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Home My WebLink About02-6126 JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SHERRY L. REIFF Defendant NO. 2002 - <c.IJb CIVIL TERM 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 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 ofthe Prothonotary, Cumberland County Court House, 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. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE P A Supreme Court ill: 72897 SCOTT A. STEIN, ESQUIRE 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN R. REIFF, JR. Plaintiff v. CIVIL ACTION - LAW SHERRY L. REIFF Defendant NO. 2002 - (,1.2.(., CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through Law Offices of Peter 1. Russo, P.e., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 112 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 308 Pitt Street, Enola, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 35 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pennsylvania for 37 years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on March 26, 1988 in Cumberland County, Pennsylvania. 6. There are two children of the parties under the age of eighteen (18): Amber Reiff Lauren Reiff May 5, 1995 January 29, 2002 COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder, 8, There has been no prior action for divorce by either party against the other. 9. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. 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, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, John R. Reiff, Jr., prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II: DIVORCE - EOUITABLE DISTRIBUTION 13. Plaintiff hereby incorporates by reference averments 1 through 12 ofthis Complaint as if each averment were set forth fully hereunder. 14. Plaintiff and Defendant have acquired property, both real and personal, during the course of their marriage. 15. The parties have also acquired home furnishings, motor vehicles, bank accounts, retirement accounts, investments and miscellaneous items of personal property. 16. Thus far plaintiff and defendant have been unable to agree as to an equitable distribution of said property, therefore Plaintiff requests the equitable distribution of said marital property. WHEREFORE, Plaintiff, John R. Reiff, Jr., prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree be entered granting equitable distribution of marital property. COUNT II1- CUSTODY 17. Plaintiff hereby incorporates by reference averments 1 through 16 of this Complaint as if each averment were set forth fully hereunder. 18. Plaintiff is John R. Reiff, Jr. residing at 112 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania. 19. Defendant is Sherry L. Reiffresiding at 308 Pitt Street, Enola, Cumberland County, Pennsylvania. 20. Plaintiff seeks custody ofthe following children: Lauren Reiff Present Residence 308 Pitt Street, Enola, Pennsylvania 17025 308 Pitt Street, Enola, Pennsylvania 17025 DOB May 5, 1995 ~ Amber Reiff January 29,2002 21. The children were not born out of wedlock. 22. The children are presently in the custody of the Defendant, who resides at, 308 Pitt Street, Enola, Cumberland County, Pennsylvania. 23. In the last five years the children have resided with the following persons and at the following address: ~ John and Sherry Reiff Address 308 Pitt Street Enola, Pennsylvania ~ October 1996- October 2002 24. The Plaintiff, the father ofthe children, is residing at 112 Hampden Avenue, Camp Hill, Cumberland County, Pennsylvania. He is married. 25. The Plaintiff currently resides with the following persons: ~ Nora Stimeling Daniel Stimeling Relationship Mother Step-father 26. The Defendant, the mother of the children, is residing at 308 South Pitt Street, Enola, Cumberland County, Pennsylvania. She is married, 27. The Defendant currently resides with the following persons: Name Amber Reiff Lauren Reiff Relationship Daughter Daughter 28. Plaintiff is not participating as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 29. The Plaintiff has no knowledge of any custody proceedings concerning these children pending before a court in this or any other jurisdiction. 30. The Plaintiff does not know of any person not a party to this action who has physical custody ofthe children or claims to have custody or visitation rights with respect to the children. 31. The best interest and permanent welfare of the child will be served by: WHEREFORE, Plaintiff requests this Honorable Court to order that the parties: Respectfully submitted, _~~'t/~ Scott A. Stein, Esquire 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 Date: 1;/ &'10'1 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE P A Supreme Court ill: 72897 SCOTT A. STEIN, ESQUIRE 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 Attorneys for Plaintiff JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SHERRY L. REIFF Defendant NO. 2002- IN DIVORCE CIVIL TERM VERIFICATION I, John R. Reiff, Jr., verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: -(; -Or? John JOHN R. REIFF, JR. Plaintiff v. SHERRY L. REIFF Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002- IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE I certify that I am this day serving a copy of the foregoing instrument upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail at Camp Hill, Pennsylvania, via certified mail with restricted delivery, return receipt requested and by regular first-class mail postage, prepaid, as follows: Date: ! J / :U-/17l. Sherry L. Reiff 308 Pitt Street Eno1a, P A 17025 By: LAW OFFICES OF PETER J. RUSSO, P.C. ,~ u -/tJ Scott A. Stein, Esquire LD. No. 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorneys for Plaintiff fi - (JJ c.v _ \) L ,... -.) () ~ "4Q ~ ~ 9v :0 , D () 0 ~ () 0 10 I () C G ( I ~~~ ~t~ '--( '--'; it? C/) 0 a 0 c f'..) :, -- ~,~ ':3 iT 'I m ~.- ; .:, -, -,. ,:-'-- C> '-l (~-. - . -~ - ; ~- \:o_~ , ~.....) f___ :::'. - :iJ :;J , (n -< JOHN R. REIFF, JR. PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 02-6126 CIVIL ACTION LAW SHERRY L. REIFF DEFENDANT IN CUSTODY .,: ORDER OF COURT AND NOW, Friday, January 03, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before ~ Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, P A 17055 on Friday, January 17,2003 , the conciliator, at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday, Esq. ( Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 .P h -'1 ~ ~ ('Cl- f'./ ~/r~~!? ~ ~~ ~(/~F.I ""7r ~~ kop -~ eO-f":/ 'VINv^1},SNN3d "~Nn""ul'"\ (1l'~,.n\PFI~I(() N- t i.' ,-, ,"_~i -,,-} II._.__.).J os :2\ Wd s- H~r ~O .J('\ ....J'-.J LAW OFFICES OF PETER J. RUSSO, P.c. PETER J. RUSSO, ESQUIRE P A Supreme Court ill: 72897 SCOTT A. STEIN, ESQUIRE 3800 Market Street Camp Hill, P A 17011 (717)591-1755 Attorneys for Plaintiff JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION .. LAW SHERRY L. REIFF Defendant NO. 2002 - 612' CIVIL TERM IN DIVORCE PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT AND NOW, COMES, Scott A. Stein, Attorney for Plaintiff, John R. Reiff, Jr., and certifies that on () E Cf;WJ B1:.7{ '2 o) .;l ~ '2. , he did serve the Defendant, Sherry L. Reiff with a true and correct copy of the Divorce Complaint filed against her alleging the parties' marriage was irretrievably broken under Section 3301(d) and Section 3301(c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, return receipt requested and addressed to Sherry L. Reiff at 308 Pitt Street, Enola, Cumberland County, Pennsylvania. ~ Service of Plaintiffs Complaint on the Defendant, Sherry L. Reiffwas effected on IJeC. "J.. J J J- e> 0 ill. . A true and correct copy of the U. S. Postal Service Return Receipt is attached hereto and the original is affixed to the reverse of this document. [ ] Service of Plaintiffs Complaint on the Defendant, Sherry L. Reiffwas effected on . A true and correct copy of Defendant's Acknowledgment of Service is attached hereto and the original is affixed to this document. Date: / /6/03 Respectfully submitted, /~a/rD Scott A. Stein, Esquire ~u.I::\,..... ::h~::J::.~ ~ C 01 t '"b C ("'\ ~~~ .::t.~~~ -. It:> ~ I~ ~ "" ft'l ;; \ ~ ~ ..... :..~ n,. ~J~~ ~~?~ -~~"'t) ~n-,,"~ ~ ~ ~ ~ - % ~ ~ ~ / UNITED STATES POSTAL SERVICE . (J) CD ::l a. CD :: "'U CD Dl C/l CD "0 .., S. - '< o c .., ::l Dl 3 CD Dl a. a. .., CD C/l C/l c z =i m o (J) ~ ~ m C/l "'U o C/l ~ r (J) m ~ () m C. Signature X o Agent o Addressee DYes oNo :>. Is delivery address different from item 1? If YES, enter delivery address below: . Service Type ~. Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. Restricted Delivery? (Extra Fee} ..9'[ Yes l leceipt 102595-0O-M-0952 __~__::t___ . '+ III/II ; ", 0 <::) () ~ W ~-n S.. L- ..\ -0 en :po 1.. ." q;: fTl -'... [np -- -,,-:IJ , -:-ln1 Zr; -fj CJ ~~. CO Ub L_ ~CJ :r.-r ~ ."....~ ...-, .-. -.-, , ~...,..... . ' -".." Fonn 10916(c) (Rev, 10-20001669 Department of the Treasury - Internal Revenue Service Withdrawal of Filed Notice of Federal Tax Lien Area: Serial Number SMALL BUSINESS/SELF EMPLOYED AREA #3 Lien Unit Phone: (412) 395-5265 230298570 I certify that the fOllowing-named taxpayer has met one or more of the elements of the Internal Revenue Code (IRC) section 6323{j). The Internal Revenue Service therefore withdraws the Notice of Federal Tax Lien for these taxes and additions. The withdrawal of this notice of lien does not affect the statutory lien provided by IRC section 6321; it simply relinquishes any lien priority obtained by the Internal Revenue Service when the notice was filed. The pro~r officia1 in the office where the Notice of Federal Tax Lien was filed on December 2 I, 2002 , is authorized to update the records to show the withdrawal of the notice of lien for these taxes and additions. Name of Taxpayer DAVID M & DANA L CHERRY For Optional Use by Recording Office -# OJ. - & ( ') 2 F7L Residence 606 ALLENVIEW DR MECHANICSBURG, PA 17055-6199 o ~:~ gl~; ....-- ~e ..J-"c.' --.; ..:" =<! "=1 (..,) I 0:) ='? . , -_\J ;'V \D ~( 4[~ @ J~~405 ,} f1ff ~ 6; !.I Unpaid Balance of Assessment (f) COURT RECORDING INFORMATION: Liber Page UCC No. Serial No. n/a n/a n/a 02-6132 FTL Tax Period Kind of Tax Ending Identifying Number (a) (b) (c) 1040 12/31/1990 296-50-2851 1040 12/31/1991 296-50-2851 1040 12/31/1992 296-50-2851 1040 12/31/1993 296-50-2851 1040 12/31/1993 296-50-2851 1040 12/31/1994 296-50-2851 1040 12/31/1995 296-50-2851 1040 12/31/1996 296-50-2851 1040 12/31/1997 296-50-2851 1040 12/31/1998 296-50-2851 1040 12/31/1999 296-50-2851 ******************************** Date of last Day for Assessment Refiling (d) (e) 06/03/1991 N/A 08/03/1992 N/A 04/11/1994 05/11/2004 OS/23/1994 06/22/2004 10/30/1995 11/29/2005 OS/22/1995 06/21/2005 05/19/1997 06/18/2007 05/19/1997 06/18/2007 07/31/2000 08/30/2010 06/14/1999 07/14/2009 06/05/2000 07/05/2010 **********~************ Place of Filing Prothonotary Cumberland County Carlisle, PA 17013 Total $ This notice was prepared and signed at PITTSBURGH, PA , on this, the 31st 2002 day of December Sign Title Compliance Technical Support Manager Cat. No. 24586T 14.98 334.83 1604.28 1414.03 730.45 1600.26 1368.75 108.24 206.19 200.75 **************** 7582.76 Part 1 - Recording Office Form10916(c) (Rev. 10-2000) Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN R. REIFF, vs. 02-6126 CNIL ACTION LAW SHERRY L. REIFF Defendant IN CUSTODY ORDER OF COURT AND NOW, this z'if. day of 1~"a.c..y , 2003, upon consideration of the attached Custody Conciliation Repo~, it is o~lered and directed as follows: 1. The Father, John R. Reiff, and the Mother, Sherry L. Reiff, shall have shared legal custody of Amber Reiff, born May 5, 1995, and Lauren Reiff, born January, 29, 2002. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children including, but not limited to, school and medical records and information. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of Amber on alternating weekends from Friday at 6:00 pm through Sunday at 7:00 pm, beginning Friday, January 31,2003. The Father shall have shorter periods of custody (not overnight) with Lauren as arranged by agreement of the parties. In addition, the Father shall be entitled to have custody of both Children during one evening per week as arranged by agreement. 4. The Father shall contact the Mother in the event he has m work during his periods of custody to offer the Mother the opportunity to provide care for the Child or Children during the Father's unavailability prior to contacting third party care givers. ...:r u--- {tj o 0 VlN"JAlASNN3d lJNn08 ONVli:E1frlNna 2fJ :01 Wd 62 N~r f:O I U\-ilC" , . '. , ^(J V l~"-Jt....: . 3JI:l~(}{jJ:d ;~h, :lei 5. The parties shall share or alternate having custody ofthe Children on holidays as follows: A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall run from Christmas Eve at 12:00 noon through Christmas Day at 12:00 noon, and Segment B which shall run from Christmas Day at 12:00 noon through December 26th at 12:00 noon. In odd numbered years, the Father shall have custody of the Children during Segment A, and the Mother shall have custody during Segment B. In even numbered years the Mother shall have custody of the Children during Segment A, and the Father shall have custody during Segment B. B. EASTER: The party who has custody of the Children over the weekend under the regular custody schedule shall retain custody of the Children on Easter Sunday until 2:00 pm and the other party shall have custody from 2:00 pm until 7:00 pm on Easter. C. THANKSGIVING: In every year the Father shall have custody of the Children from 9:00 am until 2:00 pm and the Mother shall have custody on Thanksgiving beginning at 2:00 pm. D. ALTERNATING HOLIDAYS: In odd numbered years, the Father shall have custody ofthe Children on Memorial Day and Labor Day and the Mother shall have custody on July 4th. In even numbered years, the Mother shall have custody of the Children on Memorial Day and Labor Day and the Father shall have custody on July 4th. The periods of holiday custody on Memorial Day and Labor Day shall run from 9:00 am until 7:00 pm and the period of custody on July 4th shall run from 9:00 am until after the fireworks. E. MOTHER'S DAY I FATHER'S DAY: In every year, the Mother shall have custody of the Children on Mother's Day from 9:00 am until 7:00 pm and the Father shall have custody on Father's Day from 9:00 am until 7:00 pm. F. The holiday custody schedule shall supercede and take precedence over the regular custody schedule. 6. Each party shall be entitled to have extended periods of custody of the Children during the summer school vacation each year as arranged by agreement. 7. Neither party shall do or say anything which may estrange the Children from the other parent, injure the opinion of the Children as to the other parent, or hamper the free and natural development ofthe Children's love and respect for the other parent. Both parties shall ensure that third parties having contact with the Children comply with this provision. 8. This Order is entered pursuant to an agreement ofthe parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms ofthis Order shall control. BY THE COLfRT, Ad J. cCi/9ail G. Souders, Esquire, Counsel for Mother / /Scott A. Stein, Esquire, Counsel for Father L~~ fi\ RX~ () I - ;l q - 03 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JOHN R. REIFF, vs. 02-6126 CNIL ACTION LAW SHERRY L. REIFF Defendant IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLANIJI COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Children who are the subjects of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Amber Reiff Lauren Reiff May 5, 1995 January 29,2002 Mother Mother 2. A Conciliation Conference was held on January 22,2003, with the following individuals in attendance: The Father, John R. Reiff, with his counsel, Scott A. Stein, Esquire and the Mother, Sherry L. Reiff, with her counsel, Gail G. Souders, Esquire. 3. The parties agreed to entry of an Order in the form as attached. Date ja-".~ d,l, ;/063 ~Jlf Dawn S. Sunday, Esquire Custody Conciliator JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAN)) COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW SHERRY L. REIFF ))efendant NO. 2002 - 6126 IN DIVORCE CIVIL TERM DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 330I(c) OF THE DIVORCE CODE I. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on December 26, 2002. 2. The marriage is irretrievably broken and ninety days hav,' elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, di vision of property, lawyers fees or expenses if! do not claim them before a divorce is granted. 5. 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's Office. 6. 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. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Sherry L. Reiff, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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. S 4904 relating to unsworn falsification to Authorities. J\_11l_0l_ '~ DATE ~~ .-" . LAW OFFICES OF PETER J. RUSSO, P.c. PETER J. RUSSO, ESQUIRE P A Supreme Court ill: 72897 SCOTT A, STEIN, ESQUIRE 3800 Market Street CampHill,PA 17011 (717) 591-1755 Attorneys for Plaintiff JOHN R REIFF, JR Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SHERRY L. REIFF Defendant NO. 2002 - 6126 IN DIVORCE CIVIL TERM ACKNOWLEDGMENT OF SERVICE OF COMPLAINT IN DIVORCE UN))ER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CO))E AND NOW, COMES, Defendant, Sherry L. Reiff, and does hereby acknowledge that on the date indicated below she did receive a verified copy of a Complaint in Divorce filed against her in the above captioned case. DATED:-L-J Lf - 03 ~ff (:' JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SHERRY L. REIFF Defendant NO. 2002 - 6126 IN DIVORCE CIVIL TERM PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CO))E I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ))ecember 26, 2002. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses ifI do not claim them before a divorce is granted. 5. 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's Office. 6. 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. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, John R. Reiff, Jr., do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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. S 490 re ting to unswom falsification to Authorities. /-i-ll-(}6 DATE ,.\ LAW OFFICES OF PETERJ. RUSSO, P.c. PETERJ. RUSSO, ESQUIRE P A Supreme Court ill: 72897 SCOTT A, STEIN, ESQUIRE 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorneys for Plaintiff JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW SHERRY L. REIFF Defendant NO. 2002 - 6126 IN DIVORCE CIVIL TERM PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON ))EFENDANT AND NOW, COMES, Scott A. Stein, Attorney for Plaintiff, John R Reiff, Jr., and certifies that on Januarv 4,2003 , he did serve the Defendant, Sherry L. Reiff with a true and correct copy of the Divorce Complaint filed against her alleging the parties' marriage was irretrievably broken under Section 330l(d) and Section 3301(c) of tbe Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, return receipt requested and addressed to Sherry L. Reiff at 308 Pitt Street, Enola, Cumberland County, Pennsylvania. [) Service of Plaintiffs Complaint on the Defendant, Sherry L. Reiffwas effected on . A true and con'ect copy of the U.S. Postal Service Return Receipt is attached hereto and the original is affixed to the reverse of this document. [X) Service of Plaintiffs Complaint J anuarv 14. 2003 Acknowledgment of Service is document. on the Defendant, Sherry L. Reiff was effected on . A true and correct copy of Defendant's attached hereto and the original is affixed to this Date: J - ,) y - 0:> Respectfully submitted, ~~*CftP Scott A. Stein, Esquire ( LAW OFFICES OF PETER J. RUSSO, P.c. PETER J. RUSSO, ESQUIRE PA Supreme Court ill: 72897 SCOTT A. STEIN, ESQUIRE 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 Attorneys for Plaintiff JOHN R. REIFF, JR. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW SHERRY L. REIFF ))efendant NO. 2002 - 6126 IN DIVORCE 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: I. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on Sherry L. Reiff by Certified Mail, with return receipt on January 14, 2003 as evidenced by her Acknowledgement of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff: April 17 . 2006 by defendant: April 17 . 2006 4. Related claims pending: None 5. Date plaintiffs Waiver of Notice was filed with the prothonotary: April 24. 2006 Date defendant's Waiver of Notice was filed with the prothonotary: April 24. 2006 Date: '1'J.S leI (; Respectfully submitted, _L;ff?:/'p Scott A. Stem ~ (") ....., = ~ c = < "'" vt:{, :x ~ cpn )> m:II ~t~'~ -< r- ~m -' N 06 I~'s :;:1--- > :........-H ::r 90 c Vi' 15m Z ~ =2 w N =-< . . . . . . . ~ ~ ~~~~~~~ ~~ ~~ ~~~~~ ;Ii :f. ff.'+i IN THE COURT OF COMMON PLEAS . . . . AND NOW, . . OFCUMBERLANDCOUNTY STATE OF PENNA. . . JOHN R. REIFF, JR., 2002 - 6126 . No, Plaintiff . . . VERSUS . SHERRY L. REIFF, Defendant .' . . . . . . . . . . . . . . DECREED THAT . . AND DECREE IN DIVORCE /' . /Y)~ .. JOHN R. REIFF, JR. , .2.00', IT IS ORDERED AND PLAI NTI FF, SHERRY L. REIFF , 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; . . . . AI!),) t J BY THE COURT: ATTEST' J. ~~PPOT"ONOT^,' . . 'Ii''Ii''Ii' 'Ii' .. . ~ 'Ii' ~'Ii'~'Ii'~~~ 'Ii''Ii'~'Ii''Ii' 'Ii' 'Ii'~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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