HomeMy WebLinkAbout03-6401PATSY J. BARNHART
PLAINTIFF
Vs.
RICHARD J. COMREY
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No. __ c,
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
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 divorce is indigvSties 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:
Office of the Prothonotary
Cumberland County Court House
One Courthouse Square
Carlisle, Pennsylvania 17013-3387
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAIad~ 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 17013-3387
717-249-3166
PATSY J. BARNHART
PLAINTIFF
Vs.
RICHARD J. COMREY
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY PENNSYLVANIA
No. r'~3 -- 67o/
:
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I
AND NOW, comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows:
Plaintiff is PATSY J. BARNHART, who currently resides at 516 N. Second Street,
Wormleysburg, PA 17043.
Defendant is RICHARD J. COMREY, who currently resides at 352 Crescent Street,
Harrisburg, PA 17104.
Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least
six months immediately previous to the filing of this Complaint.
The Plaintiff and Defendant were married on August 5, 2002.
5. There have been no prior actions of divorce or annulment between the parties.
The marriage is irretrievably broken.
Plaintiff has been advised of the availability of counseling and also the Plaintiff may
have the right to request that the Court require the parties to participate in counseling,
and after being so advised, Plaintiff does not desire counseling.
PATSY J. BARNHART
PLAINTIFF
Vs.
RICHARD J. COMREY
DEFENDANT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY PENNSYLVANIA
:
No.
:
: CIVIL ACTION - LAW
: IN DIVORCE
WHEREFORE: Plaintiffrequests the Court to Enter a Decree in Divorce.
Respectfully submitted,
DATE [~- !- b~ By
Attorney I.D.# 18727
352 S. Sporting Hill Rd.
Mechanicsburg, PA 17050
(717) 737-2033
VERIFICATION
I verify that the statements made in this Complaint are true and correct. I understand that false
statements herein made are subject to penalties of 18 PA. C.S. §4904, relating to unsworn
falsification to authorities.
DATE:
PATSY J. BARNHART
(PLAINTIFF)
PATSY .1. BARN HART
Plaintiff
VS.
R/CHARD .1. COMREY
Defendant
1~N THE COURT OF COMMON PLEAS
OF PERRY COUNTY, PENNSYLVAN/A
NO. 03-6401
Ct'Vt'L ACT/ON - LAW
I'N DI'VORCE
CERTIFICATE OF PERSONAL SERVICI'
I, .1AMES M. BACH, being duly sworn according to Law, say that ! personally served:
R/CHARD .1. COMREY
AT 352 S. SPORTING HILL ROAD
MECHANICSBURG, PA 17050
by handing to him a copy of the following document:
NOT/CE TO DEFEND AND CLAIM I~GHTS AND COMPLAI'NT t'N DtVORC;
on the 15th day of DECEMBER, 2003, at 10:00 a.m.
DATE: December 15 2003
SIGNATURE:
.1AMES M. BACH
Patsy J. Barnhart
Plaintiff
VS.
Richard J. Comrey
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
:
: NO. 03-6401 CIVIL TERM
:
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(C) OF THE DIVORCE CODE
(I) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
(2)
(3)
(4)
(5)
The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
I consent to the entry of a final decree of divorce, without formal notice of the intention to
request entry of divorce decree.
I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses, ifI do not claim them before a divorce is granted.
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 this 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 unswom
falsification to authorities.
DATE
lYa~sy J. Bar~h~rt '- '
PLAINTIFF
Patsy J. Barnhart
Plaintiff
VS.
Richard J. Comrey
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
;
;
: NO. 03-6401 CIVIL TERM
;
: CIVIL ACTION - LAW
: IN DIVORCE
.AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
.,ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(C) OF THE DIVORCE CODE
(1) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on
12/! 0/0 3
(2)
(3)
(4)
(5)
The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
I consent to the entry of a final decree of divorce, without formal notice of the intention to
request entry of divorce decree.
I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses, ifI do not claim them before a divorce is granted.
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 this 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 unswom
falsification to authorities.
DATE
'chard J. Comr~
DEFENDANT
PATSY J. BARNHART
Plaintiff
VS.
RICHARD J. COMREY
Defendant
: IN THE COURT OF COMMON PLEAS OF
~ CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 03-6401
:
: CIVIL ACTION - LAW
: IN DIVORCE
DIVORCE INFORMATION SHEET
The parties were married on August 5, 2002.
Respectfully Submitted,
J~ffES M. BACH, ESQUIRE
AtYorncy I.D.# 18727
Attorney for Plaintiff
352 S. Sporting Hill Rd.
MECHANICSBURG, PA 17050
(717) 737-2033
PATSY J. BARNHART
Plaintiff
VS.
RICHARD J. COMREY
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
_.
: NO. 03-6401
:
..
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORI~
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a Divorce Decree:
1. GROUNDS FOR DIVORCE: Irretrievable breakdown under Section (X) 3301(c) or
( ) 3301(d)(1) of the Divorce Code. (Check applicable section.)
2. DATE AND MANNER of service of the Complaint:
Personal Service, December 15~ 2003.
3. COMPLETE EITHER PARAGRAPH (a) or (b).
(a)
(b)
Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code:
By Plaintiff.' MarehlS.!_~.~2004; by Defendant: Mareh~
1. Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of
the Divorce Code
2. Date of service of the Plaintiffs Affidavit upon the Defendant:
4. RELATED CLAIMS PENDING: NONE
DATE: Decemb~
By:
· BACH, ESQUIRE
Attorney I.D.# 18727
Attorney for Plaintiff
352 S. Sporting Hill Rd.
MECHANICSBURG, PA 17050
(717) 737-2033
"IN THE COURT OF~ COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
.-~A~S~./..BARNHA~T ..........................
......................... P~!.N~!.FF ...............
Versus
RICHARD J. CONREY
No..o.3.~64ol ....
DECREE IN
DIVORCE
AND NOW ..... ~r~ Z-2'. P-,b....~.! ........ , ,4~9/.2004 , it is ordered and
decreed that .. PA~s¥..z...B~,~N~A~T .......................... , plaintiff,
and. RICHARD. ~1,. CD.m4HtE1,.
................................... defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record Jn this action for which a final order has not yet
been entered;
NONE .
.... P~-otho~ta~.~ '
:.;: