HomeMy WebLinkAbout04-5323
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JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
T ARICK HUSSEIN BEREME,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. ol.f-S?JJ..3 CIVIL TERM
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 right 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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'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 LA WYER 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, PAl 7013
(717) - 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court, You must attend the scheduled conj)~rence or hearing.
JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANI) COUNTY, PENNSYL VANIA
v.
TARICK HUSSEIN BEREME,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. 0'1. rJp CIVIL TERM
COMPLAINT UNDER SECTION 3301 Cd) OF THE DIVORCE CODE
1. Plaintiff is Jamie Folkenroth, who currently resides at 4542 Rolo Court, Mechanicsburg,
Cumberland County Pennsylvania, 17055.
2, Defendant is Tarick Hussein Bereme, whose current address is unknown.
3. Plaintiff has been a bona fide resident in the Commonw(~alth for at least six months
immediately previous to the filing of this Complaint.
4, Plaintiff and Defendant were married on September 15, 200 I in Carlisle, Cumberland
County, Pennsylvania, 170\3.
5. Plaintiff and Defendant have lived separate and apart since February 2002.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, Plaintiff requests that the court enter a decree of divorce dissolving the
marriage.
Respectfully submitted,
Date: 10 /JI /01-
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Erin Chafin
Certified Legal Intern
T2:~M. lace
Anne MacDonald-Fox
Lucy Johnston-Walsh
Robert E. Rains
SUPERVISING ATTORNEY
F AMIL Y LA W CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717)243-2968
VERIFICATION
I verifY that the statements made in this Complaint are tme and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to
unsworn falsification to authorities.
Date:/O -dZ/-tJf
',d~
JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
T ARICK HUSSEIN BEREME,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: NO,
CIVIL TERM
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you or the statements
will be admitted.
AFFIDAVIT UNDER SECTION 330Hd) OF THE DIVORCE CODE
I. The parties to this action separated in February 2002, and have continued to live separate
and apart for a period of at least two years.
2. The marriage is irretrievably broken,
3. 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.
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. S 4904 relating to unsworn
falsification to authorities.
Date:/O -cfl./-o'f
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JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
T ARICK HUSSEIN BEREME,
Defendant
: NO. 04-~))3 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Jamie Folkenroth, Plaintiff, to proceed in fonna pauperis.
The Family Law Clinic, attorneys for the party proceeding in fonna pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date 1012, //)1
I I
Respectfully submitted,
~t4'~
Certified Legal Intern
,L~
ROBE . RAINS
THOMA M. PLACE
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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JAMIE FOLKENROTH
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLA!'ID COUNTY, PENNSYL VANIA
v.
TARICK HUSSEIN BEREME,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. 04-5325
CIVIL TERM
PETITION PURSUANT TO PA. R.c.p 430 FOR
SPECIAL ORDER DIRECTING METHOD OF SERVICE
Petitioner, Jamie Folkenroth, by her attorneys, the Family Law Clinic, respectfully
requests this Court to enter an Order directing method of service on Tarick Hussein Bereme by
publication, once in the Carlisle Sentinel newspaper and once in the Cumberland County Law
Journal, and in support of the petition states the following:
1. Plaintiff is Jamie Folkenroth whose current address is 4542 Rolo Court, Mechanicsburg,
Pennsylvania 17055.
2. Defendant is Tarick Hussein Bereme whose last known address is unknown. Defendant
is a citizen of Saudi Arabia and is believed to have been deported to Saudi Arabia in
2002,
3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been for at
least 6 months prior to the filing of the original Divorce Complaint.
4. Plaintiff and Defendant were married on September 15,,2001 in Carlisle, Pennsylvania.
5, The parties separated in February 2002, and have lived separate and apart since that time.
6, On October 22, 2004, a Complaint for Divorce was filed in the Cumberland County
Courthouse. See attached "Exhibit A"
7. Plaintiff has had no contact with Defendant since their separation in February 2002.
8. Plaintiff has made a good faith effort to locate Defendant including the following:
a. Plaintiff has made inquiries of the Federal Bureau ofInvestigation and the
Immigration Naturalization Service regarding the whereabouts of
Defendant. In response to these inquiries, Plaintiff was informed that
Defendant had been deported to Saudi Arabia without leaving a
forwarding address.
b. Plaintiffs counsel has located and contacted John Rudy, who was
Plaintiffs landlord and who introduced her to Defendant, in hopes of
learning Defendant's whereabouts. Rudy claims to have no knowledge of
Defendant's whereabouts.
c, Plaintiff knows of no further friends or family members to whom she may
address inquiries regarding Defendant's whereabouts.
8, Plaintiff does not know whether the Defendant is in Saudi Arabia and, if so, where
he is residing. Furthermore, Plaintiff has no way of obtaining such information.
WHEREFORE, Plaintiff requests that this Court enter 2m order directing method of
service of the Complaint for Divorce under !l3301 (d) as follows: by publishing the Notice
attached hereto as "Exhibit B", once in the Cumberland County Law Journal and once in the
Carlisle Sentinel newspaper_
Date: I() If) lJ /01--
t /
Respectfully submitted,
~~~
Certified Legal Intern
~~~41
ANNE MACDONALD-FOX
LUCY JOHNSTON- WALSH
ROBERT E. RAINS
Supervising Attorneys
THE F AMIL Y LA W CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
JAMIE FOLKENROTH
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
T ARICK HUSSEIN BEREME,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
: NO. 04-5325
CIVIL TERM
AFFIDAVIT
I. I, Erin Chafin, am currently employed as a Certified L,~gal Intern by Plaintiff s counsel,
the Family Law Clinic, located at 45 North Pitt Street, Carlisle, Cumberland County,
Pennsylvania 17013.
2. I contacted John Rudy, Plaintiffs former landlord, because Plaintiff expressed a belief
that Mr. Rudy might know Defendant's whereabouts.
3. Mr. Rudy called me back on February 20,2004. At that time, Mr. Rudy told me that he
had not seen or spoken to Defendant for more than a year, and he denied any knowledge of
Defendant's whereabouts.
I verifY that the statements made in this affidavit are trw: and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. g 4904, relating to
unsworn falsification to authorities.
Date:
IO/J.bk4
I f
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Certified Le,gal Intern
VERIFICATION
I verifY that the statements made in this Petition for Special Order Directing Method of
Service are true and correct to the best of my personal knowl,:dge and belief. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to
unsworn falsification to authorities.
Date: IO-c:2/- ~4t
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JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
TARICK HUSSEIN BEREME,
Defendant
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: NO. O'/.!i ')JJ CIVIL TERM
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NOTICE TO DEFEND AND CLAIM RIGHTS
'''''''J
You have been sued in court. If you wish to defend against the claims set forthjn the'"
following p"'" you m"" wk' prompt "tion. You"" w,,",d ""' if you r.;l (0 do "1th,.,,,
m'" pro~'" withom you md , d=~ of di.."" " mnulmml m'y b, moored "...' you by th,
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 right 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 m'" _m1 m_" "",",ling. A Ii" of "",,"'" "u,",lo~ · m,il,b. m tho Otlk' of
the Prothonotary, Cumberland County Courthouse, 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 ALA WYER 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, P A 17013
(717) - 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or hearing.
JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
TARICK HUSSEIN BEREME,
Defendant
: NO. 04 -532-} CIVIL TERM
COMPLAINT UNDER SECTION 3301 (d) OF THE DIVORCE CODE
1. Plaintiff is Jamie Folkenroth, who currently resides at 4542 Rolo Court, Mechanicsburg,
Cumberland County Pennsylvania, 17055.
2. Defendant is Tarick Hussein Bereme, whose current address is unknown.
3. Plaintiffhas been a bona fide resident in the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on September 15, 2001 in Carlisle, Cumberland
County, Pennsylvania, 17013.
5. Plaintiff and Defendant have lived separate and apart s;ince February 2002.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, Plaintiff requests that the court enter a decree of divorce dissolving the
marriage.
Respectfully submitted,
Date: 10 jell /01-
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Certified Legal Intern
T2:~~~ lace
Anne MacDonald-Fox
Lucy J ohnston- Walsh
Robert E. Rains
SUPERVISING ATTORNEY
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717)243-2968
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 of 18 Pa.C.S. S 4904, relating to
unsworn falsification to authorities.
Date:/O -d./ -tJ.f
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.
JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
TARICK HUSSEIN BEREME,
Defendant
:NO.
CIVIL TERM
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you or the statements
will be admitted.
AFFIDA VlT UNDER SECTION 330H d) OF THE DIVORCE CODE
1. The parties to this action separated in February 2002, and have continued to live separate
and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses if! do not claim them before a divorce is granted.
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 I'a.C.S. S 4904 relating to unsworn
falsification to authorities.
DatejtJ -dl,/-o'-l
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mie Folkemoth
.
Exhibit "B"
LEGAL NOTICE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
NO. 04-5325 CIVIL TERM
IN DIVORCE
JAMIE FOLKENROTH V. TARICK HUSSEIN BEREME
TO: TARICK HUSSEIN BEREME
YOU HAVE BEEN SUED IN COURT. The Plaintiff., Jamie Folkemoth, by her
attorneys, the Family Law Clinic, has filed a Complaint for Divorce under S 330l(d) ofthe
Divorce Code. If you wish to defend against this claim, you must enter a written appearance
personally or by attorney and file your defenses or objections in writing with the court. You are
warned that if you fail to do so, the case may proceed without you and a decree of divorce may be
entered against you by the Court. You may lose property or other rights irnportant to you.
YOU SHOULD TAKE THIS NOTICE 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 MAYBE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGE''lCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
(717) 249-3166
V
OCT 2 8 2004 f
JAMIE FOLKENROTH
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
T ARICK HUSSEIN BEREME,
Defendant
: CIVIL ACTION - LA W
: IN DIVORCE
'53~3
: NO. 04~ CIVIL TERM
ORDER OF COURT
On this
I" day of
~
,2004, on consideration of the attached
Petition Pursuant to Pa.R.C.P. Rule 430 for Special Order Directing Method of Service, it is
ordered that service ofthe Complaint and Plaintiffs Affidavit under Section 3301(d) be made by
publication of the attached notice, once in the Cumberland County Law Journal and once in the
Carlisle Sentinel.
By the Court,
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JAMIE FOLKENROTH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V.
CIVIL ACTION-LAW
DIVORCE
T ARICK HUSSEIN BEREME,
Defendant
NO. 04-5323
CIVIL TERM
PRAECIPE TO REINSTATE THE COMPLAINT
To the Prothonotary:
Please reinstate the Complaint in the above-captioned case filed at the Cumberland
County Courthouse on October 22,2004.
Date: 11;'l q lei
I I
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~:fin .
Certified Legal Intern
~iIt..j)~AJP - ~
ROB . RAINS ~
THOMAS PLACE
LUCY JOHNSTON-WALSH
ANNE MACDONALD-FOX
Counsel for Defendant
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
T ARICK HUSSEIN BEREME,
Defendant
: NO. 04-5323
CIVIL TERM
AFFIDAVIT OF SERVICE
I, Erin E. Chafin, hereby certify that I am a competent adult and that, pursuant to an
Order of Court dated November 1, 2004, Defendant Tarick Hussein Bereme was served with
notice of the Complaint for Divorce filed against him on October 22, 2004 and reinstated on
November 19,2004 through publication of such notice in the Carlisle Sentinel on November 18,
2004 and through publication in the Cumberland County Law Journal on November 26, 2004.
Please see attached proof of publication, marked "Exhibit A" and "Exhibit B," respectively.
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: I d/1/(Jj
a;~%~
Erin E. Chafin
Certified Legal Intern
I~-~
Anne aId-Fox I
Lucy Jo ston-Walsh
Robert E. Rains
Thomas M. Place
Supervising Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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PROOF OF PUBLICATION
State of Pennsylvania, County of Cumberla.nd
Tammy Shoemaker, Classified Sales Manager, of The Sentinel, of the County and State
aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was
established December 13th, 1881, since which date THE SENTINEL has been regularly
issued in said County, and that the printed notice or publication attached hereto is
exactly the same as was printed and published in the regular editions and issues of
THE SENTINEL on the following date(s)
November 18, 2004
COPY OF NOTICE OF PUBLICATION
Affiant further deposes that he/ she is not
interested in the subject matter of the
aforesaid notice or advertisement, and that
all allegations in the foregoing statement
as to time, place and character of
~on~;<~~^-
Sworn to and subscribed before me this
24th day of November, 2004
r/if0MO.av ~. {ll'l-!jf
Notary P 'c
My commission expires: q /1 / cJ r-
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Christina L. Wolfe. Notary Public
Carlisle BOlO, Cumberland County
My Commission Expires Sept 1, 2008
Member. Pennsvlvania Association Ot Notaries
(~h~br1 6
CUMBERLAND LAW JOURNAL
32 SOUTH BEDFORD STREET
CARLISLE, P A 17013
November 26,2004
Cumberland Law Journal is published every Friday by the Cumberland County Bar
Association and is designated by the Court of Common Pleas as the official legal publication for
Cumberland County and the legal newspaper for publication of legal notices.
TO:
Family Law Clinic
RE:
F olkenroth v Bereme
Legal advertisements must be received by Friday Noon. All legal advertising must be
paid in advance. Make all checks payable to: Cumberland Law Journal.
----------------------------------------------------------------------
----------------------------------------------------------------------
Advertisementinserted on following dates:
November 26, 2004
Advertising Cost
$ 0.00
Proof of Publication
$ 0.00
Second Proof Request
$ 0.00
Payment Received
$ 0.00
Total Amount Due
$ 0.00
-------
---------
Payment received _
by Becky H. Morgenthal/Executive Director
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEAL TH OF PENNSYL VANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, Esquire, Editor ofthe Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the officia11egal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
NOVEMBER 26, 2004
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
<2-
S RN TO AND SUBSCRIBED before me this
26 day of NOVEMBER, 2004
NOTA I SEAL
LOIS E. SNYDER, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires March 5, 2005
d~~
CUMBERLAND LAW JOURNAL
LEGAL NOTICE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Term
No. 04-5323
JAMIE FOLKENROTH
v.
TARICK HUSSEIN BEREME
IN DIVORCE
TO: TARICK HUSSEIN BEREME
YOU HAVE BEEN SUED IN
COURT. The Plaintiff, Jamie Folken-
roth, by her attorneys, the Family Law
Clinic, has filed a Complaint for DI-
vorce under !l330 l(d) of the Divorce
Code. If you wish to defend against
this claim, you must enter a wrttten
appearance personally or by attor-
ney and file your defenses or objec-
tions In wrtting with the court. You
are warned that if you fail to do so,
the case may proceed without you
and a decree of divorce may be en-
tered against you by the Court. You
may lose property or other rights
Important to you.
YOU SHOULD TAKE THIS NO-
TICE TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER.
GO TO OR TELEPHONE THE OF-
FICE 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 SERV-
ICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
Cumberland County
Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Nov. 26
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JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LA W
: IN DIVORCE
T ARICK HUSSEIN BEREME,
Defendant
: NO. 04-5323
CIVIL TERM
CERTIFICATE OF SERVICE
I, Jessica L. Bowman, hereby certify that I served a Counter-Affidavit and a Notice of
Intention to Request Entry of a Divorce Decree on Tarick Hussein Bereme on February 22, 2005,
by first class United States mail, at the following address:
Tarick Hussein Bereme
250 Sample Bridge Road
Mechanicsburg, P A 17055
Date:~
. J ssica L. Bowman
( Certified Legal Intern
F AMIL Y LA W CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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JAMIE FOLKENROTH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
TARICK HUSSEIN BEREME,
Defendant
: NO. 04-5323
CIVIL TERM
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:
1. Ground for divorce: irretrievable breakdown under Section 3301(d) of the
Divorce Code.
2. Date and manner of service of the complaint: Served on Defendant,
pursuant to an Order of Court dated November I, 2004, through
publication of notice in the Carlisle Sentinel on November 18, 2004 and
through publication of notice in the Cumberland County Law Journal on
November 26, 2004.
3. Date of execution of the affidavit required by Section 3301(d) of the
Divorce Code: by the Plaintiff: October 21,2004. Date of filing of the
Affidavit: original filing- October 22,2004; reinstated on November 19,
2004. Date of service ofthe Plaintiff's Affidavit upon the Defendant
pursuant to Order of Court dated November 1, 2004: through publication
on November 18, 2004 and November 26, 2004.
4. Related claims pending: None.
..
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Date I
5. Date and manner of service of the Notice of Intention to Request Entry of
a ~3301(d) Divorce Decree, a copy of which is attached: February 22,
2005 by First Class United States mail to the Defendant's last known
address.
Respectfully Submitted,
/1
//!tJ4(zL . or. ~/Armcuv
~ressica L. Bowman
[/Certified Legal Intern
S
THOMAS . PLACE
LUCY JOHNSTON-WALSH
ANNE MACDONALD-FOX
Supervising Attorneys
The Family Law Clinic
45 North Pitt Street
Carlisle, P A 17013
(717)243-2968
Fax (717)243-3639
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IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
STATE OF
LJamie
F'()lkpnr:7()th
Plaintiff
VERSUS
Hl1"'lsp;n
't'rir;rk
Rprpmp
Defendant
AND NOW,
DECREED THAT
Jamie
rrriy";~k
Hnq"'lp;n
AND
PENNA.
No.
04-5323
DECREE IN
DIVORCE
/?'1.a...A
30'
, ?nnc;
, IT IS ORDERED AND
Folkenroth
, PLAINTIFF,
RArpmp
, DEFENDANT,
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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