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HomeMy WebLinkAbout07-4914i 6 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff V. : CIVIL ACTION - LAW DANIEL LEE REISMAN : NO. C)7- 4q 1q 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 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, Cumberland County Court House, 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 Lawyers Referral Services Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 i IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff v. DANIEL LEE REISMAN Defendant CIVIL ACTION - LAW NO. 07 . V9 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is Danielle Lee Reisman, who currently resides at 5 Glen Field Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Daniel Lee Reisman, who currently resides at 58 Sinclair Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on July 23, 1994 at Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. L 6. Neither plaintiff nor defendant is in the Armed Forces of the United States or any of its allies. 7. The marriage is irretrievably broken. 8. Plaintiff has 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. WHEREFORE, Plaintiff, Danielle Lee Reisman, prays that a decree in divorce be entered dissolving the marriage between the two parties. Respectfully Submitted, m. C. Felker, Esquire Plaintiff ID # 67999 P.O. Box 1401 Camp Hill, PA 17001 717-512-0647 !] I verify that the statements made in this Complaint 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: cl I I 1 0 Q d?L ? Danielle Lee Reisman n N 771 ' J 01 T Y (a? ?lii IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff V. : CIVIL ACTION - LAW DANIEL LEE REISMAN NO. 07-4914 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AND NOW THIS 16th day of January 2008, I William Felker, Esquire, attorney for plaintiff, hereby certify that I have served a true and correct copy of the Complaint filed in the above-captioned matter along with a Notice to Defend and Claim Rights upon the defendant, Daniel Reisman, by certified, return receipt, restricted delivery United States first class mail, to the following address: Daniel Lee Reisman 58 Sinclair Road Mechanicsburg PA 17055 The signed receipt is hereto attached. rr m. C. Felker Attorney for Plaintiff 67999 P.O. Box 1401 Camp Hill, Pennsylvania 17001 717-512-0647 ftm 411 PMi s P* ft yow`r so wo ¦ Aftch 1U 1. NOW PURUWMM- 2. Ads NXMw (T!wm* hom son** Ps Forn 3811, Fab wy 2W I%ryy ". ` rl .a 1?p _. Q 44 1020642-W, IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff v DANIEL LEE REISMAN Defendant CIVIL ACTION - LAW :NO. 07-4914 CIVIL TERM : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER rz;?, MI -II PQ cn -< Danielle Reismam, plaintiff, moves the court to appoint a master with respect to the following claim: Divorce: 1. Discovery is complete as to the claims for which the appointment of a master is requested. 2. Defendant has appeared in the action by his attorney, Jeffrey M. Cook, Esquire. 3. The statutory grounds for divorce are 3301(c) and 3301(d) of the Divorce Code. 4 (a). An agreement has been reached with respect to the following claims: Distribution of Property. (b). The action is contested with respect to the following claims: Divorce. Defendant refuses to consent to divorce absent an agreement not to seek child support. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 2 hours. Date V '?'A"Aa to Respectfully Submitted, ' ?'G Wm. C. Felker, Esquire Attorney for Plaintiff P.O. Box 1401 Camp Hill, PA 17001 717-512-0647 AND NOW ORDER APPOINTING MASTER 2010, master with respect to the following claims: By the Court: Esquire is appointed J. APR 2 ,3 2010 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff V. DANIEL LEE REISMAN Defendant : CIVIL ACTION - LAW :NO. 07-4914 CIVIL TERM : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER o c j- r-= ,, _ y L 4Ln v Danielle Reismam, plaintiff, moves the court to appoint a master with respect to the following claim: Divorce: 1. Discovery is complete as to the claims for which the appointment of a master is requested. 2. Defendant has appeared in the action by his attorney, Jeffrey M. Cook, Esquire. 3. The statutory grounds for divorce are 3301(c) and 3301(d) of the Divorce Code. 4 (a). An agreement has been reached with respect to the following claims: Distribution of Property. (b). The action is contested with respect to the following claims: Divorce. Defendant refuses to consent to divorce absent an agreement not to seek child support. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 2 hours. Respectfully Submitted, Date zz-&X Wm. C. Felker, Esquire Attorney for Plaintiff P.O. Box 1401 Camp Hill, PA 17001 717-512-0647 ORDER APPOINTING MASTER AND NOW, A3,2010, Gam. - , Esquire is appointed master with respect to the following claims: ?[! Nt1b Win; 90 :8 9Z 84V 0101 By the Cour 7? J. A171 1kEe, Y/??- j `a J . ?? ?"? IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff V. DANIEL LEE REISMAN Defendant CIVIL ACTION - LAW :NO. 07-4914 : IN DIVORCE CIVIL TERM NOTICE I - 4 S 5;F w w -c IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties of this action separated in September 2005 and have continued separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do no claim them before a divorce is granted. 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. e Date: C'- 3 - ?y Danielle Lee Reisman ti IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff V. : CIVIL ACTION - LAW DANIEL LEE REISMAN :NO. 07-4914 CIVIL TERM Defendant : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on the date set forth below a true and correct copy of the foregoing Affidavit Under Section 3301(d) of the Divorce Code, Counter-Affidavit Under Section 3301(d) of the Divorce Code and Notice of Intention to Request Entry of Divorce Decree, was served upon the party listed below via first class, United States mail, postage prepaid. Jeffery M. Cook Attorney at Law 234 Baltimore Street Gettysburg, PA 17325 May 12, 2010 William C. Felker, Esquire 67999 PO Box 1401 Camp Hill PA 17001-1401 717-512-0647 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN Plaintiff V. DANIEL LEE REISMAN Defendant CIVIL ACTION - LAW :NO. 07-4914 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DI UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without Notice. 0 ? c 4 w 2. I understand that I may lose my 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 true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. Date: 5 'jQ Danielle Lee Reism IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, ~, r..a o , PENNSYLVANIA ~ ~' v ~'+ _~ ___, -,- ~~~ DANIELLE LEE REISMAN ~= 'W ~~` ~ ~° ;,: ~;-.~ Plaintiff ,. _-:: as . , - _ , ~ ,. ~. v. :CIVIL ACTION -LAW - W: " _ -- . "'~ C ~ -,'7. DANIEL LEE REISMAN '6 NO. 07-4914 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 17, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a Final Decree of Divorce without Notice. 2. I understand that I may lose my 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 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. Date: O '"' ~ r~y Danielle Lee Reisman IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DANIELf,E LEE REISMAN ~ ^' r~ `~ ~-, o _:~ _ ~ ~, Plaintiff ~ - ~'~--~ v. :CIVIL ACTION -LAW - ~~ ~ +` ~ • ~ ~e' DANIEL LEE REISMAN ~' NO. 07-4914 CIVIL TERM Defendant : IN DIVORCE =~ c~~ ~ ~-~: ,. ~ . AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 17, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE I consent to the entry of a Final Decree of Divorce without Notice. 2. I understand that I may lose my 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 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. ~ Date: ~ _ ~ Daniel Lee Reisman DANIELLE LEE REISMAN, Plaintiff Vs. DANIEL LEE REISMAN, Defendant AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 4914 CIVIL IN DIVORCE ORDER OF COURT day of J~ , 2010, both parties having signed affidavits of consent so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code, and no economic claims having been raised in the action, the appointment of the Master is vacated. BY THE COURT, cc: ~Wm. C. Felker Attorney for Plaintiff ~ Jeffrey M. Cook Attorney for Defendant Copies m~:le~ 10/7/~~ ~LG . /~ Kevi A. Hess, P.J. ~-> ~..~ ,~ ..~, r~;r' :;~ ---•a ~^ ~ a R~~ ~a ~~ .~~ ` Q :~ ,~ e.~:~ _~ r° ~~ ~:-~ .. r° ~~ k:.,i ~ ~^'ti ~? 'B ~~ ~"'~ ~+ .,.f. DRYDEN 10/0612010 14:14 7177304077 William C relker, >rsquire P.O. Bax 1401 Camp Hill, Pennsylvania 1.7001-1401 717-512-0647 October G, 2010 Re: Danielle 1.ee Reisman v. Daniel Lce Reisman Court of Common Pleas, Cumberland County 0?-4914 VIA FACSIMTI.E 7~?-Sao-?s9o E. Robert Flicker, II Office of the Divorce Master 9 Narth Hanover Street Carlisle PA 1?013 Dear M.r.. Flicker: Pac~E Ol i Ol The parties i.n. the above referemccd matter have resolved their di..ffcrences. The only puxpose dais case was before you was hrxause husband refused to sign the consent. No economic claims have been made. Husband signed the consent on August 2, 2010 and Wifc signed the consent an ~0.ugust 3, 201.0. Both consents were filed with the court om Auga.st G, ZO1 Q. Therefore, 1 respectfully request that your appearance be vacated. I have spoken with, 1cfl'ery M. Cook, counsel for husband, (334-8516) and he has na objections. Respectfully submitt ~ d, r 114-m. C. Felker - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DANIELLE LEE REISMAN V. : DANIEL LEE REISMAN DIVORCE DECREE AND NOW, a, -73 X 01 J , it is ordered and decreed that DANIELLE LEE REISMAN , plaintiff, and DANIEL LEE REISMAN , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, NO. 07-4914 Attest: J. (JI-1 F F J.A Prothonotary 41 XtN "4 0