Loading...
HomeMy WebLinkAbout01-0854TERRI BARR, Plaintiff DELWIN BARR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 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. 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 at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 TERRI BARR, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. o~- ~'~'~ ~ 'T'~,,,-- : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE Plaintiff, Terri Barr, is an adult individual, who currently resides at 24 Oak DELWIN BARR, Defendant Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. Her date of birth is September 8, 1949, and her social security number is 206-38-9407. 2. Defendant, Delwin Barr, is an adult individual who currently resides at 1550 Williams Grove Rd., Lot 128, Mechanicsburg, Cumberland County, Pennsylvania 17055. His date of birth is August 6, 1942, and his social security number is 206-32- 1987. 3. Plaintiff and Defendant have been bonafide residents in the Commonwealth of Pennsylvania fbr a period of at least six (6) months immediately previous to the filing of this Complaint in Divorce. 4. The Plaintiff and Defendant were married on December 4, 1971, in Harrisburg, Dauphin County, Pennsylvania. 5. The marriage is irretrievably broken. 6. 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 counseling. 7. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, Dated: February 12, 2001 Heather M. Faust Attorney ID #77947 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Complaint in Divorce upon the following by depositing a copy of same in the United States mail, regular and certified, restricted delivery, return receipt, postage prepaid, addressed as follows: Mr. Delwin Barr 1550 Williams Grove Rd. Lot 128 Mechanicsburg, PA 17055 Dated: February 13, 2001 218 Pine Street Harrisburg, PA 17108-0886 (717) 232-1851 TERRI BARR, Plaintiff DELWIN BARR, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-854 Civil Term : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Delwin Barr, do hereby swear and affirm that I accepted service of a tree and correct copy of the above-captioned Complaint in Divorce on February ./,~, 2001. Delwin Barr 1550 Williams Grove Rd. Lot 128 Mechanicsburg, PA 17055 TERRI BARR, Plaintiff DELWIN BARR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-854 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 12, 2001. 2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Date: 0 ~/~//0 [ Terri Bart Plaintiff TERRI BARR, Plaintiff DELW1N BARR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-854 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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 ifI 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. § 4904 relating to unsworn falsification to authorities. Date: O ~'/,,2_//t~ / Terri Barr Plaintiff TERRI BARR, Plaintiff DELWIN BARR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-854 CIVILTERM IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 12, 2001. 2. The marriage ofplaintiffand defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Delwin Barr Defendant TERRI BARR, Plaintiff DELWIN BARR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COLrNTY, PENNSYLVANIA : : NO. 01-854 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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 ifI 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. § 4904 relating to unsworn falsification to authorities. Date: Delwin Barr Defendant TERRI BARR, Plaintiff DELWIN BARR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-854 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under Section 330 l(c) of the Divorce Code. Date and manner of service of the complaint: By certified mail, restricted delivery, return receipt, to Defendant on February 15,2001, as evidenced by the attached Affidavit of Acceptance of Service and the copy of the return receipt, which are being filed contemporaneously herewith. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on May 21, 2001; by Defendant on May 20, 2001, which are being filed contemporaneously herewith. Date of execution of waiver of notice: by Plaintiff on May 21,2001; by Defendant on May 20, 2001, which are being filed contemporaneously herewith. Dated: June 7, 2001 Heather M. Faust Attorney ID #77947 Killian & Gephart 218 Pine Street Harrisburg, PA 17101 (717) 232-1851 Attorneys for Plaintiff IN THE COURT OF COMMON TERRI Of CUMBERLAND COUNTY STATE OF ~ PENNA. BARR, Plaintiff PLEAS NO. 01-854 civil Term VERSUS DELWIN BARR, Defendant AND NOW, DECREED THAT DECREE IN DIVORCE TERRI BARR , IT IS ORDERED AND , PLAINTIFF, AND DELWIN BARR ,DEFENDANT, ARE DIVORCED From THE BONDS OF MATRIMONY. THE cOUrT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD iN THIS ACTION FOR WHiCh A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE bY ~.COdF~t: a /