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Home My WebLink About05-1450 LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : t;b : NO. 05- JI.! CIVIL TERM BARRY A. PRICE, Defendant 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, 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, Cum berland 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 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 Bedford Avenue 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. l '" LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ./ I'fJ U : NO. 05- CIVIL TERM BARRY A. PRICE, Defendant COMPLAINT UNDER 23 Pa.C.S.!I!I 3301(c) OF THE DIVORCE CODE The plaintiff, Leticia S. Price, by her attorneys, the Family Law Clinic, sets forth the following cause of action: 1. Plaintiff is Leticia S. Price, who currently resides at 142 South Hanover Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Barry A. Price, who currently resides at 102 West High Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on May 8, 1994 in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since May 2004. 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 or defendant may have the right to request that the court require the parties to participate in counseling. LETICIA S, PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A. PRICE, Defendant : NO, 05-1450 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 99 3301(c) and 3301(d) of the Divorce Code was filed on March 17, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 and intention to request entry of the decree. 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. J. lC .-/ Date lP -,:;>( ! - OS fEpw. .~~I ettCIa S. Pnce, Plamtlff (") f~ u I',' , -;5~ ~ -<. ...> = <= c.n <-- C'.:: ,.- 1 CO o -n :r.,., rnF: -om :~-,7C(1 ~\~1:i; ce-..j ~~~fn " :,;q --<.. :s -.... (~? C"""l LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A. PRICE, Defendant : NO, 05-1450 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l3301(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 in 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 1.0 cJ 9' - {) S (;~~ f?~~/, Leticia S. Price, Plaintiff o r_-~ <c "', = = en <- r- p I CO (:') -n ::;:! _1-_-,"1 f11-- ,-,F; -)'~)C (~l 1 ":::'-:lC) ~~~{ >~ -, "),;< ~ .< ::2 .,- <.;-? 0-. IT LETICIA S, PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A. PRICE, Defendant : NO. 05-1450 CIVIL TERM AFFIDAVIT OF CONSEN'{ J. A Complaint in Divorce under S9 3301(c) and 3301(d) of the Divorce Code was filed on March 17,2005, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 and intention to request entry of the decree, 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, 9 4904, relating to unsworn falsification to authorities, Date L. -""2-1 - oS -~~ Barry A. Price, endant "-> :gg "-" '- r'" f~ I CO "'1J -"", ..... ~ o .. :r!_ ff"l.-!.J -0171 ~I:]O r-... ! :=jC) ~~-~ f~{ c5/n --::;"1 b ::0 -<: - ....., lXI LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A, PRICE, Defendant : NO. 05-1450 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~330l(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 aft(~r 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 t:? _.-z '" - oS .. , ( "'~; =< .....> = = cJ' '-= c. ," I co o -n ~.." rnr -all:'; --nC-' S~~~I '}::..~ :J.~ ...... ..", ~\.. "-:? -' LETICIA S, PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A, PRICE, Defendant : NO. 05,1450 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~ 3301 (c) of the Divorce Code, 2. Date and manner of service of the complaint: March 17, 2005 by hand delivery at the Family Law Clinic, 45 North Pitt Street, Carlisle, PA 17013,. 3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce Code: by the plaintiff, June 29, 2005; by the defendant, June 29, 2005, 4. Related claims pending: none, 5. Date plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: July 5,2005. Date defendant's Waiver of Notice in 9 3301(c) Divorce was filed with the Prothonotary: July 5,2005. Date: "II gf (l') I ~ THO ROBERT . RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorneys LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A. PRICE, Defendant : NO. 05-1450 CIVIL TERM CERTIFICATE OF SERVICE I, Rene M. Gomall, hereby certify that on this 8th day of July, 2005, I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet on Barry A. Price by first class U.S, mail, addressed as follows: Mr. Barry Price 102 West High Street Apartment 309 Carlisle, PA 17013 Date:~ F AMIL Y LAW CLINIC 45 North IPitt Street Carlisle, P A 17013 717/243-2968 Q (" , ~}'~-; /\ ~~~\_- \;:\,-,. -~-::: i... ) -;;,.c: .~ ~ = "-" <- c: .- \ cP -<:) ~,.. ....~ ~ --' -;:r:,,,,, rn-p:: -o(C', -nY '~-) C.J :::i-\'1 1,..-';, If~:~ )'- ~ o - cP - ,; WHEREFORE, plaintiffrequests the court to enter a decree of divorce dissolving the marriage. Date~ , '" ..:h . ( j"Lt41 ?1;[.Q. . -- /UUii THOM~S . PLACE ROBERT E. RAINS Supervising Attorneys ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorneys 'l F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/240-5204 717/243-2968 VERIFICATION I verifY that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. 1 understand making any false statement would subject me tot he penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date 3 -ffo- os ~h~ Leticia Price, Plaintiff w .~ -v f"'- -~,\ ;", ";": -,,,) 'CI~' LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE BARRY A. PRICE, Defendant : NO. 05- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Leticia Price, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma 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~ . .'1 tb _" ,.- I! ,1\" i' " ~.'- ~ L L\/!-~t "2- t THOl\1'A~if;'1>LACE ROBERT E. RAINS Supervising Attorneys ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Staff Attorneys ,," I (/,] ti/d!A~ ( , FAMILY LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 r' ("I -"j' ,." __1 I) \"" (.",' LETICIA S. PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYL V NIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A. PRICE, Defendant : NO. 05-1450 CIVIL TERM CERTIFICATE OF SERVICE I, Rene M. Gornall, hereby certify that on this date I served a true and corr ct copy of the Complaint for Divorce and the Praecipe to Proceed in Forma Pauperis lIed March 17,2005, by hand delivering same to the Defendant at the Family Law Cli 'c,45 North Pitt Street, Carlisle, P A 17013. Date: ~l~o~ #Gtu4/ Certified Legal Interp Family Law Clinic 45 North Pitt Street Carlisle, P A 17013 ~/ C) ~~ , ._rl ,/,.... j'-~: ll. ";: f<" o . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . . LETICIA PRICE, . . PLAINTIFF . VERSUS . . BARRY PRICE, DEFENDANT . . . . . . . . AND NOW, PENNA, No, 05-1450 DECREE IN DIVORCE <juJ., 1:1' , ~ , IT IS ORDERED AND . DECREED THAT LETICIA PRICE PLAINTIFF, . . . AND BARRY PRICE DEFEN DANT, . 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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~'4J . . . . J. . . . . . . . .. .. . .~ ~~ ~IL. 50/lL -?~!7- ~~ ~ 5t/-Y/-L . , ~ "'.;.~' ..",. \.l";'~';'" LETICIA S, PRICE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE BARRY A, PRICE, Defendant : NO, 05-1450 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted divorced from the bonds of matrimony on the 13'" day of July, 2005, hereby elects to retake and hereafter use her previous name of Leticia S. Starner, and gives this written notice avowing her intention to do so pursuant to the provisions of 54 Pa. C,S. ~704, f)^ ~ ~~() ~ice - Wishes To Be Known As: fJ IL:. '- ~.9~ ~;amer COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS, On the 19" day of July, 2005, before me, a Notary Public, personally appeared Leticia S. Price, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. l/(' /, ( /, 'au',~~-)tiC?) NOTA,Y LIC' C ~.. [ Notalial Seal ~'..i Laurie L. won. Notary Public South Middleton Twp., Cumberland County My Commission Expires Jan. 7, 2006 Member. Pennsylvania AGsociation Of ~Jotd(i8S ~C\ ~ t <>\ =t' --.1 ~ D ~ ~ ~~ \~ J ~ f r-' 0 c=' ....n 9 ~ .-4 ... r -:,', ". '-- ....,-" ~ ,. r 1'-' - - .' U'\ a;