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Home My WebLink About10-14530 Dodi L. Alexander-Barber Plaintiff V. N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10- y !?3_ CIVIL TERM James D. Barber Defendant IN DIVORCE 3 - a 2 Y ?w w . ?C; •V .? k_-D Ze X NOTICE TO DEFEND AND CLAIM RIGHTS na YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims et foh 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 ? v Dodi L. Alexander-Barber Plaintiff V. James D. Barber Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10- 11-153 CIVIL TERM IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is?Joc? i3ar(Ocr , who currently resides at t '11_1V4 5 Cumberland County, Pennsylvania. ` s . PA 1 2. Defendant is Jc- M e S? ?, ?r , who currently resides at 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 A) y?e^ l S , a(Jt? ?_ at 5. The marriage is irretrievably broken, and the parties separated on -- N\G? 1 aWQ 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. Ail a act i u 19 KF Date laintiff, P Se Il)na? Pc?e?e,.c?el'-Uc:T f , 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. 'ql 2- -zl2y?o Date. ?ive'M- P aintiff, ro Se Assisted by: Jerry Brown, Esq. 4601 S. Clearview Dr. Camp Hill, PA 17011 (717) 737-9174 N C5 Dodi L. Alexander-Barber Plaintiff V. James D. Barber Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10- )Y S3 CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: moo. W Kindly allow, Dodi L. Alexander-Barber Plaintiff, to proceed in forma au eris. I, Jerry Brown, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am pro V' ng a legal services to the party. Jerry , Esquire Atto y for Plaintiff 4601 . Clearview Dr. C Hill, PA 17011 (71 737-9174 To 65-,4 fr Dodi L. Alexander-Barber IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. CIVIL ACTION - LAW James D. Barber NO. 2010 - 1453 Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, James D. Barber, the undersigned, hereby state that I personally received and accepted a true and correct copy of: 1 C . omplaint in Divorce and Verification MW = 2. Notice to Defend and Claim Rights ;;Mm :M= C1 r nr- ? 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. Date:.' James D. Barber Defendant, Pro se Dodi L. Alexander-Barber IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANI A V. NO. 10-1453 CIVIL TEOR James D. Barber rn rn Defendant c ?-- IN DIVORCE r 7i CD -? ? p: CD -r AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on March 2, 2010. 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: Signature: / i k.odiL ? ? A ander-Barber, Plaintiff Dodi L. Alexander-Barber Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-1453 CIVIL TERg rrvy James D. Barber M3 Defendant IN DIVORCE =M r- = _"7 C ) > fla CZ) -q AFFIDAVIT OF CONSENT t 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on March 2 2010. - , 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: 1?-? Signat e: ! ?.- James D. Barber, Defendant Dodi L. Alexander-Barber IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-1453 CIVIL TERM) James D. Barber ; mCZD Defendant IN DIVORCE c:;a c? N> co r11 JTJ 1. 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 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Signature: 1 La / h odi . lexander-Barber, Plaintiff Dodi L. Alexander-Barber Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10-1453 CIVIL TERMS ? =` James D. Barber CO r-n r7l Defendant IN DIVORCE N co I L s9 ? ^?' a?.». .` C:0 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY O A C-n DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 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 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: /-W- _Z 5- / [j Signa James D. Barber, Defendant DODI L. ALEXANDER-BARBER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 2010 - 1453 CIVIL TERM JAMES D. BARBER a"u' Defendant IN DIVORCE rncv X rq rn --s 'rr = PRAECIPE TO TRANSMIT RECORD :Z? C-1) c r -am o To The Prothonotary: -? j7- Transmit the record, together with the following information to the Court f-Qj , 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 and stated Date of Acceptance of Service as April 4 2010. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, December 22, ; by Defendant, December 25, 2010 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: December 28, 2010. 6. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed. with the Prothonotary: December 28, 2010. Abraham r sky, Esquire Attorne or Plaintiff Supre Court Id # 209787 674 Stover Court Hummelstown, PA 17036 DODI L. ALEXANDER-BARBER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JAMES D. BARBER NO. 2010 - 1453 DIVORCE DECREE , it is ordered and decreed that AND NOW, 4 O;b /I DODI L. ALEXANDER-BARBER plaintiff, and JAMES D. BARBER 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 ourt, Cerf• 4y m a.ilod yb aAy Prozm Mpis N04t& * y M44 kd in Ddff