The URL can be used to link to this page

Home My WebLink About03-1227 SHERYL J. REED, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Defendant CIVIL ACTION - LAW c-- NO. 03 - 1;)J.7 C!..,"ui l~ IN DIVORCE CARL J. ARRIGO, NOTICE TO DEFEND AND CLAIM RIGHTS TO: Carl J. Arrigo 432 Trudy Road Harrisburg, P A 17109 YOU HA VE 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. 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 at the 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #: 262868.1 SHERYL 1. REED, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Defendant CIVIL ACTION - LAW NO. O~ - 'J.~7 CI"LL'r~ IN DIVORCE CARL J. ARRIGO, COMPLAINT IN DIVORCE 1. The Plaintiff, Sheryl 1. Reed, is an adult individual currently residing at 4601 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant, Carl J. Arrigo, is an adult individual currently residing at 432 Trudy Road, Harrisburg, Dauphin County, Pennsylvania, 17109. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 12,2002, in Maui, Hawaii. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security Number is 188-62-9162 and Defendant's Social Security Number is 146-84-3814. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plaintiffhas 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. There were no children born of this marriage. 10. The marriage is irretrievably broken. Document #: 262868,/ . -..-..-------.......:.:.;''';;-;;.,,;,,,,...0.=..;,:.,,,,,.,,,"''',,.,,,....,_..'" VERIFICATION I, Sheryl 1. Reed, hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. lkq ~ ~ ~jO() Sheryl J. Re Date: ~ -\T.~ Document #: 262868, J (clP~ ~~~ ~ ~ ~ c '3.c: 1f! .c;: ~ - (J) 1- -- . GJ . , --- -.... .:J Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COmtTY, PENNSYLVANIA CIVIL ACTION - LA NO. 03- -lll1 IN DIVORCE SHERYL J. REED, Plaintiff v. CARL J. ARRIGO, AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff, Sheryl J. Reed, injthe above captioned action, hereby certify that a true and correct copy of the Complaint in Divorf was served upon Defendant, Carl J. Arrigo, on March 27, 2003, by certified mail, return receip requested, restricted delivery. Attached hereto, marked as Exhibit "A", and incorporat herein by reference is a copy of the return receipt card for said service. METZGER, WICKERSHAM, KNAU S & ERB, P.C. By G---; Andrew C. Spears, Esquire Attorney J.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, P A 1711 0-0300 (717) 238-8187 Attorneys for Plaintiff Dated: ~-\..\j~ Document#:26616~1 Exhibit A VERIFICATION I, Andrew C. Spears, Esquire, attorney for Plaintiff, hereby certify that the facts set forth in the within Affidavit of Service are true and correct to the best of my knowle ge, information and belief, and that false statements herein are made subject to the penalties 0 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities. Andrew C. Spears Date: '-\ ~ '\ . tJ ') Document#:26616&1 o c: ~" ~~;: -7 ~.: ~-; ~. C0 ~, -< r:. ~ ~(;~, ....C ~~ ~;: :~ ~ ,.-.., W ~ :::0 I CO o 'n w N .. :::! ):~.. :u -< N SHERYL J. REED, v. CARLJ, ARRIGO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VA CIVIL ACTION - LAW NO. 03-1227 CIVIL TERM Defendant IN DIVORCE AFFlDA VIT OF CONSEN1: 1. An Am nded Complaint in Divorce under SS 3301(c) and (d) of the Divorce Code was filed on March 19, 2003 and served upon Defendant on Mar(:h 27, 2003. 2. The m . age of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the ate of filing and service of the Complaint. 3, t to the entry of a Final Decree of Divorce after service of Notice of Intention to Request E of the Decree. I verifY that the statements made in this Affidavit are true and correct. I understand that any false statements herein e made subject to the penalties of 18 Pa.C.S., S 4904, relating to unsworn falsification to authoriti s. Dated: 10 290114-1 c -~2h~ 0 G1 C , <:': '+:) r;;'\ \"- I .,.' -7 ",-- i "0 ..',,' / (/.1 -c. f: ,- .,-~." ~<- ,,,:, ) .. _'C) --;.~ C) of Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V SHERYL J. REED, v. CNIL ACTION - LAW NO. 03-1227 CNIL TERM CARL J. ARRIGO, Defendant IN DNORCE 1. I cons to the entry of a final decree of divorce without notice. R OF NOTICE OF INTENTION TO REQUEST A DIVORCE UNDER 3301 c OF THE DIVORCE CODE 2. tand that I may lose rights concerning alimony, division of property, lawyer's fees or expens s if! do not claim them before a divorce is granted. 3. I unde and that I will not be divorced until a divorce decree is entered by the Court and that a copy of the d cree will be sent to me immediately after it is filed with the Prothonotary. I verifY that th statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P'a.C,S, ~ 4904 relating to unsworn falsification to authoriti s, I Dated: s~~~"fJ/ 290114-1 o S 'f.;... -0:-." n'l\' ~,~T ~,~- ~"~ -'::...... ~-'-.( j;-' c: (..;~ ~ ..) ~; N ~. _..i ,,<: :..1'1 (:;) . FIFILESIDAT AFILE\GcneraIICun-ent\ 11J71.38pra I Cre~led 9;'2(){C\4 o ()GI'M Revised J.'14105427PM Jennifer 1. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERYL J. REED, v, NO, 03-1227 CIVIL ACTION - LAW CARL 1. ARRIGO, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of Metzger Wickersham Knauss & Erb on behalf of Plaintiff in the above matter. METZGER WICKERSHAM KNAUSS & ERB By: ~LQQ. Andrew C. Spears, Esquire LD,No, 3211 North Front Street P,O, Box 5300 Harrisburg, P A 17110 (717) 238-8187 Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Plaintiff in the above matter. i\ . Date: /'\ \ '" . (J'-, By Jennifer 1. pears, Esquire LD, No, 87445 Ten East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff . CERTIFICATE OF SERVICE I, Tricia D, Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Mr. Carl J. Arrigo 432 Trudy Road Harrisburg, P A ] 71 09 MARTSON DEARDORFF WILLIAMS & OTTO t~.[)IYy~ ricia D. Eckenroad / Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated: /llMdt /1;12fl8S ...----- - . F \FILI.OS\DATAF1LE\GenerarClIrrenn I J 37J38ret.u.e Created 9/20104 l106PM Revised 3/30/05 IU7AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO !.D. 87445 10 East High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHERYL J, REED, v, NO, 03-1227 CIVIL ACTION - LAW CARL J, ARRIGO, Defendant IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter hereby elects to retake and hereafter use her previous name of Sheryl J, Reed and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 2, 54 Pa, C.S,A. Section 704, Sheryl J, (Signature - arried name) ~~eoot+ SKeryl J. Ree (Signature - to' e known as) COMMONWEALTH OF PENNSYLVANIA ) :SS, COUNTY OF CUMBERLAND ) ;1~ ' 2005, efore a Notary Public, personally appeared 1M , known to me to be the person whose name is subscribed to the within ocument, and acknowledged that she executed the foregoing for the purpose therein contained, IN WITNESS WHEREOF, I have here s~t my hand and Notarial SeaL - I ;() /zja1..L< . .' - Notary Public G NOTARIAL SEAL VICTORIA l. OTTO, NOTARY PUBLIC CARLISLE BORO,. CUMBeRLAND COUNTY MY COMMISSION EXPIRES OEC. 2 2006 (') ......, 0 = ~; = .... \:h en 0 :~"" ,... =? -~,~ ','r, -...J [\;;i_! -0 m:r1 ~ ~ , :;0 ..,,In ~ I -nO Q:) c::>6 -, - ~ ..,--1-; --- -0 ?:j :D :..~ ......0 - --{::, c' ~S{n ~ <S"- ::; c' 't? ..--1 --.i ..-. "... 'IJ D :,! 0 ::0 ....l -c cr, ,< ...c. ~ ...+- 6 F\FJLES\DATAFILE\GeneraJ\Curren/\! 1371.38 con Created: 9120104 0:06PM Revised: 4/14/05 2:32PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D, 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff SHERYL J, REED, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 03-1227 CIVIL ACTION - LAW CARL J, ARRIGO, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301(c) of the Divorce Code was filed on March 19,2003. 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 ofnotice of intention to request entry ofthe 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. S 4904 relating to unsworn falsification to authorities, Date: tj !it; /J(JJS- I ( '(l_l() 'Y~0^, ,",P..p r /y/::-: 21 ".1 <'.?.?S C;. "':-h ;:-;":'. " ::;::t ;':;1 "'."" CJ'~ ,~ -- c,:::> ~ "I f'.1 Jennifer L. Spears, Esquire MARTS ON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA SHERYL J, REED, v, NO. 03-1227 CIVIL ACTION - LAW CARL], ARRIGO, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) AND ~ 3301 (d) OF THE DIVORCE CODE I. 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! 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 waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. 9 4904 relating to unsworn falsification to authon.'ties. 'i \. Date: tf J J"i Jp fJ; ) J-~iIS-~ t~ ~ ~ I / Sheryl], Re , Phi' 'ff (: """ f") ('-,I ;:-,1 -""',~ ,~ r',~ :;;;;. 1".,,) U\ ,'1-, F:\F1LES\DA T AFILE\Gen,:ral\Current\11371 ,J8,praecipe Created: 9120104 006PM Revised: 4125/05 3:37PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO 1.D, 87445 10 East High Street Carlisle, P A 1. 70 13 (717) 243-3341 I Attorneys for Plaintiff i I SHERYL J, REED, Plaintiff I , i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 03-1227 CIVIL ACTION - LAW CARL J. ARRIGO, Defendant IN DNORCE PRAECIPE TO TRANSMIT RECORD 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 the complaint: Via certified mail, restricted delivery, return receipt requested on March 27,2003, 3, Date of execution of the Plaintiffs affidavit of consent required by Section 3301 (c) of the Divorce Code; April 19, 2005; by the Defendant; April 4, 2005. 4. Related claims pending: All claims have been resolved, 5, Date Plaintiffs Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: April 25, 2005, Date Defendant's Waiver of Notice III S3301(c) Divorce was filed with the Prothonotary: April 7, 2005. MARTSON DEARDORFF WILLIAMS & OTTO April 25, 2005 By J e ifi r . Spears, Esquire Ten E st High Street Carlisle, P A 17013 (717) 243-3341 Attorneys for Plaintiff o S -Dli~ lT1r --;,1">' ~h?_ l-;'C <-- ~~~ :7 -'3 -, ,-.> = = <J' "'" -0 ::0 N cr> ~ ....; X-n rnp=:. -n !1'?' ~;J " (-)() -_~:1 ~'. ~ '"... -":1 f~,M .;:>> -:~~ ..." :x s:- .. ." " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " , , " " " " " " " " " " " " " " " " , " " " " " , " " , " " " " " , " , " , " , , , , , " , , , , ++ Of. +. '+ 'f. 'f. '+;+; ++ +.++ 'f++ +++++++++.++++++++++++++++++++++++++++++++++++++++++++++. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF SHERYL J. REED. Plaintiff VERSUS CARL J. ARRIGO, Defendant AND NOW, DECREED THAT AND PENNA. No. 03-1227 DECREE IN DIVORCE tl\1 ~ 3. ''If"l~ . ::> J~ __, IT IS ORDERED AND SHERYL J. REED , PLAINTIFF, CARL J. ARRIGO , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None. ", ~ .- - By Am'f~ _ ~ ~- PROTHONOTARY , .. ++++++:!' .. +. +.:+ ++ +. Of'" +. +. +. +iI"++ +. +. +. +++++++++++++++++++ " , " ++++++++++++++++++~ J +. +. +. T+ " " , " " " , " " " " " , , " , " " " " , " " , , , " " , " , " , , " , , , " " , " , " " , , " , , " , " " " " , " " " " " " , " , , " , " " , " " , " " " " " , , " " , " " , " " , " " " " " , " " ) -L-;? <;i!.. ~. -P14~-.!1/'7 c-" ;t?-'JC' . 1/ " /' '. . Fe? .c;Y /~ ~~ ~" P '2- I'p' .'., ~~ /'?J R7>_r oil >.' .. ... ~, "