HomeMy WebLinkAbout03-3352IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
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NO. 2003- 3.¢..e'~.,, CWIL TERM
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 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 marriage, you may
request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary,
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013.
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, PA 17013
Telephone: (717) 240-6200
AMERICANS WITH DISABILITIES ACT OF 1990
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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
NO. 2003-~.~_ CIVIL TERM
CWIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Thomas J. Flyun, by and through his counsel, Howett, Kissinger
& Conley, P.C., who states the following in support of the within Complaint:
1. Plaintiff is Thomas J. Flynn, an adult individual who currently resides at 1833
Red Spruce Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. Defendant is Dyan Regan/Flynn, an adult individual who currently resides at
1833 Red Spruce Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
3. Both the Plaintiff and the Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for a period of at least six (6) months immediately preceding the filing
of this Complaint.
4. Plaintiff and Defendant were married on March 17, 2000 in Camp Hill,
Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States of its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
6. There have been no prior actions for divorce or annulment of the marriage
instituted by either of the parties in this or any other jurisdiction.
7. 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.
8. The marriage of the parties is irretrievably broken.
9. The parties have lived separate and apart since in or about June 11, 2003.
10. Plaintiff requests the court to enter a decree of divorce.
Date:
Respectfully submitted,
~~C. Howett,~e
'I~IOWETT, KISSINGER & CONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Thomas J. Flynn
VERIFICATION
I, Thomas J. Flyrm, hereby swear and affirm that the facts comained in the foregoing
Complaint in Divorce are tree and correct to the best of my knowledge, information and belief and are
made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities.
Date:
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN/A
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
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NO. 2003-3352 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, LeRoy Smigel, Esquire, hereby accept service of the Complaim in Divorce on behalf of
Defendant Dyan RegariFlynn and certify that I am authorized to do so.
Date: -"/, I Ga .~ ~ ~'~ LeRoy~~/~~~re~'
SMIGEL, ANDERSON & SACKS, LLP.
River Chase Office Center
4431 North Front Street
Harrisburg, PA 17110
Telephone: (717) 234-2401
Counsel for Defendant Dyan Regan/~lynn
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
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NO. 2003-3352 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Leo F. Luciano, being duly sworn according to law, depose and say that I am a
competent adult; that I served a photocopy of the January 20, 2004 letter to Chadwick O. Bogar,
Esquire and the enclosures referenced therein on James Paul Helvy, Esquire on the ~ C day
of January, 2004.
Leo F. Luciano
SWORN to and subscribed before me
this c:~?(day of January, 2004.
~ X~iary Public
NOTARIAl. SEAL
Dt'BRA M. SHIMP, NOTARY PUI]LI(~
CITY OF HARRISBURG, DAUPHIN COUNTY
MY COMMISSION EXPIRES AUG. 20~ 2005
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COLTNTY, PENNSYLVANIA
THOMAS J. FLYNN, )
Plaintiff )
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v. )
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DYAN REGAN/FLYNN, )
Defendant )
NO. 2003-3352 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Leo F. Luciano, being duly sworn according to law, depose and say that I am a
competent adult; that I served a tree and correct copy of the January 20, 2004 letter and the
enclosures referenced therein on Chadwick O. Bogar, Esquire on the ~ day of January,
2004.
Leo F. Luciano
SWORN to and subscribed before me
, /
this &~ ~day of January, 2004.
~ot~ Public ( ~
NOTARIAl SEAL
DEBRA M. SHIMP, NOTARY PUBLIC
CITY 0E HARRISBURG, DAUPHIN COUI~TY
MY COMMISSION EXPIRES AUG, 29, 2000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
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)
)
)
)
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)
NO. 2003-3352 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Leo F. Luciano, being duly sworn according to law, depose and say that I am a
competent adult; that I served a tree and correct copy of the Intent to Separate letter on Dyan
Regan/Flynn on the ~ c~ day of January, 2004.
Leo F. Luciano
SWORN to and subscribed before me
this ~ ~ayofJanuary, 2004.
Q_ ~) Notary Public ( ' 'xN
NOTARIAL SEA~
D[BRA M. SHIMP, NOTARY PUBLIC
CITY OF HARRISBURG, DAUPHIN COUNTY
MY COMMISSION EXPIRES AUG. 29, 2005
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
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NO. 2003-3352 CWIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO WITHDRAW COMPLAINT IN DIVORCE
TO THE PROTHONOTARY:
Please withdraw Plaintiffs Complaint in Divorce filed with this court on July 14, 2003.
Respectfully submitted,
Date: c~-/V~/~q
HOWETT, KISSINGER &~EY,
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff! Thomas J. Flynn
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
THOMAS J. FLYNN,
Plaintiff
DYAN REGAN/FLYNN,
Defendant
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NO. 2003-3352 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, John C. Howett, Jr., Esquire, counsel for Thomas J. Flynn, Plaintiff in the above-
captioned action, hereby certify that a true and correct copy of the Praecipe to Withdraw
Complaint in Divorce, filed on March 17, 2004, was served upon J. Paul Helvy, Esquire, counsel
for Defendant Dyan Regan/Flyrm, by hand-delivery on March 17, 2004, to the following address:
James Paul Helvy, Esquire
KILLIAN & GEPHART
218 Pine Street
Hamsburg, PA 17101
.~-'~i (~4t~ Estl ire ~
/John~. Howett, ~r.,~
i-i~WETT, KISSINGER ~Z-CfONLEY, P.C.
130 Walnut Street
P.O. Box 810
Harrisburg, PA 17108
Telephone: (717) 234-2616
Counsel for Plaintiff Thomas J. Flynn