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Home My WebLink About08-5145COMMONWEALTH OF PENNSYLVANIA Court of Common Pleas County of Cumberland Jamie L Freberg Plaintiff, Case No.: and Judicial District No.: 09-2-01 Matthew D Freberg Defendant. NOTICE TO DEFEND AND CLAIM RIGHTS TO THE ABOVE-NAMED DEFENDANT: 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: 1 Courthouse Sq Carlisle PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR AN 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Name: ?1C?v.Mbezlp"r? C;our? `?C P+4 Address: --52 S . C\ ?c . Telephone number: 1 ?1 ?Z?? , ?J\lplp COMMONWEALTH OF PENNSYLVANIA Court of Common Pkas County of Cumberland Jamie L Freberg Plaintiff, and Case No.: Judicial District No.: 09-2-01 Matthew D Freberg Defendant. COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Information about the Parties Name: Date of Birth: Address: Telephone: Residence County: Date of Initial Residence: 2. 3. 4. Husband Matthew D Freberg 08/01/1979 38 Winchester Gardens Carlisle PA 17013 717-713-8918 Cumberland PA 08-01-1979 Information about the Marria *?e Marriage Date: 08/19/2006 Marriage Place Carlisle PA Residency Wife Jamie L Freberg 07/26/1985 361 Hartmann Rd Evans City PA 16033 717-448-0165 Butler PA 07/28/2008 Plaintiff and/or Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. Grounds for Dissolution of Marriage The marriage is irretrievably broken and the Defendant consents to divorce. -1- 5. Minor Children If checked, the wife is pregnant. The parties have minor children (under 18 years of age) or children who are otherwise dependent as listed on the attached UCCJEA Declaration which is incorporated fully herein by this reference. 7. Acknowledgment of Availability of Counseling 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. Plaintiff does NOT request or desire counseling. 8. Marital Settlement Agreement including Child Custodv Visitation & Support The parties executed or will execute a Marital Settlement Agreement that fairly and equitably divides the parties' assets and apportions responsibility for marital debts, provides for custody and visitation regarding the minor child(ren); and sets out child support consistent with the Commonwealth of Pennsylvania Child Support Guidelines. 9. Prayer for Relief WHEREFORE, Plaintiff requests the court dissolve the marriage of the parties, enter a decree of divorce adopting the parties' Marital Settlement Agreement, and order that each party bear his/her own costs of these proceedings. 10. 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. § 4904, relating to unswom falsification to authorities. Dated: Signed: Jamie L Freberg 361 Hartmann Rd Evans City PA 16033 717 448 0165 NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURT! MY COMMISSION EXPIRFS JAM A^ n' /A -2- PARTY WITHOUT ATTORNEY (Name and AWInq Addma): TELEPHONE NO.: tea COURT UNA? OAKY Jamie L Freberg 717 448 0165 361 Hartmann Rd Evans City PA 16033 Cumberland sTREET ADDRm: 1 Courthouse Sq MAILING ADDRESS: Carlisle PA 17013 CITY AND 21P CODE: BRANCH NAME: none CASE RNME: Jamie L Freberg Matthew D Freber DECLARATION UNDER UNIFORM CHILD CUSTODY CA" NUMIKM JURISDICTION AND ENFORCEMENT ACT (UCCJEA) 1. f sm a parry to this proceeding to determine c tistody of a child. 2. M Declmnt's present address is not disclosed. It is confidential. The address of children presently residing with declarant is identified on this declaration as confidential. 3. (Number): 2 minor children are subject to this proceeding as follows: a. ChM rem Pb= of bft Do" of bft Sasr Mackensie R Freberg Chambersburg Hospital 09/08/2006 Female ft off I" r 07/28/2008 Addrm 361 Hartmann Rd Person d+w Need wNh (name and mve" aditw) Reladlorrship to Present 0 confidential Jamie L Freberg Parent 09/11/2006 38 Winchester Gardens to 07/28/2008 Jamie L Freberg parent to 09/11/2006 to to b. ChM rwrns Pbm of bft Dtle of bft Sax Kylie E Freberg ? M9 *? Intaf ow,fssoawnswommab"fordwda Carlisle Regional Medic al G*W2008 Female (ft NOT ffw cares, t fAa i> , uft* bobwj Period of residence Address Person dAd Nred wNh (name and prevent address) Robftr ship to Present O confidential to to to c. M children are involved in this proceeding. Additional children are listed on the Attachment. Peyr I of 2 DECLARATION UNDER UNIFORM CHILD CUSTODY JURISDICTION AND ENFORCEMENT ACT (UCCJEA) SHORT TITLE: vs. CASE rx2aBIM: - Jamie L Freberg Matthew D Freberg 4. Have you participated as a party or a witness or in some other capacity in another litigation or custody proceeding, in this state or elsewhere, concerning custody of a child subject to this proceeding? NO (if yes, provide 9W following information:) a. Name of each child: none b. Capacity of declarant: M party [-] witness 0 other (specify): c. Court (specify name, state, location): d. Court order or judgment (date): 5. Do you have information about a custody proceeding pending in this court or any other court concerning a child subject to this proceeding, other than that stated In item 4? NO (if yes, provide the following information) a. Name of each child: none b. Nature of proceeding: [_-] dissolution or divorce O , rship O adoption O other (specify): c. Court (specify name, state, location): d. Status of proceeding: 6. Do you know of any person who is not a party to this proceeding who has physical custody or claims to have custody of or visitation rights with any child subject to this proceeding? NO (If yes, provide the !Mowing information:) a. Name and address of person b. Name and address of person c. Name and address of person none Q Has physical custody Q Has physical custody Has physical custody Claims custody rights Q Claims custody rights Q Claims custody rights Clekns vlsitatbn rights Q Claims visitation rights Claims visitation rights Name of each child Name of each child Name of each child I declare under penalty of perjury that the foregoing is true and correct. Date: Jamie L Freberg (TYPE OR PRINT NAME) (SIGNATU DE I ITV I14C 1 V DEiZAfiANT: YOU IIM a OOntllNrlg fully tb liftM Of COW E you oblalll ally IIIf01111wo11 dm* a auafody Pr - - Nl- Many court oollown11Ig a a W subj M ID Oft 1 l9 oaa2 tl>,1. DECLARATION UNDER UNIFORM CHILD CUSTODY M fe 2 of 2 JURISDICTION AND ENFORCEMENT ACT (UCCJEA) c- c:n cm t? ? n ? W y:. ? 'gym d •a Y: -- ;,AM COMMONWEALTH OF PENNSYLVANIA Court of Common P1ew County of Cumberland Jamie L Freberg Plaintiff, Case No.: p $ ' and Judicial District No.: 09-2-01 Matthew D Freberg Defendant. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned as Plaintiff, Pro Se, in the above encaptioned matter. Dated: Signed: Jamie L Freberg Address: 361 Hartmann Rd Evans City PA 16033 717 448 0165 73 X11. Gs m t? i_ p X3?i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jamie L. V. Case No. 08-5145 Civil Judicial District No. 09-2-01 Matthew 0. Freberg, PRAECIPE TO DISCONTINUE To the mark the above-captioned action discontinued. Respectfully, Jamie L. Freberg, Pro Se i -1 I 4r-1