiff alleges that in violation of his marriage vows, the Defendant has and did, over a period of time in Cumberland County and other places, offered such indignities to the person, the Plaintiff, to render her condition intolerable in life and burdensome. The Plaintiff alleges in violation of his marriage vows, Defendant has and did, over a period of time in Cumberland County, committed adultery. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. COUNT II EQUITABLE DISTRIBUTION 8. The allegations in Paragraph 1 through 7 inclusive are mad, a part hereof, incorporated hereat by reference. 9. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. WHEREFORE, Plaintiff requests This Honorable Court to SAIDIS, GUIDO, SHUFF & MASLAND 26 W. High Simet cWhile, 1"x determine marital property and to order an equitable distribution thereof. 2 i L? COUNT III ALIMONY 10, The allegations in pw ragraph 1 LorDunk 0, b reference. are made a Part hereof anti incorporated herein y 11, Plaintiff lacks su:-ficient property t:o provides for her reasonable needs and is unable to support herself through appropriate employment. es reasonable support to adequately . plaintiff requir 12 of ii maintain herself i.n acc)r.dan e ,'n the sta::dard vina established ciuring tLe R'.arrlc.ge, I provide for the 13. Defendant is financially' able to tenter an a'aard of alimony pendente lite until final hearing reasonable needs for the Plaintiff. i 47};EREiGR.f'1, the Plai.[a if?.r= requests Your Honorable court and permanent alimony thereafter. COUNT IV COUNSEL FEES, COSTS AND EXPENSES tm? SAIDIS, GUID( suUFF & MASLAND 26 W. ? ch MUCI Ca WC. PA through i3 inclusive allegations in paragraph - 14. The reference. are made a part hereof anti incorporated 'herein by 3 ?JriS'3?S 15. Plaintiff has retained the services of Saidis, Shuff & Masland and the counsel fees, costs and expenses for representation in this action will be substantial and continuing. 16. Plaintiff is without sufficient funds, income or assets to pay such counsel fees, costs and expenses. WHEREFORE, the Plaintiff prays that this Honorable Court enter an award for preliminary and interim counsel fees, costs and expenses and to enter a final award of counsel. fees, costs and expenses. Respectfully submitted, SAIDIS, SHUFF & MASLAND Date: It - / By: John J. 9 ily, Esquire Sup(r e Cc rt I # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, CUIDO, SHUFF & MASLAND 26 W. High Street Carlisle. PA 4 E;' AFFIDAVIT I, Marilyn A. Barrick, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. (2) I understand that the court maintains a list of marriage counselors in the Prothonot:ary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. Dated: / `%` Maril n A. Barrick, Plaintiff i tl VERIFICATION 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. Section 4904, relating to unsworn falsification to authorities. Dated: irw / /?J'r /?/1??.?nt ;?Gt? .''?,y - Marti y 'A. 'Barrick, Plaintiff i i i ., ? o ?. ? °? ? ?? ? ? '? i J i ? •y V V hl ? ?? ; r; ,, ? ? :> .r I ?? '. j ? ? ? ? ,,, i ? ^c? \\y 'i r (/?\\ 1 \?'?- 1 1 1?.' I MARILYN A. BARRICK, Plaintiff V. HENRY H. BARRICK, JR., Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 99-6793 CIVIL TERM IN DIVORCE Please withdraw the Divorce Complaint filed to the above captioned action. SAIDIS, SHUFF & MASLAND BY: _- /--? Jo'nna J/ Deiiy,?Esq. 26 W. High Street Carlisle, PA 17013 Attorney for Plaintiff SAIDIS, GUIDO, SIIUCF K NIASLAND ?G W. High Strmt Wisle. PA 7 -`E ?? U