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HomeMy WebLinkAbout09-3589V NEILL A. BERRY, JR., Plaintiff v. PATRICIA A. BERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 6/?- 3S?I cN'? f 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 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, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6100 NEILL A. BERRY, JR., Plaintiff V. PATRICIA A. BERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: Q 9- 3 5" c ?'J, i f crag CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Neill A. Berry, Jr., who currently resides at 1318 Pine Rd., Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Patricia A. Berry, who currently resides at 1318 Pine Rd., Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 16, 2005. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provisions of the Divorce Code, Sections 3301(a)(6), 3301(c), and 3301(d), in that: a. The Defendant offered such indignities to the Plaintiff as to render Plaintiff's condition intolerable and life burdensome. b. The marriage is irretrievably broke. 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 such counseling. 8. Plaintiff does not request counseling, pursuant to §§3301(c) and 3301(d) of the Divorce Code. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Date: ? -'; - 0 By: Andrew H? Shaw, Esquire Sup. Ct. ID No. 87371 200 South Spring Garden St. Suite 11 Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff VERIFICATION I, Neill A. Berry, Jr., 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: Neill A. Berry, Jr. C-1100 i L P-7 T /?'? ?-a6 600 17 A NEILL A. BERRY, JR., Plaintiff V. PATRICIA A. BERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Nu.: 09- 3584 C:iv;l -Farm CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE I, Andrew H. Shaw, Counsel for the Plaintiff, Neill A. Berry, Jr., hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant via personal service on June 10, 2009. A copy of the signed certified receipt is attached. Date: ?-- ?(v U I Andrew H. Shaw, Esquire PA Sup. Ct. ID Num. 87371 200 S. Spring Garden St., Suite 11 Carlisle, PA 17013 717-243-7135 Counsel for Plaintiff i? 2 N o 3 I i i I) ?C3 0 O ?C3 O O 03 O ru to c z =3 -v{, a m O ? h i m (I) 4-1) ?< o ' Mo m C a g a a W P j: ? a M QO x CERTIFICATE OF SERVICE I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following document, Proof of Service, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Patricia Berry 1318 Pine Road Carlisle, PA 17015 Date: Sup. Ct. I.D. No. 87371 200 S. Spring Garden Street Carlisle, PA 17013 (717) 243-7135 (phone) (717) 243-7872 (facsimile) Attorney for Plaintiff 2 0 0 9 JUN 22 Pt, " 2: " CUAI ;.v r, . Edmund J. Berger Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 (717) 920-8900 tberger@bergerlawfirm.net IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILL A. BERRY Plaintiff V. Docket No. 09-3589 Civil Term PATRICIA A. BERRY Defendant 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 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: Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 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, 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 "ISO USTED HA SIDO EMANDADO/A EN CORTE. Si usted desea defenderse de [as demandas que se presentan mas adelente en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacibn de esta Demanda y Aviso readicando personalmente o por medio de un abogado una comparecencia escrita y radicando en las Corte por escrito sus defenses de, y objecciones a, las demanda presntadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFOMACION A CERCA DE COMO CONSEQUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILL A. BERRY Plaintiff V. PATRICIA A. BERRY, JR. Defendant Docket No. 09-3589 Civil Term CIVIL ACTION-Law IN DIVORCE COUNTERCLAIM IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE Defendant above-named, plaintiff on the counterclaim, by her attorney, Edmund J. Berger, Esq., files the following counterclaim and respectfully represents that: Count One-Divorce 1. Plaintiff on the counterclaim is Patricia Berry, who currently resides at 1318 Pine Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant on the counterclaim is Neill Berry who currently resides at 1318 Pine Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff on the counterclaim/Defendant on the Complaint and Defendant on the counterclaim/Plaintiff on the Complaint have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this counterclaim. 4. Plaintiff on the counterclaim and defendant on the counterclaim were married on September 16, 2005. 5. There have been no prior actions for divorce or annulment between the parties, except the complaint filed in this instant matter. 6. The marriage is irretrievably broken. Plaintiff on the counterclaim requests the court to enter a decree of divorce. Count Two-Equitable Distribution 7. Paragraphs 1 through 6 of this counterclaim are incorporated herein by reference as though set forth in full. 8. Plaintiff on the counterclaim and Defendant on the counterclaim have legally and beneficially acquired property, both real and personal, during their marriage from September 16, 2005, until the present, which property is "marital property." 9. Plaintiff on the counterclaim and Defendant on the counterclaim may have owned, prior to the marriage, property, both real and personal, which property has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property." 10. Plaintiff on the counterclaim and defendant on the counterclaim have been unable to agree as to an equitable division of said property to the date of the filing of this counterclaim. WHEREFORE, Plaintiff on the counterclaim requests the Court to equitably divide all marital property, and, in addition, to order the continuation of health insurance coverage. Count Three-Alimony 11. Paragraphs 1 through 10 of the counterclaim are incorporated herein by reference as though set forth in full. 12. Plaintiff on the counterclaim lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 13. Plaintiff on the counterclaim requires reasonable support, including the provision of health insurance, to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff on the counterclaim requests the Court to enter an award of reasonable temporary alimony, continuation of health insurance coverage, and additional sums as they may become necessary from time to time hereafter until final hearing and permanently thereafter. Count Four- Attorney's Fees, Costs, and Expenses 14. Paragraphs 1 through 13 of the counterclaim are incorporated herein by reference as though set forth in full. 15. Petitioner has employed Edmund J. Berger Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 16. Petitioner has entered into a fee agreement with her attorney, a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit A. WHEREFORE, Petitioner requests your Honorable Court to enter an award of temporary counsel fees, costs, and expenses in the sum of $2500.00 and such additional sums as they may become necessary from time to time hereafter until final hearing, and thereupon at final hearing, award such additional counsel fees, costs and expenses as are deemed appropriate. Dated: July 6, 2009 Edmund J. Berger Attorney for Plaintiff Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Phone: (717) 920-8900 Fax: (717) 920-8901 r I1 U, VI IV 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 cf 98 Pa. Cons. Stat. Ann. § 4904, relating to unsworn falsification to authorities. Date: July 2, 2009 Patricia A. Berry 800/800d WeSZ:II 6002 9 Inf :xBJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILL A. BERRY Plaintiff V. Docket No. 09-3589 Civil Term PATRICIA A. BERRY CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document, COUNTERCLAIM IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE, upon the following person and in the manner indicated. FIRST CLASS MAIL Andrew H. Shaw, Esq. 200 South Spring Garden Street Suite 11 Carlisle, PA 17013 Date: July 6, 2009 Edmund J. Berger Attorney I.D. #53407 Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Phone: (717) 920-8900 Fax: (717) 920-8901 E-Mail: tberger@bergerlawfirm.net F;1 i a •?\ OFT i r} 412.00 P° ATN CICW 4057 3 .* NEILL A. BERRY PATRICIA A. BERRY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. N0.09-3589 Civil Term 2009-# i~ S~-+=~ r~ ~"3 Defendant ~~~`' -~ MOTION FOR APPOINTMENT OF MASTER !;moo -b Defendant ,moves the court to appoint a master with ri~~t to'`:-- the following claims: ~"'~ ~ .. OX Divorce QX Distribution of Property -`~ ".~ - ^ Annulment ^ Support `~~ t:r+ ~X Alimony ~ Counsel Fees ^ Alimony Pendente Lite ~ Costs and Expenses and in support of the motion states: I. Discovery is comulete as to the claims (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his atorney,_ Edmund J. Berger ,Esquire). 3. The staturory Around (s) for divorce is SECTION 3301(c) OF THE DIVORCE CODE 4. Delete the inapplicable paragraph (s): A OX B © C ^ a. The action is not contested. b. An agreement has been reached with respect to the followine claims: C. The action is contested with respect to the following claims: Alimony, Distribution of Property, Counsel Fees, Costs and Expenses 5. The action involves 6. The hearing is expected to take ? Additional information, if any, relevant to the tion: Date: 14!0612010 Attorney for Defendant Edmund J. Berger Print Name ORDER APPOINTING MASTER AND NOW complex issues of law or fact. hours 20 , is appointed master with respect to the following claims: Esquire, -~~ ~~ t'~"ti f~ a.'~ t,Y~ ''~ t':.1 ~~ ---i ~ ~~: c::.:1-r°1 t~ ~ t~'1 By the Court, `f ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILL A. BERRY . Plaintiff . v. PATRICIA A. BERRY Docket No. 09-3589 Civil Term CERTIFICATE OF SERVICE I hereby certify that I have this day served a true copy of the foregoing document, Motion for the Appointment of a Master, upon the participants, listed below, in accordance with the requirements of § 1.54 (relating to service by a participant): FIRST CLASS MAIL Andrew H. Shaw, Esq. 200 South Spring Garden Street Suite 11 Carlisle, PA 17013 Date: October 6, 2010 Edmund J. Berger Attorney I.D. #53407 Berger Law Firm, P.C. 2104 Market Street Camp Hill, PA 17011 Phone: (717) 920-8900 Fax: (717) 920-8901 E-Mail: tberger@bergerlawfirm.net ., ~. NEILL A. BERRY PATRICIA A. BERRY OCT 0 81U10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. ~;'~ 09 3589 Ci il T ~ ~ - v erm 2Q.09 NO. c~ ~ = ~ -~~-i • L/ L crt ~ Defendant ~ MOTION FOR APPOINTMENT OF MASTER ~' `~ ~ -v Defendant ,moves the court to appoint a master with r~~pt to'=> the following claims: ~-~ ^X Divorce ^X Distribution of Property a'~' ~ '~ -s ~., ^ Annulment ^ Support X^ Alimony ^X Counsel Fees ^ Alimony Pendente Lite ^X Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is requested. 2. The defendant has appeared in the action (personally) (by his attorney,_ Edmund J. Berger Esquire). 3. The staturory ground (s) for divorce 's SECTION 3301(c) OF THE DIVORCE CODE Delete the inapplicable paragraph (s): A ^X B ^X C ^ a. The action is not contested. b. An a¢reement has heen reached with resnect to the followine claims: C. The action is contested with respect to the following claims: Alimony, Distribution of Property, Counsel Fees, Costs and Expenses 5. The action involves 6. The hearing is expected to take ? complex issues of law or fact. hours 7. Additional information, if any, relevant to the tion: Date: 10/06/2010 Attorney for Defendant Edmund J. Berger Print Name ORDER APPOINTING MASTER AND NOW , 20 LO , ~,L~~ 10~,~~,,~v .~ Esquire, is appointed master with respect to the following claims: ~0 ~- . ~~ ~ Q ~ ts! _ ' ~. ~ 1 ~; ^ <-+" ~i .~ C7 n l~L~ ~i~ I'~1~,t tel. U e ~ ~.. i.- ~ l ~~ ~ .~~ A• By the Court, J. 0 _,1 _..{ Try, !`~"t --- w,.~ rY1 t~ `~ ~--rt ~-~ o ~' --;~ ~~ Y NEILL A. BERRY, JR., Plaintiff V. PATRICIA A. BERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No.: 09-3589 C= rn -,r-- 'Dom ACTION - LAW IN DIVORCE : ' AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on June 1, 2009. 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 the decree. 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 unsworn falsification to authorities. Dated: 6 Neill A. Berry, Jr., Plainti NEILL A. BERRY, JR., Plaintiff V. PATRICIA A. BERRY, Defendant W ON IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 09-3589 m c- -n rr' CIVIL ACTION -LAW =m " vs ? ) IN DIVORCE D y - C_Z c a REQUEST ENTRY OF A I VQRC 1 OF THE DIVORCE CODS 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 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. Dated: Neill A. Berry, Jr., Pla' iff OF THFEILPERDO- OFFICE 2011 JUN 24 A1411: 26 IN THE COURT OF COMMON PLEAS MiBERLAND COUNTY ENNSYLVANIA CUMBERLAND COUNTY, PENNSYLVANIA NEILL A. BERRY, JR., Docket No. 09-3589 CIVIL TERM Plaintiff V. PATRICIA A. BERRY Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on June 1, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint. 3. 1 consent to the entry of a final decree of divorce. 4. 1 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. 5. 1 verify that the statements made in this affidavit are true and correct. understand that false statements are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: atricia A. Berry IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NEILL A. BERRY, JR., Docket No. 09-3589 CIVIL TERM Plaintiff . V. IN DIVORCE PATRICIA A. BERRY Defendant C-- n z car- -z-. " r- r) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE c = o * -zt Na a A r 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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 are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904 relating to unsworn falsification to authorities. Date: 6 13-1 atricia A. Berry NEILL A. BERRY, JR., THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09 - 3589 CIVIL C`' ^" r PATRICIA A. BERRY,r lr Defendant IN DIVORCE Fri co CD ORDER OF COURT Q: AND NOW, this F4 day of , 2011, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated June 14, 2011, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, Kevin . Hess, P. J. cc: V1 Andrew H. Shaw Attorney for Plaintiff Edmund J. Berger 81$1 ?? Attorney for Defendant l ub NEILL A. BERRY, JR., Plaintiff V. PATRICIA A. BERRY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 09-3589 CIVIL ACTION - LAW IN DIVORCE rn CO ?M z:;o PRAECIPE TO TRANSMIT RECORD To the Prothonotary: -, CZ ,cap c x?. 90 r- Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified return receipt signed by Defendant on June 10, 2009. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff on June 14, 2011; by Defendant on June 23, 2011; 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary's Office: June 16, 2011. Date Defendant's Waiver of Notice was filed with the Prothonotary's Office: June 24, 2011. p Date: Q " jo - ?? By: rew H. Shaw, Esquire Attorney I.D. # 87371 200 Spring Garden Street, Ste. 1 I Carlisle, PA 17013 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following document, Praecipe To Transmit Record, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Edmund "Tad" Berger, Esquire 2104 Market Street Camp Hill, PA 17011 Attorney for Defendant Date: d -//- I/ NEILL A. BERRY, JR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICIA A. BERRY NO. 09-3589 DIVORCE DECREE AND NOW, yr f? C/ ,it is ordered and decreed that NEILL A. BERRY, J d , plaintiff, and PATRICIA A. BERRY , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, ?ZAAttest: J. Prothonotary ?a??e? ? ?? shy #07?ce- ?