The URL can be used to link to this page

Home My WebLink About01-1541 FX ."1." _ r."' ,~, 'k ~ ,'.'~'" , ;'-.-.!, u__ __" ,~_', .' po, ,~ .'_j,'-_, I~ ,j",--" .. . . '" "''''''' "'''''''''',., '" . . . . . . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY . . . . PENNA, STATE OF . . . Justen Reynolds . No. 01 1541 . . . VERSUS . . Tarnra Reynolds . . . DECREE IN . ~ DIVORCE . . 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 . . . '" '" '" '" . :4 t~ PROTHONOTARY J. . . . . . . . . . . . . . . . , ;,~ - " .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~_~I;~j~Nill:!l!;~~~~~J~r.;,,~;~iel;i~~1iiltii!l ~ Z~~Ifr1/ ~~ t ~~<p2rr~..~ " ,,^" ,,,~__e"',o_ _ .,,, ~ , ."_M~_ ".~'O"""_' .~.~_~"." ","___>_<,,,,,",~ ___,~,__. __~,~ _,.c . _ _-~,,.,..'_,__ _lj"-~ [V-w" c: g?' 0(" [' ~- ' . "-~ -,,;, , . ., -".~. ,,~- - ~"'" ~ ~ , -1\1-, - ~ - -, - ';-. C,' ~ ',_ r. , ,--"--,,,... -';'.'", -".> ",;-<," .'J __ ,:::"1~i~~1;.':;",,_,,-_ _~, JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- )6"'/ J CIVIL TERM : CIVIL ACTION - LAW : IN CUSTODY v. TAMRA REYNOLDS, Defendant QRDER OF COURT AND NOW, this day of , 2001, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , Esq., the Conciliator, at on the day of 2001, at .M., 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. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By: Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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 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, PA 17013 (717) 249-3166 II . '. . ~_h~- '". "_._i_' -L.,-'; C "',,1' - "0_"' ,.;;__~ic . ,.',.-., "-+'l.~,-,"_',i",:,,~ . -"> ~~ ~, '~4wi;{;" ",." JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 01- Ii5Y I CIVIL TERM v. TAMRA REYNOLDS, 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 prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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 child. 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 of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, PA 17013 (717) 249-3166 II ."~ . . , ..1', , '~'. . "~..~" --" .~,..:"",~;"~,,, __ ,'m., , , .., . _~'_ ;','. <)., .~.,.;,~, - .;;;:" ,",.,.,,', ,,,,",,,.,,,-- - ,".., JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- IS,,!, CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE v. TAMRA REYNOLDS, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Juston Reynolds, an adult individual, currently residing at 8555 Newington Forrest Court, Springfield, Fairfax County, Virginia. 2. Defendant is Tamra Reynolds, an adult individual, currently residing at 146 Virginia Avenue, Carlisle, Cumberland County, Pennsylvania. 3, Defendant is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on July 10, 1993 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have liX/ed separate and apart since November 8, 2000 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 1/ <, -:' w"-. "" ~ -'~", ".. ".,' ,,0 ., _.~,,-,,"',,;:;,'~',.!.,-' -''''~,-'-"C"',,. ~l~jii0.!;ii t 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the fi!ling of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce, COUNT II CUSTODY 12. The averments in paragraphs 1 through 11, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 13. Plaintiff seeks shared legal custody and partial physical custody of the following child: NAME PRESENT ADDRESS DATE OF BIRTH II' Brittanie Charlotte Reyonlds 146 Virginia Avenue Carlisle, PA 17013 September 8, 1992 1,1, .1' I lill. 14. The child is presently in the custody of Defendant who resides at 146 , Virginia Avenue, Carlisle, Cumberland County, Pennsylvania. Iii 15. Since the child's birth, the child has resided at the following addresses: I, Name Address Dates Tamra Reynolds 146 Virginia Avenue Carlisle, PA 17013 Present - November 8, 2000 Juston & Tamra Reynolds 146 Virginia Avenue Carlisle, PA 17013 November 8, 2000 January 1997 Juston & Tamra Reynolds Jacksonville, North Carolina January 1997 - January 1995 16. The relationship of the Plaintiff to the child is that of natural father. 17, The relationship of the Defendant to the child is that of natural mother. 18. The Plaintiff has not participated as a party or in any other capacity, in other litigation concerning the custody of the child in this or any other Court. 19. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth, II I' ~:: 0".-';-..", ,'"-,,y ,-",., _-,U(","",,-,;~, '<-.,,' lIIiJ:k~--:,',-A~t:. ~ 20. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. Not other persons are known to have or claim to have any right to custody or visitation of the child other than the parties to this action. 21. Primary physical custody of the child shall be in the mother subject to the following periods of partial custody with the father: a. Alternating weekends from Friday at 7:30 p.m. through Sunday at 6:00p.m. 22. Alternating holidays from 8:00p.m. on the evening before the holiday to 6:00p.m. on the holiday. The holidays shall be New Year's Day, Memorial Day, 4th of July, Labor Day and Thanksgiving Day, with the father having custody on Memorial Day, 2001. 23. The parties shall alternate the Christmas holiday. The father shall have custody of the child from 2:00p.m. Christmas Eve until 2:00p.m. Christmas Day in even numbered years and the mother shall have this period in odd numbered years. The mother shall have custody of the child from 2:00p.m. Christmas Day until 6:00p.m. December 26 in even numbered years and the father shall have this period in odd numbered years. WHEREFORE, Plaintiff requests your Honorable Court to refer the Custody portion of the Complaint to conciliation. Respectfully Submitted TURO LAW OFFICES 3/;OtJi Date zU~'/ Robert J. u derig, ESqUi~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II f~: ,. ., ^ '" , -"~ ~__ ," ,__' ~__H~ ,_" _ ".__ ' <. ....,'., """""1 ~', I VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true'<lnd .'.--:; correct. I understand that false statements herein made are subject to the penalti~s;6t b; Pa.C.S. 94904 relating to unsworn falsification to authorities.;~; l~ ~\.... -;200 I Date ~-'::4 J ton yn tls II '^__. i "' ~'~l~Hbiie.~~~I;i.~j,Wlihlj~~!~~~ft-.i>it."-@&..,;;..~.".m,j,;t>J!.:',:ii<lL;;d!a~~~.~'i'~i . ~'~'Mi"'t'~'" '",",,,,,", ~~;"'~""""'';''';~'.!I;_ b.T lIij!llr'I'$i' _'" r - ._<~ - , () C) c n "'" - -'fi l'''' ..... InS; i: ~,...! 2'" ~f ;::0 ;\2 - O'l 1'1'1 i::j ~'c::] "<:, :l:"r. '" ".,( <.,J' -,- :i?:rt '-0 - ,') n ,):>c ~ ><"5 < om =< N j;! (J;> ::n -<:: ~ ~ b<1 ~ II '" " " "- v... t' ~ '- "'I It; -..J ~ "'- ~ ':'\ r~ 0 C' & ~ f tJ "- .\.; r 0 tv "<:l ~ ..0 '" I., 00 ".', ~, -,~" , ~, -" ,~, ~,' .., , ~ ,-, ,. ,~'~ . -. .1 .'C'. '-. r,~1 . I mSTON REYNOLDS PLAINTIFF V. TAMRA REYNOLDS DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-1541 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Friday, March 23, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Huhert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud County Courthouse, Carlisle on Thursday, April 26, 2001 at 8:30 a.m. 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 defme 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. FOR THE COURT, By: Isl Hubert X. Gilroy, Esq.f;I; 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 infonnation 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 !~S:llf~!ifu1~~!kj,,;'~{'''~''''~':N,,,'~d;*~~~i=''');-'ll,,*j}jIlOC"",,Gt:ri'''U;'''';'f...;iLJq",0.i,k&;,~ln<iilFj..Jl~..lhl!li~~' ' ~'"~l!l~iIi!1l!lld~''~-''' . ~ ~L ~ ~~/ /c1-frE' t"/"r ~ ~ ~~ /17 fC'- [' ~ -r $ ~-~Z7U/ 4J . p? JrPt?)e.[' 'rV~~\I,~lASNN3,-1 )J~l] ;U~l,,_ 0J'I:;.r,t,!-';:;'I"n .' ._, ~~._" ,.,' 0 ., ",' ;,,:f!'''h I' iJU:71-'_' c.,d q /1 D't-~11 t ,.... _'v l...lii"1 IU % tR 'j.;\-fl( /\..11..:,..._ .'-:D "~ ,'~~" ~ v. "". ~ - - , ~. . '0' " ,,'~O~,~ -oa -~'-""'- --,. , 11 il II II I' II " d II " !I II :i II II ~ ... -~ , --~. , '---' ;---- "-'d-'-- .'"-,, -_, .c'_' ':-,-'.M>'O';,; ,~,-;--_;_' -,-.:."X~) JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. 01- l.S'L/! CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE v. TAMRA REYNOLDS, Defendant I HEREBY CERTIFY THAT I served a true and correct copy of the Divorce Complaint filed in the above captioned case upon Tamra Reynolds, by certified mail, return receipt requested on March 26, 2001 addressed to: Tamra Reynolds 146 Virginia Avenue Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated April 3, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C,S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES tjJ~/o1 Date obert J ulderig, EsqUire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II 'j! - > ... ,~ .0;_ --~' hlVDttt WfYlt9LAIDT Z 452 476 220 us Postal SelVice Receipt for Certified Mail No Insurance Coverage Provided. Do not use' for International Mail See reverse Senl10 Cel1ffied Fee; Special Der~ry Fee Restricted De~very Fee :ll CD Relurn Recei 't Showing to T"'" Whom & Date; Delivered .~ RelumReceipt 'ngtoWhom, <t Date, & Address's Address ei i TOTAL Posta,e & Fees C'? Postmark or D' e E 11l-164t'4t 2JJ, ZOO ( ;J.,r75 l.aD $LPJ7 D - -.- - -~~-~----- --- ~. .. ." U; D Complete items 1 and/or 2 for additional servic:es. G) Complete Ilams.,3; 4a, and 4b. f CJ Printyour'name--and address on the reverse oUhis form so that WE! can return this ~ C8!'dtoyou.. ' 1. f lJ Atta_ch this form to the front of the mailpiece, or on the back if space does not QI permit. ., , = oWrite "RetumReceipt Requested" on the mailpiece ~19Wjtne article number. c CThl! f:lel,u~_ Receipt will show to Whom the ~rtjcle ~~~$ted;;Eif1(Hhe date o delrverwl.. ..{l'..,_" '.';, ,',' "Cl 3. Artibr~'Cllltfessed to: ':'~ 4a. Article Number f TAllul ~f4tJOLM '4b.;';1V1~; kIlo 8 I~~ VI \t~ I iIJ I V1 A-US D Registered . 0 Express Mail ~~( Pr+- NO,~ Return Receipt for Merchandise I_ta_thefollow- ing services (for an extra fee): s Restrict~t;t Delivery ~o .JfJ;ertified D insured DCOD 8. Addressee's Address (Only if requested and fee is paid) 1; j; '''ji!I(:~.. II " ,~- :-~;:'::.~~; ..'J,j- ,J,-: "', cD " 'i: <l. ';; u 8! c 5 ... a: '" c 'iij " ~ .l! " o ... " c .. .c .. '_WA...'...'''''.,''''r_l_m.il.....'' ",' ijjjliPiiGiiii!iiiiii''''''l]jl~'';~i'ii;~~''''''''"ii",ii 'i ~ i ,.C-,.HY".f,'t,."."',-,"1<_,,.~. ~ .~. ~,,' ','" ^"',-,_"_'e_ ,_. ,"_m."_" _~, ,~,_ ~-' .,.< ,~,""",,~" , ~. ~ -~~~ ;~!Jlt\lijj!.'J!liliJ -~- j~ -,~"-" CJ 0 C) C -, I ~ ~ ~.~-" ~'1 -0 Cr:.' -::l n1 fl"" .j,.> '7 ;~'." ,-,'J I L:'" , :1 en 0" -, c; ~,: r::: :~7.>~ 2 ...~ (- -';-,. C) f:-:. C ~-'-. ::~) rr' .;;' C ...~.' 2: '-) i2 :;2 :n 0) -< ;: ~, - ~. - ~ ... . ., ",' ~-" , ~' .'-' '-l;',,,-,: ".' .~_,' "-'~''''''~ MAY 0 1 20atfJ . mSTON REYNOLDS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TAMRA REYNOLDS, Defendant NO. 01 - 1541 CIVIL IN CUSTODY COURT ORDER AND NOW, this 'Z~ day of A~ 2001, upon consideration of the Conciliation Report, it is ordered and directed as follows: attached Custody 1. The Mother, Tarnra Reynolds, and the Father, Juston Reynolds, shll anjoy shared legal custody ofBrittanie C, Reynolds, born September 8,1992. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Friday at 7:30 p.m. until Sunday at 6:00 p.m. The first eight (8) times the Father sees the child shall be at either the Father's parents home or the Father's sisters home, Additionally, for the first two weekends, Father's roommates shall not have any contact with the child. The next two weekends, the roommates may have contact of 2 hours. The following two weekends, the roommates may have contact of 3 hours, and the next two weekends, the roommates may have contact for 4 hours. Thereafter, the Father may exercise the alternating weekend schedule at a location that Father deems appropriate and the restrictions with respect to the contact by the roommates is also removed. B. Father shall also enjoy periods of temporary custody at such other times as agreed upon by the parties, 4, The parties shall alternate custody on holidays to include New Year's Day, Memorial Day, July 4th, Labor Day and Thanksgiving. The time shall be from 8:00 p.m. on the evening before' the holiday until 6:00 p.m. on the holiday. This alternating schedule shall commence with Father exercising custody on Memorial Day 2001. .,. -~_- "-_" '--'-~--~''''iIiI''''''''- ~-- ..- -...---. -J~_"..;_. ---illJ~i~af\I~~'"''l'" c- -'....1' -., ~ ,.. iiIi \!IN\I^lASNN3d AINftlfj" n' \r1Ll:Jq"'n" ; i\./\) '. _1\_' ""j"J~,,~~ \"J 9Z:8 !IV [- A~H /0 AH\flO:\K::':';JU~i._; .:0 :J::ji.:L:O--C:,j "J;:I Iiill'~ - ,-, " ~ . . . ~~ . , -'- "','~- ,,'0.- "'~>_ ."',~, _, ,n_ ,,_'. "r"'c_'~, "'--'o'A'~~' -";"_""'_'," "~,-":-_"_"-,~""~_,V.,,,,,,,",_.,, ".,_'~ ">;,j 5. For the Christmas holiday, th4 Mother shall always have custody on Christmas Eve and on Christmas Day until 2:00 p.m, The Father shall have custody every Christmas Day from 2:00 p.ml until December 26th at 6:00 p.m. 6. Both parties shall be sensitiv, to their child's desires with respect to exercising of custody, . 7, Father shall cooperate in co~seling sessions for the minor child that may be scheduled. 8, The parties may alter the above custody schedule as they agree. Absent an agreement, this order shall cohtrol. In the event either party desires to modify this custody order, that party ma)t petition the court to have the case again scheduled with the Conciliator for a conffrence, BY THE COURT, 4L J. cc: Robert J. Mulderig, Esquire Carol J. Lindsay, Esquire ~ * v_ ^ ~.__ ~ _" ,'.' ._~_ 0'" _ ",' , . , ~ , -. ,"" .-". , - '",., "'___"""'_ "__.~; _r.= "'_~ _~.".' _~_. "__~"~__,",_,__"'_ .', . " JUSTON REYNOLDS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TAMRA REYNOLDS, Defendant NO. 01 - 1541 CIVIL IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: I. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Brittanie C. Reynolds, born September 8, 1992. 2. A Conciliation Conference was held on April 26, 2001, with the following individuals in attendance: The Father, Juston Reynolds, with his counsel, Robert J. Mulderig, Esquire; and the Mother, Tamra Reynolds, with her counsel, Carol J. Lindsay, Esquire. 3. The parties agree to the entry of an order in the form as attached. t{l1~(Crl DAT .' ,,,',,=~ ,,;, .J', "'~ -,~-, ,,"-~ ,,, '-,"; ,', ,.-".",' ,,_,~ ,'";_,'l ' ri'_ -"'\i r JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1541 CIVIL TERM TAMRA REYNOLDS, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on March 16,2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 7M-cE, Date ~p JUS ON EY D13 ~_'(r-"'~'~._tM~:lifildl~~~IID~J(i,afJl04~,"~_,@iI~~ti 'i.l-- ,., <' . ~''. """," "" ~lillillb.1 ~,~ '.' (") ~. -(lIT1 mLi-' ~--' :;:-:::: L l~. <:~ ,:..,,> -< 1 ~~~ -r;:" >.J --,-' r......::' . -, ," C) 1~ -'....,: :D =< '" w :::> ...J ~-",-- ,-, ,_ '-".'_;n__ "," '-"_v..-'n"_ _"~'b.,;" !~,,-.~o>':. ...." - ,~' i-, _' ~.i,O_' .,__~~,:( JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 01-1541 CIVIL TERM TAMRA REYNOLDS, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER Of INTENTION TO REQueST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 ~ 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. <C~C8 Date ~& Jll. . ON R." NOCbs I II ~~I~nlfi.;'~";-' ''''Wtdd~'~'wiil1nt~'i'1i:j~iiMj!9ii!;i!.si~-jJH~~i:I.1li~~iill!lid;;' '.... . o'~Q"' "^. ~ . .~... "......,.-,~..- '.,- -'-'~ ,-, ..... , .1:~> i . ,,, 0 c; () C 0;' "~1 '; ~"", -0 (:' nln: z::r! 7":C. (j),': 1'-) ~~; -'0 :~',~ , .. pLI W :~ C --', ...-::, ::::> ~D -., -< '....! -< 00 -... - . - ",' < c- -,_~-'" '-"', _ ' JUSTON REYNOLDS, Plaintiff v. TAMRA REYNOLDS, Defendant .',,- _,"-,"'.-;---' ,-, ,,;'-' 'j' ,,' ..,'-::';_:',/-,~~--:;, "--'''-'...' "_ _'Ct- - '7 ' -~llti;i' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-1541 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on March 16, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. 1- r- 0> Date ~ ~ilt<lr:tir'~ ~_L~ ';~:~~~~"Awo';"~F"rNh-:kii:~~1?"kli4i,~~f.-- ~ ~ ~~ ~ ... ". ,S' "' )('J.- '~ + - -'lIIlAi '" -. . . .." ".~, " '", (") C. -of~ rJLr; :?.::L C/' ,_: 0<.:, ~c:' ~~; :Pc 7: :;;l ~ c::::. c..) .-"":',!: ,::" ,~~} ;;jl -'j ~~<.' ~t:.j '-^' :::> ....J ill T_O ~, , ~.. . . . 'W' ~ -..--. '"ii.''' "'~""';'.""""';"'_. _ I~, JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1541 CIVIL TERM TAMRA REYNOLDS, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301 ~ 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S, 34904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~~t-b7 Date I; II :I11r':"'iIllOOlmIW - <. .!lij~-tW~~:'-"",",",--t."'j!.~i*1!t~~,;;i.),b~,~~ -'~ -".-, -_~""'~ ""'"~ -,~_"v _""~ ,~ .""",'l 'C_.'..,", _~> _q_,,~. ..._"'" ,_~,,~ ~",,~. "",--"~ >&.-~';~~"< - .", illdB ....- o r- ;;!'- -0[:;;" n'lr-:-: ~[ ~:~~'; r::c:. Zj- ~(j Pc':: 3 -:; I c; (",,:, <;:2 ::u p".;~ ~D w '- _--~; S-2 ~:)' 'I --i ~G -< :::> -.J 1-% . . ~~ .- , '> " __". H_"'."" , ,,-,,""."- - '--' ""._,~, ;",,, -,'. --'"',,.." ", """"--.'~ .-,~- ",~~- '== "'., - , ";" SEP 1 ~ ZOOl pi} JUSTON REYNOLDS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW TAMRA REYNOLDS, Defendant NO. 01 - 1541 CIVIL IN CUSTODY COURT ORDER ~- ;1 I I ;~ '1 i :~ I 'I "1 , Y7 ' AND NOW, this (g day of September, 2001, the conciliator being advised the parties have reached an agreement, the conciliator relinquishes jurisdiction. BY THE COURT, Hubert X. Gilroy, squire Custody Concil' tor ;i i (1 ~~;m'~ 'MtWlRi.ii.r --J :] _ .~ ~~~i$i~~i~" ',,",'-'~"" "-"""'+Y""-.'~~ ~~- ,,~~," ,~'"-"' ,= "-.' . ,^, ,""""".^ I 0 c. S::2 c ~. :':-0" en -\3 Ci,-, :'1 ITl p; --0 ;;?: :C! 7" r- ;--..,) (r) -1':" U'; -< '~':,.. , r" C. -- :~ -~ .> C:.' . " 0 :z );8 N c:) ,'Tl z :.0 54 =< ::r:J CO -< - H - ,.,_~ ,_. ~,- -, h '_"'''r._ -, ". .0_ ".~__~ ~" JUSTON REYNOLDS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-1541 : CIVIL ACTION - LAW : IN DIVORCE CIVIL TERM TAMRA REYNOLDS, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under ~3301 (c) ~3301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail on March 16, 2001. 3. Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code, 4, By Plaintiff: March 8, 2003 Date the Waiver of Notice in By Defendant: March 7, 2003 ~3301 (c) divorce was filed with the Prothonotary: By Plaintiff: March 12, 2003 By Defendant: March 12,2003 ;if!~~ire Turo Law Offices 28 S. Pitt St. Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff II ~~~Ii'~MWr~,*~IW",i:""h"'U':t,'MfIi~H.>;i'lE..hMjJ~I!1i'li 1?~ <_",_j] ...,~ - '-~-""'~ - .=- --" " ~-tI'i" "~, -? .-~ -'";--''' 1 (") C) ~;~ C c.) ?::: '"D G:'"', m eT -:;:- .~ Z en r".') -< '< ;_i :.r, t:..'" _. 2>-: i::,j~~ ;J,; u eN c: -.-) ...-::::' :::> ."'.~,. -, II ...< .-1 -< t' i;j