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HomeMy WebLinkAbout02-3185MARILYN K. BARLUP Plaintiff vs. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 CIVIL TERM LAW - DIVORCE 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, Carlisle, Pennsylvania 17013, Telephone: (717)-240- 6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRA/~TED, 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, Pennsylvania 17013 Telephone (717)-249-3166 MARILYN K. BARLUP : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. :oo -- J. MICHAEL BARLUP : LAW - DIVORCE Defendant : CIVIL TERM COMPLAINT The plaintiff by her attorney, MURREL R. WALTERS, III, ESQUIRE, brings this action in divorce for a Decree of Divorce from the bonds of matrimony and respectfully represents: 1o The plaintiff is MARILYN K. BARLUP, an adult individual, who currently resides at 67 Hellam Drive, Mechanicsburg, Cumberland County, Pennsylvania since 1976. 2. The defendant is J. MICHAEL BARLUP, an adult individual, who currently resides at 67 Hellam Drive, Mechanicsburg, Cumberland County, Pennsylvania since 1976. 3. Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has been for at least six (6) months immediately previous to the filing of this Complaint. The plaintiff and defendant were 1973. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The plaintiff avers that the marriage is irretrievably broken. 7. The plaintiff requests the Court to enter a Decree of Divorce. married on August 25, 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, plaintiff does not request that the court require the parties to participate in counseling prior to a Divorce Decree being handed down by the court. WHEREFORE, the Plaintiff prays that a Decree in Divorce be entered divorcing Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant. / Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E. Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No. 24849 MARILYN K. BARLUP Plaintiff J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002 CIVIL TERM : LAW - DIVORCE VERIFICATION I, MARILYN K. BARLUP, verify that the statements made in this Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. MARILYN ~. B/~RL~JP ~ MARILYN K. BARLUP Plaintiff VS. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEAINSYLVANIA : : NO. 2002 - ~;~ CIVIL TERM : LAW - DIVORCE : AFFIDAVIT OF SERVICE I, MURREL R. WALTERS, III, ESQUIRE, being duly sworn according to law, depose and say that on July 3, 2002, Defendant, J. Michael Barlup, personally accepted a true copy of the Divorce Complaint filed by Plaintiff Marilyn K. Barlup. Anyceptance of Service signed by J. Michael Barlup is attached her~o. Re s~fT//~~~' Murrel R. Walters, III, Esquire Attorney for Plaintiff 54 E. Main Street Mechanicsburg, PA 17055 (717) 697-4650 I.D. No. 24849 Sworn to and subscribed before me this ~fz6 day , 2002 Notary Public g ¢' NOTARIAL &~r. AL I DEBORAH L. FIYAN, NOTARY PUBLIO J cou. l , MYCOMMIS$10NEX~RESJUNEll, 2006 / MARILYN K. BARLUP Plaintiff VS. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002 -~;~ CIVIL TERM : LAW - DIVORCE AFFIDAVIT OF SERVICE I, J. MICHAEL BARLUP, hereby accept service, by being personally handed a copy of the Divorce Complaint filed by Marilyn K. Barlup. Date: ~-- ~ - 02_ Michael Barlup; MARILYN K. BARLUP Plaintiff VS. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002 ~ 51~5 CIVIL TERM : LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 3, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: MARI~.~I~ K]' -BARLUP MARILYN K. BARLUP Plaintiff vs. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002 ~ FiF$ CIVIL TERM : LAW - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July 3, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 unsworn falsification to authorities. Date: /O/Z?/~L- 'MICHAEl, BARLU[5 MARILYN K. BARLUP Plaintiff VS. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002 - 5;g~ CIVIL TERM : LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(¢) OF T~E 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 decree 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 understand 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: MARILYN K. BARLUP ~ MARILYN K. BARLUP Plaintiff VS. J. MICHAEL BARLUP Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002 CIVIL TERM LAW - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(¢) OF T~E 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 decree 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 understand 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: MARILYN K. J. MICHAEL BARLUP BARLUP VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 2002-3185 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) (Strike out inapplicable section). Date~and manner of service of the complaint: Defendant, Michael Barlu~ was served on 7/3/02 by being handed a copy of the complaint by the Plaintiff, Marilyn K. Barlup (Copy of Affidavit of Service.atta~_h~_~]. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff 10/29/02 ; by defendant 10/29/02 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: n/a (2) Date of filing and service of the plaintiff's affidavit upon the respondent: n/a 4. Related claims pending: None 5. Complete either (a) or (b). (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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: l o / 31 / o 2 wi/ Date defendant's Waiver of Notice in §3301 (c) DivOrcE ~was'J/iled the ProthonotarY: 10,3l,02 ~" ~/ l~ ,i~ //////1 ~ Attorney for Plaintiff / Defendant IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF MARILYN K. BARLUP VERSUS J. MICHAEL BARLUP PENNA. N o. 2002-3185 PLEAS DECREE IN DIVORCE ~ .~,~ ~..~~, , ~, IT IS ORDERED AND DECREED THAT MARILYN K. BARLUP __, PLAINTIFF, AND J. MICHAEL BARLUP , 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; NONE ~4OTARY