The URL can be used to link to this page

Home My WebLink About07-4669,. > LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor@pjrlaw.com A. MICHELE REEKIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW GENTRY K. WEISS, NO. 2007 -~1~~~ CIVIL TERM Defendant 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 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 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 3800 Market Street Camp Hill, PA 17011 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor a~pjrlaw.com A. MICHELE REEKIE, Plaintiff v. GENTRY K. WEISS, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007 - ~jl,~~ CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE AND NOW COMES the above-named Plaintiff by and through her attorneys, the Law Ofi'ices of Peter J. Russo, P.C. and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is A. Michele Reekie, an adult individual who has resided at 1340 Hunter Drive, Lancaster, Lancaster County, Pennsylvania, 17601 since June of 2006. 2. Defendant is Gentry K. Weiss, an adult individual who has resided at 1340 Hunter Drive, Lancaster, Lancaster County, Pennsylvania 17601, since June of 2006. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 20, 2006, in Las Vegas, Nevada. 5. Plaintiff and Defendant separated on August 2, 2007. 6. Neither the Plaintiff nor the Defendant are in the United States Army. 7. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 8. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the court require the parties to participate in counseling, but does not request the same. COUNT I --DIVORCE 9. The prior paragraphs of this Complaint are incorporated by reference as though fully set forth herein. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II -EQUITABLE DISTRIBUTION 14. The prior paragraphs of this Complaint are incorporated by reference as though fully set forth herein. 15. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502 (a) of the Divorce Code. 16. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing this Complaint. 17. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties without regard to marital misconduct in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: The Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. LAW OFFICES OF PETER J. RUSSO, P.~. Attorneys for Plaintiff Peter J. Russo, Esquire I D # 72897 Scott A. Stein, Esquire I D # 81738 `Elizabeth J. Saylor, Esquire I D # 200139 Date: ~ 6 ~~ . ~_ VERIFICATION I, A. Michele Reekie, 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. §4904 relating to unsworn falsification to authorities. Date: ~ Z- ~~ 7 ~' C~ W o~ c~ o Cy. ~-y~t ~ i'; ~ i-il fTl - ~ ,.. ~ ~ I. ~ ~- -~ ~ T a ~~i ~ ~~~ ~. ~ r-- - ~, ~:. {V :~ ~.: -.~ Law Offices of Peter J. Russo, P.C. By: Elizabeth J. Saylor, Esquire Attorney I.D. No. 200139 3800 Market Street Camp Hill, PA 17013 (717)591-1755 (717) 591-1756 Facsimile Isaylor@PJriaw.com A. MICHELE REEKIE, IN THE COURT OF CO~YICNt PLEAS ~ Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION -LAW GENTRY K. WEISS, NO. 2007- 4669 CML TERM Defendant IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the above complaint originally filed on August 7, 2007. Law Offices of Peter J. Russo, Peter J. Russo, Esquire ~..-D. No. 72897 ~,~Elizabeth J. Saylor, Esquire I.D. No. 200139 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 (717) 591-1756 Date: ~/-~~ ~ ~ t~~ ;~ ~~~ ~ ?f ` 5 F ~ ~ ~ zT A. MICHELE REEKIE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW GENTRY K. WEISS, NO. 2007 -4669 CIVIL TERM Deie~ndant IN DIVORCE AFFIDAVIT OF SERVICE I, Ashley R. Sipe, being duly sworn according to law, that i am over 18 years of age and not a party to the above-captioned action, served and made known to on the 14th day of November, 2007 at 3:50 p.m. at Lancaster County Courthouse, 50 N. Duke Street, 3'~ Floor, Lancaster, Pennsylvania a Reinstated Divorce Complaint and Praceipe to Reinstate Complaint issued in the above entitled case in the manner described below: [ X ] Personally delivered into the hands of the person to be served [ ] Adult family member with whom that person resides. Relationship is [ ] Agent or person in charge of person's office or usual place of business [ ] Other. Description of Recipient Seat: Male Skin Color: White Hair Color: Brown Facial Hair: Beard Height {approx.): 5'8" Weight (approx.): 250 Age: 41 Title Badge/ID # (if any) C'~ C~ ~.~ R. ~~ ~~.~ _ -+ ~ -Y- `~ ~ -~ ~€ C : .~ 3 i