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HomeMy WebLinkAbout03-0150GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul $. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 DEBRA W. REESE, IN THE COURT OF COMMON PLEAS Plaintiff, V. JACK W. REESE, JR., Defendant. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 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 man/age, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, 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 BAR AS SOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de en abogado una comparecencia escrita y radicando en la Corte pot escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar action como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya pot la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVARESTE DOCUMENTO A SU ABOGADO IMMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME O VAYA A LA SIGU[ENTE LEGAL. OFICINAPARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Goldberg, Katzma~ & Shipman, P.C. Paul J. Esposito, Esquire - I.D. #25454 320 Market Street Posl Oltice Box 1268 Harrisburg, PA 17108-1268 Altorneys for Plaintiff DEBRA W. REESE, Plaintiff, Vo JACK W. REESE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03- /523 IN DIVORCE WAIVER OF COUNSELINC DEBRA W. REESE, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that may request that the Court require my spouse and I to 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 that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Waiver 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. OEBRA W. REEVE GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Stmwbeny Square Post Office Box 1268 Harrisburg. PA 17108-1268 (717) 234-4161 DEBRA W. REESE, Plaintiff, · JACK W. REESE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. /SC) IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, DEBRA W. REESE, is an adult individual, who currently resides at 55 Southmount Drive, Enola, Cumberland Coumy, Pennsylvania. 2. Defendant, JACK W. REESE, JR., is an adult individual whose currently mailing address is P. O. Box 60032, Harrisburg, Daiuphin County, Pennsylvania. 3. Plaintiff avers that she has been a bona fide resident in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The parties were married on January 27, 2000, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment filed by either of the parties hereto. 6. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 7. The Defendant in this action is not presently a member of the United States Armed Forces or of any of its allies. 8. Plaintiff requests the court to enter a decree of divorce. thereto. 10. .COUNT I The averments of Paragraphs 1 through 8 herein are hereby incorporated by reference The marriage is irretrievably broken. WHEREFORE, Plaintiffprays Your Honorable Court to: (a) Enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant; and Co) Order such other relief as the Court deems just and reasonable. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. PAULe~' Ept3osfi'b- ESQUn Supreme Court ID #25454 Post Office Box 1268 Harrisburg, PA 17018-1268 Attorneys for Plaintiff (717) 234-4161 89006.1 VERIFICATION I verify that the statements contained in the foregoing COMPLAINT INDIVORCE are true and correct to the best of my knowledge, information and belief.. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. unsworn falsification to authorities. Section 4904 relating to DEBi~ W. REESE ' GOLDBERG~ KAT~ & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Ofl%e Box 1268 Han~sburg, PA 17108-1268 (717) 234-4161 DERRA W. REESE, IN THE COURT OF COMMON PLEAS JACK W. REESE, JR., · Defendant. · CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF DAUPHIN ) Personally appeared before me, a Notary Public, in and for said Commonwealth and County, PAUL J. ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on January 10, 2003, he sent a copy ora Complaint in Divorce filed with the Cumberland County Court of Common Pleas, by certified mail, return receipt requested, restricted delivery, to Jack W. Reese, Jr., and the return receipt card signed by Jack W. Reese, Jr., and shown as being delivered January 13, 2003, is attached hereto and made a part hereof. ~ ~ / PAUL J. pPO~j~O, ESQU1RE Sworn to and subscribed before me this _2~day of January, 2003. No~yry Pubhc -' ~ My Commission Expires: 89926.1 ~ Notam~ Seal _...~e~,K~,ter L. Boltz Notary Public ~3ty .:,f Harrisburg,' Dauphin Coun 'Commission Expires Mai 30 o~nn~ emir, Pennsylvania Association of Notaries m Postage r""l Certified Fee Retum Receipt Fee I V I"U (Endomement Required) f"-I (Endorsement Required) 0 Total P(mta~e & Fee~ _-z' I Sent TO I r'~[Mr. Jack W. Reese, Jr. I n,/~;'~'t;'X~:"~;:;* ........................................................... I ~ [or PO eox No. P.O. Bo× 60032 _c3 r:~'~:;~;'~;;'~'"':: .......... ': ..................................... I '- ~arrisDur , PA 17].06 Complete Items 1, 2, and 3. AJ8o compile :'~1~1 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. mallplece,. or on the front if space permits. 1. Article Addressed to: Mr. Jack W. Reese, Jr. P. O. Box 60032 Harrisburg, PA 17 106 RESTRICTED DELIVERY 2. Article Number ('rransfer frorn service label) 7 PS Form 381 ~, August 2001 3. Service Type ~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail r"l C.O.D. Domestic Return Receipt 102595-02-M-0~35 GOLDBERG, KATZMAN & SHIP~, P.C. Paul $. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 DEBRA W. REESE, IN THE COURT OF COMMON PLEAS Plaintiff, Vo JACK W. REESE, JR., Defendant. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DIVORCE EIJECTION TO RESIJMI*~ PRIOR NAME DEBRA W. REESE, being duly' sworn according to law, deposes and says that she is the Plaintiff in the above suit, which was filed with the Court of Common Pleas on January 9, 2003, at the above-referenced docket number. That Defendant wishes to retake and hereafter use her prior name of DEBRA BARBARA KORHUT, and therefore, gives written notice of avowing said intention, in accordance with the provisions of Title 54 Pa.C.S.A. §704(a). To be known as DEBRA BARBARA KORHUT DEBRA BARBARA KORHUT Sworn to and subscribed before me this / day of Iammry, 2003. olq~. Public My Commission Expires: DEBRA W. REESE, Plaintiff, JACK W. REESE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COLrNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 9, 2003. 2. The marriage of Plaintiffand 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 in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and I 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, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint in Divorce on or about January 13, 2003, by certified mail, restricted delivery. 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 unswom falsification to authorities. Date:-6/o.~ ':~- ,2003 //~c~}~:-,,-~~// · ~W.~ESE, JR. ' ~ 96544,1 DEBRA W. REESE, Plaintiff, JACK W. REESE, JR., : Defendant. : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DIVORCE 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 tree 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: "4~¢0~. ~- ,2003 %C~'W. REESE, JR.'~k~ 96543.1 GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 DEBRA W. REESE, Plaintiff, JACK W. REESE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 9, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. I verify that the statements made in this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Date: ~ ,2003 .CL,~..J t"t~ 2003 DEBRA W. REESE DEBRA BARBARA KORIqUT 96541.1 GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 DEBRA W. REESE, Plaintiff, V. JACK W. REESE, JR., Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DIVORCE 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 divome 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 unsworn falsification to authorities. Date: ~c~ DEBRA W. REESE~ DEBRA BARBARA KORI-IUT 96542.1 © cT} ~? . .,.: DEBRA W. REESE, Plaintiff V. JACK W. REESE, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-150 Civil Term IN DWORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: Code. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce 2. Date and manner of service of the Complaint: Certified MaiL Restricted Delivery~ on January 13~ 2003. 3.(a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff on June 17~ 2003 ; by Defendant on June 12~ 2003 (b)(1) Date of execution of the Affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None. 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Co) Date Plaintiffs Waiver of Notice in § 3301 (c) Divorce was filed with the prothonotary: July 16~ 2003. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: June 18~ 2003. Attorney for Pla~tiffy IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ~~. PENNA. DEBRA W. REESE Plaintiff Defendant VERSUS .TACK W. RFFSE NO. 03-1~0 DECREE iN DIVORCE AND NOW, DECREED THAT AND Debra W. Reese Jack W. Reese, Jr. ARE DIVORCED FROM THE BONDS Of MATRIMONY. , . ~L~_~ IT IS ORDERED AND __~ PLAINTIFF, , DEFENDANT, 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;