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Home My WebLink About09-1074. Rebecca J. Barclay Plaintiff V. Tony W. Barclay Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- t d 71 CIVIL TERM 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Rebecca J. Barclay Plaintiff v. Tony W. Barclay Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- ID-7'1 CIVIL TERM : IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is kc bec (CS L CC y , who currently resides at Cumberland County, Pennsylvania. 2. Defendant is/ o n 1 W Cz rq l V who currently resides at tCtll-e- , 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on QJ,'C, 2 / , / r97 at CCi r i5 ?C P? 5. The marriage is irretrievably broken, and the parties separated on 311 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date laintiff, Pro e I, _F'hc?c,z ?S4?<.( verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: Plaintiff, K"ro Se / Assisted by: Michael A. Scherer, Esq. O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 t- ?a Y . w _ ? !? ? ,? , ? ~_ \ ^_? _ __ V . ? s 4? . ;fit ?_•.5 ?.? . .,,? Rebecca J. Barclay Plaintiff V. Tony W. Barclay Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- ) 6 7 7 CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Rebecca J. Barclay, Plaintiff, to proceed in forma ap uperis. I, Michael A. Scherer, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. - 141A lkq 1. - Mic ae1 . Scherer, Esquire Attorney for Plaintiff O'Brien, Baric & Scherer 19 West South Street Carlisle, PA 17013 (717) 249-6873 t-, r.,a .? ?? - K=? } ?o - _ ? ? ? ? _ ? i F? s^J ?--1 ???` C'; _? , _ ' ;"? ?" r 1 .? ?; Rebecca J. Barclay IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 10-7q CIVIL TERM Tony W. Barclay Defendant IN DIVORCE ACCEPTANCE OF SERVICE 1, Tony W. Barclay (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand.that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 3 ?- Date ony W. Barclay, Defendant w J; T 3 Rebecca J. Barclay IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA NO. 09- CIVIL TERM Tony W. Barclay Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A??c^^o,mplaint in divorce Sunder §3301(c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: e°' Signature: ?d ^ Rebecca J. arclay, Plaintiff AL.EC Uri EvE OF THE PR,; F ?N0, NARY 2009 JUN 30 Ail 10: 4 2 I 6 ? ?i.r?ttif• Rebecca J. Barclay Plaintiff V. Tony W. Barclay Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- la?tl CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 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 statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 07- Signature: Rebecca . Barclay, Plaintiff FILED-01-i?iCE CE THE FRRIC'''-i :r-?N!O- ARY 2009 JUN 30 Ail 10: 4 2 CUM! JU Rebecca J. Barclay IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 09- IM CIVIL TERM Tony W. Barclay Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: ,25 _a Signature` ny W. Barclay, Defendant RLED--O?T CE '",`? ?'`'':?T,!?Y OF THE 2099 JUN 30 AH 10: 41 1 ,'UN 1 i ate..: ?. kl 1 Rebecca J. Barclay Plaintiff V. Tony W. Barclay Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 09- 16qq CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. ?. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 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 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 unsworn falsification to authorities. Dateh °?3 Q Signature: T Barclay, Defendant ALEG-C)ill 11 In, P OF THc PP ; T a0-N!OT * Y 2009 JUN 30 Ali 10: 4 1 Rebecca J. Barclay Plaintiff V. Tony W. Barclay Defendant NO. 09- 107Lj CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on /° `6a h `1 , 2'0 0? 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, 6 1 el ' '31 ; by Defendant, 6'13 "01 4. Related claims pending: There are no outstandin clg aims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: lQ- Plaintiff's Social Security Number: Defendant's Social Security Number: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA It,?) -Ciq - ?q I Rebecca J. arclay ALI-I 'I I 2009 JUL -8 P?'t 2 c wr_ , i ? t r