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Home My WebLink About05-6055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Craig W. Barnhart, Plaintiff Civil Action - Law v, No 2005- /:'055, CvL "-TEiL"Y\. Sarah R Barnhart, Defendant In Divorce a.v.m. 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 at the Cumberland County Courthouse, first floor, 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, Pennsylvania Bar Association, Lawyer Referral Service 100 S Street, PO Box 186, Harrisburg, PA 17108 1-800-692-7375 (pA only); (717) 238-6715 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. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Craig W. Barnhart, Plaintiff Civil Action - Law v. No: 2005- loo!;.S CivL~[JL~ Sarah R. Barnhart, Defendant In Divorce a. v.m. COMPLAINT UNDER SECTION 3301 (c) or 3301(d) OF THE DIVORCE CODE 1. The Plaintiff is Craig W. Barnhart, who currently resides at 97 Broad Street, Newville, Cumberland County, Pennsylvania since, 2003. 2. The Defendant is Sarah R. Barnhart, who currently resides at 120 East Louther Street, Apt., F, Carlisle, Cumberland County, Pennsylvania since September, 2005. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were manied on March 19, 2003 at Newville, Cumberland County, 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 that marital counseling may be requested and that a list of marriage counselors is available in the office of the Cumberland County Prothonotary. Plaintiff has further been advised of the right to request that the Court require the parties to participate in marital counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, O~i1P-P it i1~ Carol . Redding, #82041 Attorney for Plaintiff Craig W. Barnhart REDDING LAW OFFICE 19 North Main Street Chambersburg, P A 17201 (717) 267-1440 VERIFICATION I verifY that the statements in this Petition 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: //-/~ -oj ( '1 / A ~J---- '~ {..U; 1A::t~ Craig W. Barnhart ~ .Jg. ,-."' 8 ~ --- T-\\- ~ ...--," ....1 - - \) . <~ i "-~- UJ. \'<:; C'< - C> ...:t. -c '--'-.' -.J - 1'-' . - -' l.rJ r r \'.' - ~ :2 ( ". --I-- ( ---- . Hl05.157 REV. 5.117 COMMONWEALTH Of PENNS'l1..VANIA DEPARTNENTOF HEALT1-I VITAL ReCORDS 51 A TE FILE NUMBER Cumberland DIVORCE [i] RECORD OF OR ANNULMENT (CHECK ONE) 0 STATE FILE DATE COUNTY HUSBAND 3. RESIDENCE City, Bora. or Twp. County (Last) 2. DATE (Man/h) (Day) (Year) Barnhart OF 2 27 79 BIRTH S/e/e 4. PlACE (S/818 or FonJ/gn Country) PA OF Maryland BIRTH 7. USUALOCCUPATlON 1. NAME (Flrsl) Craig Strf/6IorR.D. (Middle) W. 1 Cumberland 97 Broad Street 5. NUMBER OF THIS MARRIAGE Mechanic WIFE ., ""AlDEN NAME (First) (Middfe) (Lssl) 9. DATE (Month) (Day) (Year) Maul Sarah R. Barnhart OF 4 25 82 BIRTH 10. RESIDENCE Srre6IorR.D. City, BOt'O. or Twp. County Slats 11. PLACE (State or FOr9ign Counlry) Louther Apt. F Carlisle Cumberland PA OF Pennsylvania 120 E. St. , BIRTH 12. NUMBER 1'3. RACE 114. USUAL OCCUPATION OF THIS WHriE enK O~R IS"""'~I 1 k , MARRIAGE 1 Store C er I 15, PLACE OF (County) (StaM or Foreign Country) 16. DATE OF (Mon/h) (Day) (Yesr) THIS Cumberland Pennsylvania THIS 3 19 03 MARRIAGE MARRIAGE 17A. NUMBER OF 17B. NUMBER OF DEPENDENT I.. PLAINTIFF 19. DECREE GRANTED TO , CHILDREN THIS CHILDREN UNDER 18. HUSBAND WIFE OTHER (Specify) HUSBAND WIFE OTHER (Specify) MARRIAGE 0 0 10 0 0 [}S) 0 0 20. NUMBER OF HUSBAND WIFE SPUT CUSTODY OTHER (Specify) 121 LEGAL GROUNDS FOR . CHILDREN TO 0 0 0 0 DIVORCE OR ANNULMENT CUSTODY OF Irretrievably Broken 22. DATE OF DECREE (Mon/h) (Day) (Yel1r) r3. DATE REPORT SENT (Month) (Dsy) (Yesr) TO VITAL RECORDS 24. SIGNATURE OF TRANSCRIBING CLERK . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Craig W. Barnhart, : Civil Action - Law Plaintiff v. : No: 2005-6055 Sarah R. Barnhart, Defendant : In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) or 3301 (d) of the Divorce code was filed on November 28, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of 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. Section 4904 relating to unsworn falsification to authorities. ~~;1{ ~~~L_74--/ Sarah R. Barnhart Date: 0""2,. 0 S- - 0 (, c IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYL VANIA Craig W Barnhart, : Civil Action - Law Plaintiff v, : No: 2005-6055 Sarah R. Barnhart, Defendant : In Divorce a.v.ill. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &330HC) 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 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. 94904 relating to unsworn falsification to authorities. Date: G 3 - '" "7 - D b );~J~k Sarah R. Barnhart ------- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLV ANlA Craig W. Barnhart, : Civil Action - Law Plaintiff v. : No: 2005-6055 Sarah R. Barnhart, Defendant : In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) or 3301 (d) of the Divorce code was filed on November 28,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verif'y that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of ]8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date I1lar. 10. tJ & I L~Ah~V~ Craig W. B art ------ - IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLV ANlA Craig W. Barnhart, Civil Action - Law Plaintiff v, : No: 2005-6055 Sarah R. Barnhart, Defendant : In Divorce a. V.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DNORCE DECREE UNDER &330I(C) OF THE DNORCE 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 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. 94904 relating to unsworn falsification to authorities. Date!fl{)f',IO,O& / , (LJ.~' 'g~ ----------- - . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Craig W. Barnhart, Plaintiff Civil Action - Law vs. F.R 2005-6055 Sarah R Barnhart, Defendant In Divorce a. v, ill. AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA. R.c.P. 403 COMMON WEALTH OF PENNSYL VANIA COUNTY OF FRANKLIN SS Carol A Redding, Esquire, being duly sworn according to law, deposes and says that she is the attorney for Craig W. Barnhart, and she did mail a true and correct copy of the Complaint in Divorce Under Section 3301 (c) or (d) filed in the above matter by certified, restricted delivery, to the addressee of Sarah R Barnhart, on December 3, 2005, at 120 E. Louther Street, Apt. F, Carlisle, P A 17013. The signed acceptance of service is attached hereto as "Exhibit A" Co J<() 0 D ~dt"L~ Carol A Redding Sworn to and subscribed before me this vi J day of fY"lJ. (p h , 2006, 1 ~. / ,. {{ !/ ,J\0n!r,.lCliC} N tary Public NOTARIAL SEAL Renee L. Wildoson, NOlaIy Public Chambersburg 8..0., Franklin Coumy My commission expires Detfmber 22, 2009 " -. ~ . ~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Deiivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Arti Ie Addressed to: Sar.:; 1 R. Barnhart 121J E. LOuther St., Apt. F. Cnrlisle, PA 17013 Ay Sig~a.tur~ /J X '3~"'1~~ G DAgent o Addressee B. Received by ( P:inted Name) C, Dat~ Delive", S'JI'f-.4-tt P-V-t'l+ k~A-t<~.. ttftl'2.+ I,;). - ",j" D. Is delivery address different from item 1? 0 $- If YES, enter delivery address below: 0 N 3. Service Type ID Certified Mail o Registered o Insured Mail o Express Mall o Return Receipt for Merchandise o C.O.D. 2. Article Number (T rans'sr from service labelj PS Form 3811 , February 2004 4. Restricted Delivery? (Extra Fee) m Yes 7005 1160 0002 0660 0549 Domestic Return Receipt 102595-02-M-1540 IT" ;r '" CJ U.S. Postal Service,. CERTIFIED MAIL. RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) CJ . , Barnhart v. Barnhart CJ Postage $ .60 I1.J CJ CJ Return Receipt Fee o (Endorsement Required) Certified Fee 2.30 1. 75 3.50 $ 8.15 o RestricledDeliveryFee ..D (Endorsement Required) r'l r'l Tolal Postage & Fees '" o SentTo CJ ..s.<lJ::i!D.nRAnl\arnhar.L. C"- Street. Apt. No.; o~~O_~~~-~~J_~.Q___~_~_u~Q.t!J_h~!__.~J;_!_~___AP_~_._._.f______u__.___ City, -Sfate, ZIP+4 Ca lisle PA 17013 PS Form 3800, June 2002 See Reverse for Instructions EXHIBIT "A" { \ / ) -- THE COURT OF CONUtlON PLEAS CUMBERLAND COUNTY PENNSYL VANIA Craig W. Barnhart, Plaintiff Civil Action - Law vs. F.R 2005-6055 Sarah R. Barnhart, Defendant In Divorce a. v. ill. PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following infonnation, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable Breakdown under Section 3301 (c) or (d) of the Divorce Code. 2. Date and manner of service of the complaint: December 3, 2005 by first class mail, certified, restricted delivery to the Defendant, Sarah R Barnhart. 3, Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff, March 10, 2006; by Defendant, March 5, 2006. 4. Related claims pending: None. 5, (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintift's Waiver of Notice in Section 3301 (c) Divorce was filed with the prothonotary: March 14,2006. Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the prothonotary: March 9, 2006. {I (}.J? tLJ (] PC' d d ,-f -Ct:f Carol A. Redding, Esquire :.::;l -,,. '-~-' c.; .",.-,""""'" ii"""'''' '" . . + + + + + . + + + + + + + + + + + + + + , + + . + + + . + + + + + + + + + + + + + + , , + + + , + , + , + + , + , + + + , + + + + , + + + + . + + + + , + + + . + + + + + + . + + + + + + + + , , + + + + Oi',+ '+ '+ '" :+: + :+: :+: :+: :+: ,., + :+:+;f.+ +.. "':f.;f.:+:;f.:+: :+::+::+:+ :+:++"'+ :+::+:+c+. c+.:f.:+:c+.c+.c+.:+:c+. :+: c+.:+::+::+: :+:+:+::+:;f.:+::+::+:+++:+:,++,+:+:+:+:;f.+,+~ + + + + + , , + + + + , , + + + + + + + , , , + + + , + + + + + + + + + , + + + + + + + + + + + + , IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY Craig W. Barnhart PEN NA. STATE OF No. 2005 - 6055 Plaintiff VERSUS Sarah R. Barnhart Defendant DECREE IN DIVORCE ~~r'\\ ..... 1CO(", IT IS ORDERED AND AND NOW, Craig W. Barnhart DECREED THAT . PLAINTIFF. AND Sarah R. Barnhart . DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. + . . + + + + + + + + . + + + + + . + . + . + + + + . , , + + , + + + + + + + + , + + + + '+ :+: + :+: '+ :+: :+: + + + + :+: c+. ++ 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; By THE COURT: ~~~ A ~~. PROTHONOTARY + .. :+::+:'f:+::+:'+:+:+:+::f+ +:f++ +'+:t.+++'f++'+ ++1'+++++'++:+:+++++ + + + + + + J. ~, Z I~I' xr;P',;,t; '~.? I /; $v 7' /tF~ 4"'~.J )'7/ "/!I L-I;