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Home My WebLink About06-6584ROBERT A. BARRICK, JR., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW 10? (C54 4 CHERYL A. BARRICK, : NO. - CIVIL TERM Defendant : IN DIVORCE NOTICE 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 Court House, High and Hanover Streets, Carlisle. 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 Bar Association 2 Liberty Avenue Carlisle, PA '17013 Phone: (717) 249-3166 ROBERT A. BARRICK, JR., Plaintiff V. CHERYL A. BARRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 0a-G!rry NO. - CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Robert A. Barrick, Jr., who currently resides at 2 Terri Drive, Cumberland County, Carlisle, Pennsylvania, since March 1, 2006. 2. Defendant is Cheryl A. Barrick, who currently resides at 2 Terri Drive, Cumberland County, Pennsylvania, since March 1, 2006. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 15, 1979, in Detroit, MI. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: i 1- ?- Respectfully Submitted, ROMINGER & WHARE Michael J. Whare, Esc fuire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court ID # 89028 (717) 241-6070 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. § 4904, relating to unsworn falsification to authorities. Date: ?? - 13 -Oro Robert A. Barrick, Jr., Pla ntiff W ?cl C \I L-3 -TI ROBERT A. BARRICK., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 06-6584 - CIVIL TERM CHERYL A. BARRICK, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 4. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 14, 2006. 5. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 6. 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. § 4904, relating to unworn falsification to authorities. d Date: P-1617 T' • Robert A. Barrick/PlaidtO Fri d ROBERT A. BARRICK., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 06-6584 - CIVIL TERM CHERYL A. BARRICK, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 2. 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. § 4904, relating to unworn falsification to authorities. Date: -n71 t &44-4 R Robert A. Barrick/Pl iff ti t- "`ti y ROBERT A. BARRICK., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 06-6584 - CIVIL TERM CHERYL A. BARRICK, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 14, 2006. 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. § 4904, relating to unworn falsification to authorities. Date: A9-17-e,7 Ch A. Barrick/Defendant C C3 C= -r t ?''_ 2V x3 L c- n ROBERT A. BARRICK., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 06-6584 - CIVIL TERM CHERYL A. BARRICK, : IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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. § 4904, relating to unworn falsification to authorities. Date: 10-17-0 7 CA. Barrick/Defendant r-3 i i ?.. ? c n - ROBERT A. BARRICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law CHERYL A. BARRICK, Defendant No. 06-6584 IN DIVORCE PROOF OF SERVICE ¦ Complete llama 1, 2, and 3. Also complete Rem 4 If Pm icled Delivery is desired. E,:.Ortit your name end 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. AAicle Addressed to: 1-7013 13 Agent by N&-nq) 0. r of D. Is delivery address different from Item 1? El Yes M YES, enter delivery address below: 0No 3. l3qlos IW* ;v Illed man 13 Mail t3 Registered alum ipt f or Merchandise Insured Mail ? C.O.D. 4. PAdrlclsd D~ f5ft Fay 2. Mole Number (rmnsrerfrom ser 7004 1350 0003 7142 7349 PS Form 3811, F6bruary 2004 Domestic Return Rsoeipt 10259s-o2-W" CC) C,? ROBERT A. BARRICK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law CHERYL A. BARRICK, Defendant No. 06-6584 IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Filed November 14, 2006, was served on the Defendant by certified mail, endorsed restricted delivery-return receipt requested and signed on November 17, 2006 (attached hereto as proof of service). 3. Date of execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code: by the Plaintiff on October 21, 2007; by the Defendant on October 17, 2007. 4. Related claims pending: None. 5. (b) Date Plaintiffs Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: October 22, 2007. Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: October 22, 2007. Respectfully submitted, Date: 7 t-1?A ich el I Whare, E uire 37 East Pomfret Street Carlisle, Pa 17013 (717) 243-3561 Supreme Court ID # 89028 Attorney for Plaintiff 77 Co r - y' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ain VERSUS Dego-„ Lni No. (05M a001? DECREE IN DIVORCE AND NOW, N04t"N% eft- 1 ` , Zoo , IT IS ORDERED AND DECREED THAT RO ,.+ a QA(`PI , PLAINTIFF, AND cher4l A. Bate JLk 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; l ONr BY THE COURT: PROTHONOTARY ,, 0 ,s (Q, bear co. dd -it