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HomeMy WebLinkAbout06-2184Mr. William Harr, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE Mrs. Barbara E. Harr, Defendant : NO. 06- 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 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, 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 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 MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 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. Mr. William Harr, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Mrs. Barbara E. Harr, Defendant : NO. 06- CIVIL TERM DIVORCE COMPLAINT The plaintiff, Mr. William Harr, by his/her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Mr. William Harr, who currently resides at 45 Spring Road, Apt. 4, Carlisle, PA 17013, Cumberland County, PA 17013, since October 2003. 2. Defendant is Mrs. Barbara E. Harr, who currently resides at 343 East Story Road, Winter Garden, Orange County, FL 34787-3661, since 2000. 3. Plaintiff has 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 on August 31, 1988, at Stafford, Stafford County, Virginia. 5. Plaintiff and Defendant have lived separate and apart since September 1998. 6. There have been no prior actions for divorce or for annulment between the parties. 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 the court to enter a decree of divorce. Kathleen McKeown' Certified Legal Intern ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCYJOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of IS Pa.C.S. §4904, relating to unsworn falsification to authorities. Date Plaintiff -y Mr. William Harr Mr. William Harr, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN CUSTODY Ms. Barbara Harr Defendant :NO, 06- of I ?`? CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Mr. William Harr, 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. Respectfully submitted, // iCJ?'sr? JY.__ Date Kathleen McKeown Certified Legal Intern ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ", ,; i ? Mr. William Harr, Plaintiff V. Ms. Barbara Harr, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 2006- `a Ii-y CIVIL, TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in September 1998, and have continued to live separate and apart for a period of at least 2 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. §4904, relating to unsworn falsification to authorities. Date 0 (a LJ Q Q e e-, lgelt- Mr. William Harr Plaintiff Mr. William Harr, Plaintiff/Movant V. Ms. Barbara Harr Defendant/Re spondent IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO. 06- 2184 CIVIL TERM MOTION PURSUANT TO Pa.R.C.P. RULE 430 FOR SPECIAL ORDER OF COURT DIRECTING METHOD OF SERVICE OF PROCESS Plaintiff/Movant, William Harr, by his attorneys, the Family Law Clinic, requests this Honorable Court to direct method of service by publication, once in the Cumberland County Law Journal, upon consideration of the following: 1. Movant, William Harr, is the Plaintiff in the above captioned matter. He currently resides at 45 Spring Road, Apartment 4, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Respondent, Barbara Harr, is the Defendant in the above captioned matter whose last known residence was 343 East Story Road, Winter Garden, Florida 34787. 3. Movant and Respondent were married on August 31, 1988 at Stafford, Virginia, both were at that time domiciled in the Commonwealth of Pennsylvania. 4. Movant and Respondent have lived separate and apart since 1999. 5. Movant filed this suit in the Court of Common Pleas of Cumberland County on April 19, 2006 (Movant's Exhibit A). 6. Movant's present suit in divorce requests only a decree in divorce, there are no economic claims. 7. Movant, at the time suit was filed, had no knowledge of where Respondent was located. 8. Movant provided to the Family Law Clinic Respondent's married name, maiden name and the name of who Movant believed may have been a relative. 9. Movant has not seen Respondent since mid 2006 when he saw her, by chance, boarding a bus in downtown Carlisle, Pennsylvania. Movant and Respondent made eye contact, Respondent replied to Movant "hey Bill", then departed on the bus to whereabouts unknown. 10. Movant has no contact with any of Respondents family. 11. A search of Respondent's family members using the Accurint search program yielded no usable results. 12. Movant has no contact with or knowledge of any of Respondents friends or acquaintances. 13. Since that time Movant's counsel has repeatedly engaged in a good faith effort to locate the Respondent, and give notice, including: a. On March 27, 2006 Movant's counsel employed an internet search program called Accurint (www.accurint.com); an overview of the service, provided by the manufacturer, is attached hereto as Movant's Exhibit B to locate the Respondent. A records search under Movant's married name, "Barbara Harr" returned an address in Winter Gardens, Florida. Notice was attempted by certified mail, restricted delivery, return receipt requested. The letter was returned by the United States Post Office as "Returned to Sender / Unclaimed / Unable to Forward". b. On December 4, 2006, Movant's counsel again employed Accurint to attempt to locate the Respondent using other search parameters. A records search under Movant's maiden name, "Barbara Spong" returned no records matching that first name. Movant remembered a possible relative or acquaintance that he thought was named Katherine Harrison. However Movant was uncertain as to the spelling of "Katherine". An Accurint search under several variations of Katherine yielded too many results. c. A records search of Respondents maiden name, "Spong" on the telephone search engines, www.bigyellow.com and www.anywho.com returned no results. d. On January 1, 2007 a records search of the United States Government's Social Security "master death" file was conducted, using Respondents Social Security Number, through the search program, www.ssnvalidator.com. The search confirmed no death was recorded in the Social Security Number files. e. On January 26, 2007 Movant's attorneys contacted Florida Department of Motor Vehicles requesting a search of their records for Defendant under her married name, maiden name, alternate names and Social Security Number. The results were negative. £ On March 29, 2007, Movant's attorneys obtained a subpoena (Movant's Exhibit C), pursuant to the requirements of Pennsylvania Department of Transportation, per DL-503, requesting a search of their records for Defendant under her married name, maiden name, alternate names and Social Security Number. The results were negative (Movant's Exhibit D). g. Another search using Respondents Social Security Number was made using Accurint on June 13, 2007. Two results were returned (Movant's Exhibit E), one to the already established Winter Gardens address that the Post Office indicated was "unclaimed / return to send / unable to forward" and another in Lookout Mountain, Georgia. A phone number was associated with each address. The individual who answered the phone in Georgia denied ever knowing the Respondent. The phone number associated to the address in Florida was not answered. Attempts to get an answer failed after several days of attempts. 14. No Judge assigned to this case. 15. No concurrence of counsel, pursuant to C.C.R.P. 208.3(a)(9), was obtained as no counsel of record has been entered and original service has been attempted and has failed. WHEREFORE, Movant requests that this Honorable Court enter an order directing method of service of the Complaint for Divorce under §3301(c) and (d) as follows: by publishing the Notice attached hereto as Movant's Exhibit F, once in the Cumberland County Law Journal. DATE: e _ Certified Legal Intern THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC Counsel for Plaintiff 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the Motion Pursuant to Rule 430 for Special Orders of Court Directing Method of Service of Process are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date Mr. William Harr Movant °i' i L ;v EXHIBIT Mr. William Harr, Plaintiff V. Mrs. Barbara E. Harr, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 06-11 gL.l CIVIL TERM DIVORCE COMPLAINT The plaintiff, Mr. William Harr, by his/her attorneys, the Family Law Cli the following cause of action in divorce: 1. 2. 3. 4. 5. 6. 7. 8. rte-- ? i"1 c.' -+ fob DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Mr. William Harr, who currently resides at 45 Spring Road, Apt. 4, Carlisle, PA 17013, Cumberland County, PA 17013, since October 2003. Defendant is Mrs. Barbara E. Harr, who currently resides at 343 East Story Road, Winter Garden, Orange County, FL 34787-3661, since 2000. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on on August 31, 1988, at Stafford, Stafford County, Virginia. Plaintiff and Defendant have lived separate and apart since September 1998. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 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 the court to enter a decree of divorce. Kathleen McKeown t = --- Certified Legal Intern ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH WILLIAM G. MARTIN Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 j ?6?-.. / a VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. J ? Date Plaintiff Mr. William Harr About Us: Overview Accurint ` A=Uririt 0 v rr '?` ` mc?mtwrahrps Website Links Accun'd OveMew EXHIBIT I V tdKII What We Do Accurint® is a LexisNexis® service that brings data to life. Accurint provi+ products that allow organizations to quickly and easily extract valuable k huge amounts of data. These innovative products are made possible by i powerful technology, tens of billions of data records on individuals and b proprietary data-linking methods. LexisNexis Backed by more than 30 years of expertise in data management, LexisN, innovator in validating and verifying identity. LexisNexis products and se intelligent hiring decisions, uncover fraudulent transactions, prevent ider missing children, track down terrorists, and prosecute white collar crimin For Additional Information: For sales assistance use our online form or call: 888.332.8244. j L >home I > rivac i >contact us The information provided by Accurint is not a consumer report (as the term is defined in the Fair Credit Reporting Act (FCRA)) and may not be used for any purpose permitted by the FCRA. u 2007 Accurint. All rights reserved. htti)://www.accurint.com/aboutus.htnl 6/13/2007 Mr. William Plaintiff V Mrs. Barbara Defendant TO: PennDot Harr COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND File No. Harr EXHIBIT 06-2184 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS F' L E FOR DISCOVERY PURSUANTTO RULE 4009.22 (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: Information requested in enclosed form DL-503 Basic infog=_i on on Barbara Eliane Harr Dossible SSN 184-34-8965. DOB 06/11/1943 all other information is unkown, last name may be 'Ault' or 'Spong' at-BY US Mail to Warren Eth Family Law Clinic 4 N Pitt- st Carlisle , PA 17 013 (Address) You'may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above.You have the right to seek in advance the reasonable cost of preparing they copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. --THIS SUBPOENA WAS 'ISSUED AT THE REQUEST OF THE FOLLOWING PERSON: Name l e e.C' Address: 45 N. Pitt St. Carlisle, A 1701'1 el I I r<7 Telephone: (-4171? +19io Supreme Court ID # Attorney For: Mr. William Harr BY THE COURT: Prothonotary/Cler , evil Division Date: --r--.1 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF DRIVER LICENSING HARRISBURG, PA 17123 04/17/07 FAMILY LAW CLINIC 45 NORTH PITT STR CARLISLE PA 17013 Dear Customer: EXHIBIT I)-- 071076273495149 001 06/11/43 BARBARA E HARR The Bureau of Driver Licensing has received your re- quest for information. We are not able to provide this information because the record you requested does not exist in our files. We regret that your payment must be retained to cover the cost of the search. If you have any questions concerning this transaction, please contact the Information Sales Unit at the address or telephone number listed below. Sincerely, ADDRESS CORRESPONDENCE TO: Department of Transportation Information Sales Unit P 0 Box 68691 Harrisburg, PA 17106-8691 Customer Service Team Bureau of Driver Licensing INFORMATION (8:00 AM to 6:00 PM) IN STATE 1-800-932-4600 OUT-OF-STATE 717-412-5300 TDD IN STATE 1-800-228-0676 TDD OUT-OF-STATE 717-412-5380 Advanced People Search Page 1 of 2 24/7 Search and Technical Assistance 1.800.543.6862 Main Menu I My Account I Print I Contact Us I Log Out ti? f,? ?ia?e arae Phones Plus Basic Lookup Reverse Lookup 184-34-8965 EXHIBIT E ?. - l NZT1" 1 `tr% .t A ,curs U: Y -p ,' ll t? .T 1 i?;. t'-t t tYn City ,. '?+r ',ipIC.r Ra a t ... t..ii, ? •'e r.c.'i?L .. . 'e.i v--Y I,i"_.i i` cl nle CI put ';tpe: • For hatted H7ivii_ Cut Find Pas--!e /Printer Friendly Text ;N- e eports) Duq 1!u?' dui nr .G"'GIBS : n?a :?Ol?lftlP.IGIL1liv avaiiable data SOUrces used in this syslem hc.4? trrorS l? l't?1 I? SOfrl??jtn?<•S =( ?, ";r-•,- prr-'r, N iii nr ; _t I5 _???lj; ii t f)8C irUE?i CiBT (-;l. ills s)?slenn shoul(l slot b relied upon as de`Initiveiv ..m ::iata f,i,.: ,}istern F upplies, it should be independently verified. For Secretary of State documents, the ?i ;rrnaCnn purposes only and is not an official records Certified copies may be obtained from that individual L iT-jt,nl cr X 1a SEARCH: SSN: 184348965 CIi SL Mr Pr Pr Nz Ins PE .' cf 2 Ec Full Name SSN DOB Address / Dates i Phone Information BARBARA SASSER 184-34-xxxx 343 E STORY RD (407) 656-0879 - Active BARBARA E HARR WINTER NEW MACEDONIA BARBARA HARR GARDEN FL 34787-3661 CHURCH & MINISTRIES Jul 00 - Jan 07 INC 4800 S CLEVELAND AVE APT FORT MYERS FL 33907- 1320 Dec 90 - Jan 95 12 S HANOVER ST # 512 CARLISLE PA 17013- 3306 3520 DAIRY FAYETTEVILLE NC 28304 1',?`t.,c•I/cPrnrr> arrnrint ?nmlann/hnc/mice Advanced People Search Page 2 of 2 JOHN TESSMANN 184-34-xxxx 1202 CINDERELLA RD (706) 820-0043 - Active LOOKOUT TESSMANN JOHN D MOUNTAIN GA 30750- 2505 Jul 02 - Mar 04 SEARCH: SSN; 184348965 & dl t , 4-A'4- 17-q? Ec https:Hsecure.accurint.com/app/bps/misc 6/13/2007 ----------------------- LEGAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Term ---------------------- No. 06-2184 -------------------- WILLIAM HARR V. BARBARA HARR ------------------- IN DIVORCE TO: BARBRA HARR YOU HAVE BEEN SUED IN COURT. The Plaintiff, William Harr, by his attorneys, the Family Law Clinic, has filed a Complaint for Divorce under §3301(c) and (d) of the 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 loose property or other rights important 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 MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717)249-3166 EXHIBIT I - )L- Commonwealth of Pennsylvania County of Cumberland AFFIDAVIT 1. I, Warren Eth, am currently employed by Movant's counsel, the Family Law Clinic, located at 45 North Pitt St., Carlisle, Cumberland County, Pennsylvania, 17013. 2. I have been engaging in an ongoing effort to locate the Defendant Mrs. Barbara Harr. 3. Prior to my efforts, other Certified Legal Interns had attempted to locate the Defendant without success. 4. I have exhausted all reasonable means to attempt to locate the Defendant and have maintained a record of all attempts, my effort included: a. Searches on specialized data archive sites maintained by Lexis-Nexis (Accurint) for Respondent and possible relatives. b. Mailing by Certified Mail, restricted delivery, return receipt requested a notice to the Defendant's last known address-the mailing was returned undeliverable. c. Searches on multiple internet person locator websites. d. Searches through Florida Department of Motor Vehicles. e. Obtained a subpoena ordering Pennsylvania Department of Transportation to search their driver's license records for the Defendant, including searching through her Social Security Number. f. Questioned Plaintiff about any and all possible relatives, friends or associates who may know the Defendants whereabouts. g. Contacted two phone numbers provided by Accurint associated with Defendant's Social Security Number. 1. The first number, associated with her Social Security Number reached a home owned by Mr. John Tessman in Lookout Mountain, Georgia who denied ever knowing the Defendant. II. The second number, associated with the address that the certified mail was returned from undeliverable, yielded no answer after numerous telephone calls over a period of days. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are subject to the penalties as prescribed by 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. / f DATE? Legal Intern ?Y ? c? v -a G b ? ? L p ?S ?_ 4 'tl Q?? ? ? ? ?? n ? O .p ,t,, Mr. William Harr, Plaintiff/Movant IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Ms. Barbara Harr Defendant/Respondent NO. 06- 2184 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FOR DIVORCE To the Prothonotary: Kindly reinstate the above captioned matter filed April 19, 2006. DATE: alll?110 /? W giieMLgal Intern THOM S M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC Counsel for Plaintiff 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ?- `= Q - ° ? r,-, C ' ? -?' CJ7 I ' rn CD G 3 Mr. William Harr, : IN THE COURT OF COMMON PLEAS OF Plaintiff/Movant :CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Ms. Barbara Harr Defendant/Respondent NO. 06- 2184 CIVIL TERM ORDER OF COURT AND NOW, this day of, 2007, upon consideration of the attached Motion pursuant to Pa.R.C.P. Rule 430 for Special Order of Court Directing Method of Service of Process and Affidavit, it is ordered that: 1. Service of the Complaint and Plaintiffs Affidavit under Section 3301(c) and (d) be made by publication of the attached notice, once in the Cumberland Law Journal; 2. Notice of Intent to Request Entry of Divorce Decree is waived; 3. Publication of notice in the Carlisle Sentinel is waived. /f a7 Date Judge :01 t 61 ! Eau Mr. William Harr, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Ms. Barbara Harr, Defendant :NO. 06-2184 CIVIL TERM AFFIDAVIT OF SERVICE I, Warren Eth, Certified Legal Intern, of the Family Law Clinic, hereby certify that, pursuant to an Order of Court dated June 19, 2007, permitting notice by publication once in the Cumberland County Law Journal, and waiving notice by publication in the Carlisle Sentinel, Defendant Ms. Barbara Harr was served with Notice of the Complaint for Divorce filed against her on April 19, 2006, Complaint Reinstated on June 16, 2007, through publication of such notice in the Cumberland County Law Journal on July 13, 2007 (Attached Proof of Publication marked as `Exhibit A'). I verify that the above made statements made in this affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. DATE:pI I ? 01 ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 LUC JOHNSTON-WALE EXHIBIT A PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. Lisa Marie Coyne, Esquire, Editor of the 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 official legal 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 July 13, 2007 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. Editor AND SUBSCRIBED before me this 13 day of July, 2007 Notary NOURIA SM DESORAN A COLLINS Notary PubSc CARLISLE 8080, CUMKRLAW COHNiy My CorrW**M DOW AP 24, 2010 CUMBERLAND LAW JOURNAL LEGAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Term No. 06-2184 WILLIAM HARR V. BARBARA HARR IN DIVORCE TO: BARBRA HARR YOU HAVE BEEN SUED IN COURT. The Plaintiff, William Harr, by his attorneys, the Family Law Clinic, has filed a Complaint for Di- vorce under §3301(c) and (d) of the 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 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 OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA- TION 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 SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 July 13 ?? ? ? t:? ? `ri - ""7 C'i _ _ _ _ ?. ?? x. - c' ;+ ?? ?: ?1 .? ? Mr. William Harr, Plaintiff V. Ms. Barbara Harr, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE AND CUSTODY No. 06-2184 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant pursuant to an Order of Court dated June 19, 2007, through publication of notice in the Cumberland County Law Journal on July 13, 2007. 3. Date of execution of the Affidavit required by §3301(d) of the divorce code: by Plaintiff. April 19, 2006. Date of filing of the Affidavit: original filing- April 19, 2006. Date of Service of Plaintiff s Affidavit upon the Defendant: not effectuated as no known address for Defendant exists and Service of Complaint permitted by publication pursuant to an Order of the Court on June 19, 2007. 4. Related claims pending: none 5. Date and manner of service of the Notice of Intention to Request Entry of a §3301(d) Divorce Decree: Waived by Order of Court dated June 19, 2007. Ff I A ??( gislo Date wane `` Ce i ied Legal Intern LUCY J TON-WALSH ROBERT E RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013-2899 (717) 243-2968 Fax: (717) 243-3639 C a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS NO. 2184 2006 Barbara Har Defendant DECREE IN DIVORCE czr.?. AND NOW, IT IS ORDERED AND DECREED THAT William Harr PLAINTIFF, AND Barbara Harr 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; Done ATTEST: J. ?I PROTHONOTARY ?I 40) --,PV e- 0 - -51 - ?