HomeMy WebLinkAbout10-2788J ?? rt arL
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2010 OR 26 Pri 4* 02
MARY ANN BERRIAN,
Plaintiff
CU
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
VS.
ROBERT F. BERRIAN,
Defendant
CIVIL ACTION - LAW
NO. J0 - a awe 6pj
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
foregoing 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 in 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:
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,
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 5 .06 32 SOUTH BEDFORD STREET P ??
CARLISLE, PA 17013 ' 7G F3
Telephone: (717) 249-3166
i
MARY ANN BERRIAN,
Plaintiff
vs.
ROBERT F. BERRIAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
IN DIVORCE
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a 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.
MARY ANN BERRIAN,
Plaintiff
VS.
ROBERT F. BERRIAN,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, MARY ANN BERRIAN, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is MARY ANN BERRIAN, an adult individual who currently resides at
143 North 26t' Street in Camp Hill, Cumberland County, Pennsylvania.
2. The Defendant is ROBERT F. BERRIAN, an adult individual who currently resides
at 129 Clemens Lane in Bellefonte, Pennsylvania 16823.
3. Both the Plaintiff and Defendant have been bona fide residents 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 5 October 1985 in Gettysburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the
Divorce Code of Pennsylvania.
vc?
Samuel L. es
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12'' Street
Lemoyne, Pa 17043
(717) 761-5361
I verify that the statements made in this Complaint are true and correct. I understand that
any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unworn
falsification to authorities).
Date:
MARY BERRIAN
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201D ,~~~~ 14 Ate 11 ~ 31
Ct,=fir°-
~~.; ~~ l,'.JUNTY
~~)~~'~~'LV~1"!~/~: IN THE COURT OF COMMON
MARY ANN BERRIAN,
PLAINTIFF ) PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
vs. ) CIVIL ACTION-LAW
NO. 2010-2788 CIVIL TERM
ROBERT F. BERRIAN, )
DEFENDANT ) IN DIVORCE
ACCEPTANCE OF SERVICE
I, ROBERT F. BERRIAN, hereby accept service of the original Complaint in Divorce
and acknowledge receipt of a copy of the Complaint.
Date: S ~ ~~
~~~
_~
ROBERT F. BERRIAN
4
MARY ANN BERRIAN, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
ROBERT F. BERRIAN,
NO. 2010-2788 CIVIL TERM
DIVORCE DECREE
AND NOW, it is ordered and decreed that
MARY ANN BERRIAN, plaintiff, and
ROBERT F. BERRIAN, , 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
:laims remain indicate "None.")
NONE
By the Court,
J.
Prothonotary
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