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Home My WebLink About04-1478In the Court of Common Pleas of Cumberland County, Pennsylvania JILLEAN A. RIVERA-SCARBERRY, ) Plaintiff, r / VS. ) No. 2004 - N 7 KENNETH L. SCARBERRY, ) CIVIL TERM Defendant. ) 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 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: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 F-1ptnAI RE ••, ?.+? ram- _,_.._?.-..?. ... .......a.-s.w win In the Court of Common Pleas of Cumberland County, Pennsylvania JILLEAN A. RIVERA-SCARBERRY, ) Plaintiff, ) VS. ) No. 2004 - KENNETH L. SCARBERRY, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Michael S. Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania JILLEAN A. RIVERA-SCARBERRY, ) Plaintiff, vs. j No. 2004 - 1q% ) KENNETH L. SCARBERRY, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by her attorney Michael S. Travis, respectfully represents: Plaintiff is Jillean A. Rivera-Scarberry, who resides at 143 15th Street, No. 5, New Cumberland, Cumberland County, Pennsylvania, 17070, since August, 2001. 2. Defendant is Kenneth L. Scarberry, who resides at 7227 Catherine Drive, Harrisburg, Dauphin County, Pennsylvania, 17112, since April 3, 2004. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 29, 1997, in Dauphin County.. Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time. Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. 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. 9. Neither party is in the Military Service in the United States. 10. Plaintiff requests the court to enter a decree of divorce. 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: '7/ - - 0 4 Plaintiff Michael S. Travis Attorney for Plaintiff I.D. # 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 i Z?' (? _`\^. _ ) ?? l? ?? "(`?. ^1 ? J Lam') ?? \ C V\ v'? ? 1 ?, . ?, ? ; - „ r ?{ _. I -- ) C`1 C-? In the Court of Common Pleas of Cumberland County, Pennsylvania JILLEAN A. RIVERA-SCARBERRY, ) Plaintiff, ) VS. ) No. 2004 -1478 KENNETH L. SCARBERRY, ) CIVIL TERM Defendant. ) IN DIVORCE Praecipe to Reinstate Complaint in Divorce To the Prothonotary: Please reinstate the Complaint in the above case. S. Travis Attorney for Plaintiff ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Date: j ?_ C-?)'/ N C? T S". ?- T .s _a m = ? -c?c;7 u! ' rn . 4 C? ".t_ _, ?. ?TZ J' ? t '? N l ? SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-01478 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SCARBERRY JILLEAN A RIVERA VS SCARBERRY KENNETH L R. Thomas Kline Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: SCARBERRY KENNETH L but was unable to locate Him deputized the sheriff of DAUPHIN in his bailiwick. He therefore serve the within COMPLAINT - DIVORCE County, Pennsylvania, to On June 8th , 2004 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Cc 30.50 .00 67.50 06/08/2004 MICHAEL TRAVIS So answers: R`. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this YE' day of „2On`f A. D. 0 / , Prothonotary' In The Court of Common Pleas of Cumberland County, Pennsylvania Jillean A. Rivera Scarberry vs. Kenneth L. Scarberry SERVE: same 04-1478 civil No. Now, May 7, 2004 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, within upon at by handing to a and made known to , 20_, at o'clock M. served the copy of the original the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of 20 COSTS SERVICE $ MILEAGE AFFIDAVIT (? t?Q of tot ocher-f f Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph:(717)255-2660 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania SCARBERRY-RIVERA JILLEAN A vs County of Dauphin SCARBERRY KENNETH L Sheriff's Return No. 4546-T - - -2004 OTHER COUNTY NO. 04-1478 AND NOW:May 18, 2004 NOTICE & COMPLAINT IN DIVORCE SCARBERRY KENNETH L at 1.OOPM served the within upon by personally handing to BRIAN SCARBERRY BROTHER OF DEFT 1 true attested copy(ies) of the original NOTICE & COMPLAINT IN DIVORCE and making known to him/her the contents thereof at 7227 CATHERINE DR HBG, PA 17112-0000 Sworn and subscribed to before me this 26TH day of MAY, 2004 NOTARIAL SEAL MARY JANE SNYDER, Notary Public Higi spire, Dauphin County My Commission Expires Sept. 1, 2006 So Answers, k A/c- Sheriff of Dauphi$`County, Pa. By Deputy Sheriff Sheriff's Costs:$30.50 PD 05/13/2004 RCPT NO 194607 G MILLE Curtis R. Long Prothonotary office of the Protbonotarp Cumberland Cuuntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Q41 - 1.41 7,R CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573