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Home My WebLink About07-0799F2 ELLEN M. SAYLES, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. REGINAL L. SAYLES, Defendant : CIVIL ACTION - LAW : 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One 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. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)-990-9108 ELLEN M. SAYLES, Plaintiff, VS. REGINAL L. SAYLES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . NO. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud. se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por las Corte. una decision puede tambien ser emitida en su contra por caulquier otra queja o compensacion eclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County, One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telefono (800)-990-9108 ELLEN M. SAYLES, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA L VS. :NO. REGINAL L. SAYLES, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes Plaintiff, Ellen M. Sayles, by and through her counsel, Linda A. Clotfelter, who files this Complaint in Divorce and in support thereof states the following: 1. Plaintiff is Ellen M. Sayles, (hereinafter "Plaintiff") an adult individual who resides at 836 Factory Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Reginal L. Sayles, (hereinafter "Defendant"), an adult individual who resides at 836 Factory Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the parents of two (2) minor children, namely, Alexis R. Sayles, born February 26, 1998, age eight (8) years; Sydney A. Sayles, born January 21, 2002, age five (5) years. There are presently no disputed issues regarding the children. 4. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this divorce Complaint. 5. Plaintiff and Defendant were married on December 15, 1997, in El Paso County, Texas. 6. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since February 7, 2007. 7. There are no pending divorce proceedings upon the filing date of this Complaint. { ?? 8. Defendant is not a member of the armed forces of the United States or any of its allies. 9. Plaintiff avers that the marriage is irretrievably broken. 10. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff, Ellen M. Sayles, respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this Court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Date: B 3M21 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff VERIFICATION I, ELLEN M. SAYLES, verify that the statements in the foregoing DIVORCE COMPLAINT are true and correct to the best of my knowledge, information and belief. 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: Z 7 ELLEN M. SAYLES c ? l I V ' ? _ ? 4 i r r CJ 3 "'? 1 ELLEN M. SAYLES, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-799 CIVIL REGINAL L. SAYLES, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Linda A. Clotfelter, Esquire, counsel for Plaintiff, Ellen M. Sayles, do hereby affirm that the original return receipt dated February 22, 2007, for the Divorce Complaint which was sent by Certified Mail, Restricted Delivery, Return Receipt Requested, is set forth below and appears to contain the signature of Reginal L. Sayles. Also attached is the USPS electronic confirmation for certified mail number 7001 2510 0003 4439 8249. The undersigned understands that the statements herein are made subject to the penalties of 18 P.S. § 4904 relating to unworn falsification to authorities. ¦ Complete Items 1, 2, and 3. Aiso complete Item 4 if Restricted Delivery 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. Article Addressed to: *4R1.. i.., 2Yt4tES 061121 islR- . Aqlj1rtbts A. Signa X Agent 1.ez?,Z:L dressee B. Recei by ( Printed Name) C. Dgte of D*ery D. Is delivery address different from Rem 1? ? 'tes If YES, enter delivery address below: ? No 3. Service Type XCert fl Mail ? Express Mail ? Registered 'XRetum Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery Pft Fee) 2. Article Number (Transfer from service fabO 7001 2 510 0003 4439 8249 Ps Form 3811, February 2004 Donbstlc Return Pka ipt 102595-02-M-1540 Respectfully submitted, Dated: s D LAW OFFICE OF LINDA A. CLOTFELTER inda A. Clotfelter, Esquire ttorney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 telephone (717) 796-1930 facsimile (717) 796-1933 Attorney for Plaintiff h EA ?C 0 N N N O O J 0 M Q iD D Z M 0 0 R e?ro t(3 ip C ff3 ? VS ,y, D CD ?p z 00 ri F> > 0 0 0 A Q m 3 h I I t i i -0? C&s D °WO 1 c v E SD O m y 77 C'S w3 CL „z N a3 E (.. CL ?. 8 N O O ° 8 7 w T N O O v 7 n D r cn r - In N 0 33 m Co -o z r_ 3 Q CD 91 WWII a e a t? O -w 3 a O H 3 ., rQ ?m ELLEN M. SAYLES, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-799 CIVIL REGINAL L. SAYLES, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 1,54*1 day of March, 2007, the undersigned hereby certifies that a true and correct copy of the foregoing AFFIDAVIT OF SERVICE was served upon the opposing parry by United States First Class Mail, postage prepaid: Reginal L. Sayles 836 Factory Street Carlisle, PA 17013 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Linda A. Clotfelter, Esquire orney ID No. 72963 021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff 1 ? ? ?i : ? ?? ? ? ...,- _r? ?? ? ? Ti?~? ??" ; ?• ELLEN M. SAYLES, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.07-799 CIVIL REGINAL L. SAYLES, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed February 9, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and 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. Section 4904, relating to unsworn falsification to authorities. V Date: QCO ELLEN M. SAYLES, Plaintiff o fT ? rn C ELLEN M. SAYLES, Plaintiff, VS. REGINAL L. SAYLES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-799 CIVIL CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 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. Dater Q 7 ELLEN M. SAYLES, Pl ' tiff ?uF i ).5 r C.S1 ? 1 ? C..a ? co ELLEN M. SAYLES, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-799 CIVIL REGINAL L. SAYLES, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 9, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and 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. Section 4904, relating to unworn falsification to authorities. Date: RE AL L. SAYLES, Defendant ,i;(t C? o ?- o -rt Fn- 7tj S`i't C-S ELLEN M. SAYLES, Plaintiff, VS. REGINAL L. SAYLES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-799 CIVIL : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 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: REG AL L. SAYLE , Defendant C? ? p -OM ?C7 Gal 3 ELLEN M. SAYLES, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-799 CIVIL REGINAL L. SAYLES, : CIVIL ACTION - LAW Defendant : IN DIVORCE 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. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint was filed on February 9, 2007. 3. Date and manner of Service of the Complaint: February 22, 2007, by Certified Mail, Return Receipt, Restricted Delivery, as evidenced by the Affidavit of Service filed on March 16, 2007. 4. Plaintiffs Affidavit of Consent was executed by Plaintiff on May 29, 2007, and filed on June 5, 2007. The Defendant's Affidavit of Consent was executed on May 31, 2007, and filed on June 11, 2007. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on May 29, 2007, and it was filed on June 5, 2007. Defendant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on May 31, 2007, and it was filed on June 11, 2007. 6. There are no related claims pending. Respectfully submitted, FIRM OF LINDA A. Clotfelter Date: y: Li da A. Clotfelter, Esquire torney I.D. No. 72963 021 East Trindle Road, Suite 1 Mechanicsburg, PA 17050 (717) 796-1930 - ., - rTi i --C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ELLEN M. SAYLES, Plaintiff VERSUS REGINAL L. SAYLES, Defendant 07-799 CIVIL No. DECREE IN DIVORCE AND NOW, ' 2007 IT IS ORDERED AND ELLEN M. SAYLES DECREED THAT PLAINTIFF, REGINAL L. SAYLES AND 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 A BY ,Tj+E COU ATTEST: J. PROTHONOTARY ?o -