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Home My WebLink About09-6301T KATHERINE J. BARRICK, Plaintiff, V. CARL L. BARRICK, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - L901 CIVIL TERM 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 will proceed without you and a decree in divorce or annulment may 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 KATHERINE J. BARRICK, Plaintiff, V. CARL L. BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - L.301, CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is Katherine L. Barrick, an adult individual whose current residence is 1844 Holly Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Carl L. Barrick, an adult individual whose current residence is 657 Mallard Drive, Etters Pennsylvania. 3. The Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and the Defendant were married on or about June 26, 1993, in Hunterdon County, New Jersey. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. The Plaintiff and the Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since April 2005 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. The Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, the Plaintiff respectfully requests your Honorable Court to enter a decree in divorce. Q14 0111©9 _ Date Respectfully Submitted, TURO LAW OFFICES Lori ndrew ny er, Esquire P D#203 9 98 Sou; itt Street C e, PA 17013 Phone: 717-245-9688 Fax: 7171-245-2165 VERIFICATION I, Katherine J. Barrick, verify that the statements made in the foregoing Divorce Complaint are true and correct. 1 understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. d ? 4 / DatC- Ka erine J. Bar is KATHERINE J. BARRICK, Plaintiff, V. CARL L. BARRICK, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Complaint in Divorce on Defendant, Carl L. Barrick, by depositing same in the United States Mail, first class, postage pre-paid, certified, return receipt requested, on the Twenty-First day of September, 2009, from Carlisle, Pennsylvania, addressed as follows: Carl L. Barrick 657 Mallard Drive Etters, PA 17319 TURO LAW OFFICES er, Esquire treet F outR?77013 slee: 7 -245-9688 Fax: 7 ,P.245.2165 T r F 0/1 -rte iF `?"? t,.py OF tH ;.:111:0' ,,. v. 2Cl 99 SL' 21 PI 2: 39 s?Y 3 3 S. SU7? ?? jZ4 Q'61"7