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HomeMy WebLinkAbout07-7224I- JOSHUA JACOB BARRETT Plaintiff V. JESSICA LYNN BARRETT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. ol-,jaAq CIVIL TERM 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 Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 JOSHUA JACOB BARRETT : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JESSICA LYNN BARRETT :NO. CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Joshua Jacob Barrett, who currently resides at 208 North Baltimore Avenue (Rear), Mt. Holly Springs, Cumberland County, Pennsylvania, 17065 since October 2007. 2. Defendant is Jessica Lynn Barrett, who currently resides at 208 North Baltimore Avenue (Rear), Mt. Holly Springs, Cumberland County, Pennsylvania, 17065 since October 2007. 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 October 11, 2001, at Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment 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 of Divorce. i `6 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 unsworn falsification to authorities. Date: !O2$/6-7- 1 .1 J ua Jacob Barrett, Plaintiff ANDREWS & JOHNSON By: Ronald E. Jo h, Attorneys for aintif 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 rn a 00 o s a ; Z C4 . 3 r -' N w JOSHUA JACOB BARRETT Plaintiff V. JESSICA LYNN BARRETT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW :NO. 7224 -dl CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this day of December 2007, I, Ronald E. Johnson, Esquire, attorney for Joshua Jacob Barrett, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice io Defend and Claim Rights, executed by the Plaintiff in the above- captioned matter, upon the Defendant at her residence at 208 North Baltimore Avenue, Rear, Mt. Holly Springs, PA 17065, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on December 5, 2007, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: Sworn and subscribed to before me this day of December 2007. Public C tH OF PENNSYLVANIA NOTARIAL SEAL SHELLY SEXTON, Notary Public Carlisle Boro, Curnbedand County Commission Expires Apil 2011 • ?y I 46 ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so t can return the card to you. ¦ Attact Is card to the back of the mailpiece, or o"m front if space permits. 1. Ak!&ddressed to: ?CSiCA LYnh 13arrr??' oZO AV & 14i rr?or? ?4vr vela r Y ??Of?J A. B. P# elved by (PrInM!Name) I C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type 14 Certified Mail © Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) WYes 2. Article Number (rrenster fromsamcebw 7007 1490 0001 7953 7770 PS Form 3811, Febmary 2004 Domestic Return Receipt 102595-02-M-1 540 . Exhibit A Page 1 of 1 Track/Confirm - Intranet Item Inquiry - Domestic I Item: 7007 1490 0001 7953 7770 Destination ZIP Code: 17065 Origin ZIP Code: 17013-2935 Class: First Class Anticipated Delivery Date: 12/04/2007 Service Calculation Acceptance Date/Time: 12/03/2007 13:03 City: MOUNT HOLLY SPRINGS State: PA City: CARLISLE State: PA Weight: 0 lb(s) 1 oz(s) Postage: $0.41 Delv Rqmt: Normal PO Box?: N Special Services Associated Labels Amount CERTIFIED MAIL 7007 1490 0001 7953 7770 $2.65 RETURN RECEIPT $2.15 RESTRICTED DELIVERY $4.10 I Event Date/Time Location Scanner ID MOUNT HOLLY SPRINGS, POS6720065 I PA 17065 MOUNT HOLLY SPRINGS, 030SGQ6556 PA 17065 CARLISLE, PA 17013 Direct Query - Intranet - "Quick" Search w Enter Request Type and Item Number: Quick Search OF Extensive Search C` hoot A Version 1.0 Inquire on multiple items. Go to the Product Tracking System Home Page. http://pts.usps.gov/pts/labelInquiry.do 12/6/2007 Direct Query - Intranet Track/Confirm - Intranet Item Inquiry Item Number: 7007 1490 0001 7953 7770 This item was delivered on 12/05/2007 at 15:31 Signature• V? lhmg?, Address: Version 1.0 Inquire on multiDle items. Go to the Product Tracking System Home._Pa_ge. Page 1 of 1 http://pts.usps.gov/pts/imageView.do 12/6/2007 SC-) C fl is C": r • . i?Ta