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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF PENNA.
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WILLIAM B. BARRICK,
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TERESA..A., BARRICK,
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Defendant
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DECREE IN
D I V 0 R C E J~ ~ ~~,AA
AND NOW, ....~...~......." ,.".." it ;, e,d.,.d end
decreed that"",'" , ,. " " ",I:lHg<;1l)l,!l:, !l<;1rr~~!t", "" """. plaintiff,
and, " , , " " " , , , , , , , , , . , , . , , , ,T,e.r,e,s,a, ,11," ,B,a,r,r,:I.<;~ , , , , " , , , , , '. defendant,
are divorced from the bonds of matrimony,
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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;
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Nune. The attached Pust-Nuptial Agreement is incurpurated, but not
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merged intu this Decree.
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POST-NUPTIAL AGREEMENT
THIS
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AGREEMENT made and entered into this
11f"~
, ~ by and between:
eJ"r
day of
WILLIAM B. BARRICK, of 103 Bungalow Road,
Enola, Pennsylvania, party of the first part,
hereinafter "Husband",
AND
TERESA A. BARRICK, of 1913 E. villa Theresa
Drive, Phoenix, Arizona, party of the second
part, hereinafter "Wife"
WITNESSETH:
WHEREAS, Husband and Wife (collectively referred to herein
as "the parties") were married to each other on June 26, 1983 in
New Kingstown, Cumberland county, Pennsylvania; and
WHEREAS, the parties hereto have accumulated certain
assets, property and debts during their marriage;
WHEREAS, certain differences have arisen between the
parties, as a consequence of which they have heretofore
separated and now live separate and apart from each other; and
LAW o,,.,eu
SNELBAICER
&
BRENNEMAN
WHEREAS, on March 9, 1994 Husband commenced an action in
Divorce docketed to No. 1127 civil 1994 in the Court of Common
-
Pleas of cumberland county, pennsylvania (hereinafter the
"Divorce Action"); and
WHEREAS, the parties agree that their marriage is
irretrievably broken; and
WHEREAS, the parties acknowledge that each has had the full
opportunity to be advised independently and represented by
separate counsel concerning their respective rights, duties and
obligations arising out of their marital status; and
WHEREAS, the parties having a full opportunity to be so
advised of their respective rights, duties and obligations
arising out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and
all other aspects of each other's property and their jointly
owned assets and liabilities, have come to an agreement for the
final settlement of their propert~ and affairs.
NOW THEREFORE, in consideration of these presents and the
mutual covenants, promises, terms and conditions hereinafter set
forth and to be kept and performed by each party hereto, and
intending to be legally bound hereby, the parties mutually agreej
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as follows: !
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The foregoing preamble and I
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,
1.
INCORPORATION OF PREAMBLE.
LAW O"ICE.
SNELBAKER
a
BRENNEMAN
paragraphs are incorporated by reference herein in their
entirety.
2. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties declare and agree that they have, prior to the
execution of this Post-Nuptial Agreement, voluntarily agreed to
divide and have physically divided and distributed between
themselves all assets which they Acquired during their marriage,
whether or not said property is or would be deemed to be mQrital
property under Pennsylvania Divorce Code and subject to
equitable distribution. The parties further declare And agree
that prior to the execution hereof, they have voluntarily
distributed between themselves all assets and property which
each brought with them into their marriage.
The parties declare and acknowledge that they are
fully aware and familiar with all assets and property that each
have brought into the marriage and that have been obtained or
acquired separately or jointly by them during the course of
their marriage and therefore waive any evaluation thereof. Each
party expressly releases the other of and from any and all right
of equitable distribution or claims to assets and property of
any kind or nature whatever possessed by the other party.
3. AUTOMOBILES. Husband presently has in his possession
and is using a 1992 Ford Ranger purchased during the parties'
marriage and titled in Wife's name. Said vehicle is encumbered
LAW O".CEI
SNELBAKER
a
BRENNEMAN
If permitted by Ford Motor
,
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Credit, Wife shall transfer title in said vehicle to Husband '
alone and if not so permitted, immediately upon refinancing the !
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by a lien held by Ford Motor Credit.
Ford Motor Credit debt or upon husband's payment of that debt in
full. Husband agrees to be responsible for and pay all amounts
due Ford Motor credit. Husband agrees to make a good faith
effort to refinance the debt on said vehicle for purposes of
extinguishing Wife's liability therefor. Husband agrees to
indemnify and hold harmless Wife from any and all debts, damages
and expenses which Wife may incur directly or as a result of
Husband's failure to payor discharge said debt.
Wife presently has in her possession and is using a
1992 Thunderbird purchased during the parties' marriage, which
vehicle is encumbered by a loan. Husband agrees to transfer
title in said vehicle to Wife alone if permitted by the lien
holder. wife agrees to be responsible for and pay all amounts
due on the loan secured by said vehicle. Wife further agrees to
make a good faith effort to refinance the debt on said vehicle
for purposes of extinguishing Husband's liability therefor.
Wife agrees to indemnify and hold harmless Husband from any and
all debts, damages and expenses which Husband may incur directly
or as a result of Wife's failure to payor discharge said debt.
Each party agrees promptly to execute any and all
documents necessary to transfer title ownership and/or refinance
debt in order to effectuate the terms set forth above.
LAW o,."cce
SNILBAKER
It
BRENNEMAN
4. REAL ESTATE. The Real Estate acquired by the parties
during marriage; namely, the home located at 18 Eisenhower
Boulevard, Duncannon, Perry county, Pennsylvania, was sold on
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December 15, 1994 and the proceeds of same split by agreement of
the parties and to their satisfaction after the payment of
certain debts incurred during marriage.
Each party agrees to waive and does hereby waive any
right, claim or title to any real property acquired by the other
party prior to or after any final decree in divorce is granted
or entered.
5. DIVISION OF LIABILITIES. The parties declare and agree
that they have divided a~d allocated between themselves all
debts and liabilities, whether or not incurred by them during
the course of their marriage.
Husband agrees to hold harmless and indemnify Wife
from any and all debts, damages, costs and expenses which Wife
may incur directly as a result of Husband's failure to payor
discharge any debt or obligation he agrees to pay hereunder and
as elsewhere set forth in the Agreement. Wife agrees to hold
harmless and indemnify Husband from any and all debts, damages,
costs and expenses which Husband may incur directly as a result
of Wife's failure to payor discharge any debt or obligation she
agrees to pay hereunder and as elsewhere set forth in this
Agreement.
LAW O"'ICU
SNELBAtCEA
8r
BRENNEMAN
6. FUTURE OBLIGATIONS. The parties agree that
obligations incurred subsequent to the date of their
d all i
any an I
separation,
December 11, 1993, shall be the sole and separate liability and
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responsibility of the party incurring the obligation and each
party agrees that he/she will not incur or attempt to incur any
obligations for or on behalf of the other party and will
indemnify and hold harmless the other party of and from any and
all liability arising from such future obligation.
7. COUNSEL FEES. Each party to this Post-Nuptial
Agreement shall be responsible for paying his or her own counsel
fees and related costs associated with the processing of the
Divorce Action and the negotiation, execution and consummation
of the provisions of this Post-Nuptial Agreement.
8. PENSION. 401K. RETIREMENT PLANS. BENEFITS AND
EMPLOYMENT BENEFITS.
Each party waives and forever releases the other of and
from any and all claims which either may have against the
other's pension, 401K Plan retirement plan or any other
retirement plan, benefit or employee benefit or benefits, if
any.
UW O,.,.ICCS
SNELDAKER
&
BRENNEMAN
9. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of
and from any and all claims which either may have against the
other for spousal support and for all claims which either may
have against the other by reason of and pursuant to the
Pennsylvania Divorce Code (and the divorce law of any other
jurisdiction) including, but not limited to, alimony, alimony
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pendente lite, equitable distribution of marital property,
counsel fees, costs and expenses, except that the performance of
any obligation created hereunder may be enforced by any remedies
under the Pennsylvania Divorce Code.
10. DIVORCE. The parties agree to terminate their
marriage by mutual consent without counselling and each agrees
to execute the necessary affidavits and consents to procure a
consensual divorce under the provisions of the pennsylvania
Divorce code, such documents to be filed in the Divorce Action.
lAW O,.P1CCI
SNELBAKER
a
BRENNEMAN
11. GENERAL RELEASE. Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of
the parties hereto by these presents, for himself or herself,
his or her heirs, executors, administrators or assigns, does
hereby remise, release, quit-claim and forever discharge the
other party hereto, his or her heirs, executors, administrators
or assigns, or any of them, of any and all claims, demands,
damages, actions, causes of action or suits at law or in equity
of whatsoever kind or nature, for or because of any matter or
thing done, omitted or suffered to be done by such other party
prior to the date hereof, except that this release shall in no
way exonerate or discharge either party from the obligations and
promises made or imposed by reason of this Agreement.
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12. SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Post-Nuptial Agreement shall survive any
action in divorce which may be instituted or prosecuted by
either party, and no order, judgment or decree of divorce,
temporary, interlocutory, final or permanent, shall affect or
modify the terms of this Agreement, but said Agreement may be
enforced by any remedy at law or in equity, including
enforcement proceedings under the Pennsylvania Divorce Code.
The parties agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this
Agreement shall not be merged into said order or decree in
divorce.
13. COOPERATION. The parties agree to cooperate with each
other and to make, execute, acknowledge and deliver such
instruments and take such further action as may hereafter be
determined to be requisite and necessary to effect the purposes
and intention of this Post-Nuptial Agreement.
LAW opncu
SNELDAtcER
Bt
BRENNEMAN
14. VOLUNTARY EXECUTION. The parties declare and
acknowledge that they have had the opportunity to have the
provisions of this Post-Nuptial Agreement and their legal effect
fully explained to them by independent counsel of their choosing
and each party acknowledges that this Post-Nuptial Agreement is
fair and equitable, that it is being entered into voluntarily,
with full knowledge of the assets of both parties, and that it
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, '
is not the result of any duress or undue influence. The parties
acknowledge that they have been furnished with all information
relating to the financial affairs of the other to the extent
same has been requested by each of them.
LAW CI'''IClI
SNELBAKER
a
BRENNEMAN
15. ENTIRE AGREEMENT. This Post-Nuptial Agreement
contains the entire understanding of the parties and there are
no representations, warranties, covenants or undertakings other
than those expressly set forth herein. The parties acknowledge
and agree that the provisions of this Agreement with respect to
the distribution and division of marital and separate property
are fair, equitable and satisfactory to them based on the length
of their marriage and other relevant factors which have been
taken into consideration by the parties. Both parties hereby
accept the provisions of this Agreement with respect to the
division of property in lieu of and in full and final settlement
and satisfaction of all claims and demands that,.they may now
have or hereafter have against the other for equitable
distribution of their property by any court of competent
jurisdiction pursuant to the Pennsylvania Divorce Code or any
amendments thereto. Each party vOluntarily and intelligently
waives and relinquishes any right to seek a court ordered
determination and distribution of marital property, but nothing
herein contained shall constitute a waiver by either party of
any rights to seek the relief of any court for the purpose of
enforcing the provisions ~: this Agreement.
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16. WAIVER. The waiver of any term, conditions, clause or
provision of this Agreement shall in no way be deemed or
considered a waiver of any other term, condition, clause or
provision of this Agreement.
17. APPLICABLE LAW. This Agreement shall be construed,
interpreted and enforced according to the laws of the
Commonwealth of Pennsylvania.
18. HEADINGS. The headings or titles of the numbered
paragraphs of this Agreement have been used only for the purpose
of convenience and shall not be resorted to for the purposes of
interpretation or construction of the text of this Agreement.
19. EFFECTIVE DATE. This Agreement shall be dated and
become effective on the date when executed by the latter of the
two parties.
IN WITNESS WHEREOF, the parties have hereunto set their
respective hands and seals the day and year first above written
intending to legally bind themselves and their respective heirs,
personal representatives and assigns.
WITNESSED BY:
LAW omcc.
SNILIIAKER
III
BRENNEMAN
"'--~ffJ1Ul ~
eresa A. Barr ck
Date:
(SEAL)
%~~( AI16if~/(i)-{ (SEAL)
W 11 am B. Barr c
Date:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1127 CIVIL 1994
IN DIVORCE
WILLIAM B. BARRICK,
Plaintiff
TERESA A. BARRICK
Defendant
PRAECIPE TO TRANSMIT RECORD
TO: prothonotary of Cumberland County:
Please transmit the record, together with the following
information, to the Court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under
Section 3301(c) of the Divorce Code.
2. Date and manner of service of Complaint: See Affidavit
of Service filed March 25, 1994 indicating service upon Defendant
March 17, 1994.
3. Date of execution of the Affidavit of Consent required
by Section 3301(C) of the Divorce Code: By the Plaintiff: June
26, 1996; by the Defendant: June 26, 1996.
4. Related pending claims: None.
LAW a"le...
SNELDAKER
a
BRENNEMAN
Dated: June 27, 1996
::ELB~~:=:
Keith O. Brenneman
Attorneys for Plaintiff
~ In --
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WILLIAM B. BARRICK, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
vs. . CIVIL ACTION - LAW
.
TERESA A. BARRICK, . NO. II;)) CIVIL 1994
.
Defendant IN 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 divorce is indignities or irretrievable
breakdown of the marriage, you may request that the court
require you and your spouse to attend marriage counseling prior
to a divorce decree being handed down by the court. A list of
marriage counselors is available in the Office of the
Prothonotary at the Cumberland County Court House, Carlisle.
You are advised that this list is kept as a convenience to you
and you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are
to be borne by you and your spouse.
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 WHERE YOU CAN GET LEGAL HELP.
Court Administrator
One Courthouse square
Carlisle, Pennsylvania 17013-3387
(717) 240-6285
LAW O"ICE&
SNELSAKER
a
BRENNEMAN
By
~~ ,
for Pla nt ff
"'-- >,..-..., .....".,.
WILLIAM B. BARRICK,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
TERESA A. BARRICK,
Defendant
NO.
: IN DIVORCE
CIVIL 1994
COMPLAINT
COUNT I - DIVORCE
1. Plaintiff WILLIAM B. BARRICK is an adult individual
residing at 18 Eisenhower Blvd., Duncannon, Perry County,
Pennsylvania 17020.
2. Defendant TERESA A. BARRICK is an adult individual
residing at 4173 Grouse Court, Apartment 118, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
3. Both the Plaintiff and Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six.
(6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully joined in
marriage on June 26, 1983 in New Kingston, Cumberland County,
Pennsylvania.
LAW O,P1CU
SNELBAKER
a
BRENNEMAN
5. There have been no prior actions of divorce or
for annulment between the parties hereto in this or any
other juriSdiction since the date of the marriage averred
in Paragraph 4, above.
6. Neither party is a member of the armed forces of the
united states of America.
7. The Plaintiff avers as the grounds upon which this
action is based is that the marriage between the parties hereto
is irretrievably broken.
8. The 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.
9. The Plaintiff requests this Court to enter a decree of
divorce.
COUNT II - EOUITABLE DIVISION OF PROPERTY
10. The plaintiff and Defendant have legally and
beneficially acquired property both real and personal during
their marriage from June 26, 1983.
11. The Plaintiff requests this court to equitably divide
all marital property pursuant to section 3502 of the
Pennsylvania Divorce Code.
WHEREFORE, the Plaintiff, WILLIAM B. BARRICK, prays your
Honorable court to:
LAW O"ICr..
SNELBAKER
a
BRENNEMAN
(a) enter a decree of divorce, divorcing the
Plaintiff from the bonds of matrimony
heretofore existing between the Plaintiff
and the Defendant; and
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(b) order equitable distribution of marital property.
Date: March 7, 1994
SNELBAKER & BRENNEMAN, P.C.
/1/1
By: "hU1,(.I.'1ttt't"!4't1-z..-
Keith O. Srenneman, Esquire
44 West Main street
Mechanicsburg, PA 17055-0318
Telephone: 717-697-8528
Attorneys for Plaintiff
William B. Barrick
LAW O'..ICI:1I
SNELBAKER
a
BRENNEMAN
VERIFICATION
I verify that the statements made in the foregoing Complaint
re true and correct. I understand that false statements herein
re made subject to the penalties of 18 Pa. C.S. S 4904 relating
o unsworn falsification to authorities.
It )[(?!/UX ,.8. ,/it/AA/~J'li
William B. Barr ck
ate: "t.-..z5-Y4
LAW OF'ICE.
SNELBAI(ER
a
BRENNEMAN
WILLIAM B. BARRICK,
Plaintiff
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
.
.
.
.
vs.
.
.
TERESA A. BARRICK,
Defendant
.
.
NO.
IN DIVORCE
CIVIL 1994
AFFIDAVIT
WILLIAM B. BARRICK, being duly sworn according to law,
deposes and says:
1. I have been advised of the availability of marriage
counseling and understand that I may request that the court
require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of
marriage counselors in the Office of the Prothonotary, which
list is available to me upon request.
3. Being so advised, I do HQI request that the court
require my spouse and I participate in counseling prior to a
divorce decree being handed down by the court.
I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. S 4904 relating to unsworn
falsification to authorities.
LAW QFt'.C:C.
SNEI.DAKER
a
BRENNEMAN
VIto /3. /3 ~
lL L et/U!lL . MAL'
William B. Barr ck
(Plaintiff)
Date: ,[.-.1:.5'-91
WILLIAM B. BARRICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
TERESA A. BARRICK,
Defendant
NO. 1127 CIVIL 1994
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
SS.
COUNTY
OF
CUMBERLAND)
Keith O. Brenneman, Esquire, being duly sworn
according to law deposes and says: that he is a principal in
the law firm of Snelbaker & Brenneman, P. C., being the
attorneys for William B. Barrick, the Plaintiff in the above
captioned action in divorce; that on March 15, 1994, he did send
to Defendant Teresa A. Barrick by certified mail, return receipt
requested, restricted delivery, a duly certified copy of the
Complaint in Divorce which was filed in the above captioned
action as evidenced by the attached cover letter of the same
date and Receipt for Certified Mail No. P 290 633 041; that both
LAW O,...ICC.
SNELBAKER
a
BRENNEMAN
the Complaint and cover letter were duly received by Teresa A.
Barrick, the Defendant herein, as evidenced by the return
receipt card for said certified mail dated March 17, 1994; that
a copy of the aforementioned cover letter dated March 15, 1994
is attached hereto and incorporated by reference herein as
"Exhibit A" and that the original Receipt for Certified Mail and
.'
the Domestic Return Receipt are attached hereto and incorporated
by reference herein as "Exhibit B"; and that the foregoing facts
are true and correct to the best of his knowledge, information
and belief.
,"(iqu<u~
Keith O. Brenneman
Sworn to and subscribed before
me this ..:?J/c.< day of March, 1994.
g~~lj 4 ~---j.1 ~ A~. J
Nota{y ~6n~'~~=-
NaIII1aI Seol PIdc
I'alr'daJ,11vJnsO~ClltI1Iy
~E>\:lrosQoc.31, 1994
LAW O"ICI:.
SNELDAICER
a
BRENNEMAN
. .
SNELBAKER. 8 BRENNEMAN
^ PJl,O.D5IONAL COUORAnON
ATTORNEYS AT ,-^W
.. WUT MAIN sTUET
MECHANICSBllRc;. PENNSYLVANIA 17055
P. O. lOX 311
fACSIMILE C7I7l IW.78l11
IlICHAJU) Co SNELIMEl\.
IWTH O. IIlDlNEMAN
PHIUP H. SPAIlE
7I1'-eQ7.a~1I
March 15, 1994
Teresa Barrick
4173 Grouse Court,
Mechanicsburg, PA
Apartment 118
17055
Re: Barrick v. Barrick
No. 1127 civil 1994
Dear Ms. Barrick:
I am serving upon you a certified copy of the Complaint in
Divorce which was filed on March 9, 1994 in reference to the
above action.
Please be guided accordingly.
Yours truly,
Keith O. Brenneman
KOB/sz
Enclosure
cc: William Barrick (w/enclosure)
Via certified mail, return receipt requested,
restricted delivery, parcel No. 290 633 041
EXHIBIT A
P 29D 1.33 D41
~ Receipt for
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,,,'" Teresa Barrick
l'f173'Grouse Court, Apt. 11
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LAW OfFICES
SNELDAK~n
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BRENNEMAN
EXHIBIT B
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WILLIAM B. BARRICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
.
.
v.
.
.
TERESA A. BARRICK,
Defendant
NO. 1127 CIVIL 1994
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the
Divorce Code was filed on March 9, 1994.
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. S4904 relating to unsworn
falsification to authorities.
Date: June 26. 1996
It ~t#a1&~ /};AA./~Y
W 11 am B. Barr~ck
plaintiff
LAW O,.'ICES
SNELBAKER
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BRENNEMAN
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WILLIAM B. BARRICK,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
TERESA A. BARRICK,
Defendant
: NO. 1127 CIVIL 1994
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the
Divorce Code was filed on March 9, 1994.
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. 54904 relating to unsworn
falsification to authorities.
Date: June 26. 1996
\-h?/.i24 ~./~i'
Teresa A. Barr~ck
Defendant
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WILLIAM B. BARRICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1127 CIVIL 1994
IN DIVORCE
v.
TERESA A. BARRICK,
Defendant
AFFIDAVIT
TERESA A. BARRICK, being duly sworn according to law,
deposes and says:
1. I have been advised of the availability of marriage
counseling and understand that I may request that the court
require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage
counselors in the Office of the prothonotary, which list is
available to me upon request.
3. Being so advised, I do NOT request that the court
require my spouse and I participate in counseling prior to a
divorce decree being handed down by the court.
I understand that false statements herein are made subject
to the penalties of 18 Pa. C.S. S 4904 relating to unsworn
falsification to authorities.
LAW O,.,ICE8
SNELBAfiCER
a
BRENNEMAN
'-,~A~ ~/;
Teresa A. Barrick
Defendant
ate:
June 26. 1996
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WILLIAM B. BARRICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
TERESA A. BARRICK,
Defendant
NO. 1127 CIVIL 1994
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER S 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. S4904 relating to unsworn
falsification to authorities.
Date: June 26. 1996
\ /J lLatA'
4~U2
Teresa A. Barrick
Defendant
LAW o....'cr:.
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BRENNEMAN
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