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HomeMy WebLinkAbout03-6546MAURA L. REITZ, Plaintiff V. ADAM L. REITZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03- 65'Y?> CIVIL TERM 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, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 '' Telephone: 717-249-3166 ? ?s//c- ?i? Way F. Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street WAYNE F. SHADE Carlisle, Pennsylvania 17013 Attorney at Law 53 West Pomfret Street Telephone: 717-243-0220 Carlisle, Pennsylvania 17013 Attorney for Plaintiff MAURA L. REITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. :NO. 03- (0 5 4 C. CIVIL TERM ADAM L. REITZ, Defendant : IN DIVORCE COMPLAINT COUNTI DIVORCE 1. Plaintiff in this Action in Divorce is MAURA L. REITZ, an adult individual who resides at 1253 Rebert Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is ADAM L. REITZ, an adult individual and citizen of the United States of America who resides at 1253 Rebert Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. WAYNE F. SHADE Plaintiff and Defendant were lawfully joined in marriage on May 4, 2002, in Attomey at Law 53 West Pomfret Street Carlisle, Pennsylvania Biglerville, Adams County, Pennsylvania. 17013 5. The parties have been living separate and apart since on or about October 15, 2003. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusive. 9. Both parties to this Action in Divorce are legally capable of managing their own concerns. 10. Defendant herein is not a member of the armed forces of the United States of America. 11. There were no children born to the parties. WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 -2- 12. 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 demands judgment dissolving the marriage between the parties. COUNT II EQUITABLE DISTRIBUTION 13. The averments of Paragraphs 1 through 12 inclusive above are incorporated herein by reference as though fully set forth. 14. Plaintiff and Defendant possess various items of marital property which are subject to equitable distribution by the Court. WHEREFORE, Plaintiff demands judgment equitably distributing all marital property owned by the parties and such further relief as the Court may deem equitable and just. Wayne Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 Attorney for Plaintiff -3- I verify that the statements made in this pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: l a,Ila1©3 Maura L. Reitz WAYNE F. SHADE Attorney at law 53 West Pomfret Street Carlisle, Pennsylvania 17013 N ? V 1 a -44. r ` O V o ?so.. 0 C IT !T ,ern MAURA L. REITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW V. NO. 03-6546 CIVIL TERM ADAM L. REITZ, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in the above-captioned matter, that he did, on December 22, 2003, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on December 24, 2003, as evidenced by the return receipt card attached hereto bearing Certified No. 7099 3400 0018 5044 8639. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: December 29, 2003 Wayn .Shade WAYNE F. SHADE Attorney at Law 53 West Pomfret Streei Carlisle, Pennsylvania 17013 or PIP -a 7 Postage $ .60 C3 Certified Fee 2.30 V'1 Postmark Return Receipt Fee Here eCI (Endorsement Required) 1.75 0 Restricted Delivery Fee ia-as-ao?s C3 (Endorsement Required) 3.50 M Total Postage & Fees $ 8.15 7 R 1 'ant's N e (Pile Pgnt Clearly) (to be completed by mailer) m ME E. Seitz ................ --- -------------------' - -------------------- r s Note?b?ert Drive I r --- -° r- `If anicsbura. PA 17055 ? 0 C7 M tT r r T -r r-n t? O r Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. ' ¦ Print your name and address on the reverse so that we'can return the card to you. ¦ Attach.this card to the beck of the maiiplece, r or on the front if space perks. tt. Article Addressed to: Mr. Adam L. Reitz 1253 Rebert Drive Mechanicsburg, PA 17055 13 S. Received by (Pd'Med Neme) C. Date of Delivery pagl, e: l" 12- 24-03 D. I; Q0,IlQaranf eom Item 17 ? Y' I . enter delhrowftwsss below: -jp o Ate 3. d ;.., 110tw d II ? Express Mail, ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 2. Article Number manahr, i a t se,MCe Ybei) 2001 Domestic Return R@oW 1026960241-OB e PS Forth 3811, Mgwl MAURA L. REITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW 2003-6546 CIVIL TERM ADAM L. REITZ, Defendant : IN DIVORCE PRAECH'E TO ENTER APPEARANCE To Curtis R. Long, Prothonotary: Please enter my appearance on behalf of the Defendant, Adam L. Reitz, in the above captioned case. Respectfully Submitted, IRWIN & McKNIGHT Douglas G. ler, squire Supreme Cou ID. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Date: March 23, 2004 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: WAYNE F. SHADE, ESQUIRE 53 WEST POMFRET STREET CARLISLE, PA 17013 Date: March 23, 2004 IRWIN & McKNIGHT Douglas Miller, squire Supreme Court I.D. No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 r-, nn <- ? <-; c:> ^ -? 1 -1 - ,\J -,., i 1 i . ).-J j <: ? ? .. 1 i SIAURA L. REITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 03-6546 CIVIL TERM ADAM L. REITZ, Defendant : IN DIVORCE ELECTION TO RETAKE ]PRIOR NAME NOTICE is hereby given that the Plaintiff in the above-captioned matter, prior to the entry of a Final Decree in Divorce, hereby elects to retake and hereafter use her former name, MAURA LYNN KELLER, and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, 54 Pa.C.S.A. §704. Date: April 21, 2004 Maura Lynn Reitz To Be Known As Maura Lynn Kellei?J WAYNE F. SHADE Attorney at Law 53 West Pomfret Stree Carlisle, Pennsylvania 17013 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) On this, the 21 st day of April, 2004, before me, a Notary Public, personally appeared MAURA LYNN REITZ, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose herein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. s I Notary Polic Notarial ea Connie J. Trill. Notary Public Carlisle, Cumberland County My Commission Expires Oct. 5, 2004 o' a -o _ c_a r -Il ?V i C) 1 MAURA L. REITZ, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW 2003-6546 CIVIL TERM ADAM L. REITZ, Defendant IN DIVORCE PETITION FOR ALIMONY PENDIENTE LITE AND NOW, this __c2eday of July, 2004, comes Adam L. Reitz, by and through his attorneys, IRWIN & McKNIGHT, and petitions this Honorable Court as follows: 1. The Plaintiff/Respondent is Maura L. Reitz, an adult individual who resides at 21253 Robert Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant/Petitioner is Adam L. Reitz, an adult individual with a current address of RR2, Box 333, Sunbury, Northumberland County, Pennsylvania 17801. 3. The Petitioner and Respondent were married on May 4, 2002 in Adams County, Pennsylvania, and were separated on or about October 15, 2003. 4. The Plaintiff has filed a Divorce Complaint in Cumberland County Court of Common Pleas at 2003-6546 on December 22, 2003. 5. The Petitioner is without ability to earn income sufficient to meet his reasonable needs and pay for his legal expenses. 2 WHEREFORE, Petitioner, Adam L. Reitz, respectfully requests that this Honorable Court order alimony pendente lite in an amount equal to the Pennsylvania State Support Guidelines. Respectfully submitted, IRWIN & MCKNIGHT By: D?g.l . Mi le" Esquire 60 t omfr et Street Carlisle, PA 17013 Supreme Court I.D. No: 83776 (717) 249-2353 Attorney for the Petitioner Adam L. Reitz Date: July A, 2004 3 VERIFICATION The foregoing Petition is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they 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.A. Section 4904, relating to unsworn falsification to authorities. ADAM L. REITZ Date: July 33 , 2004 4 CERTIFICATE OF SERVICE I, Douglas G. Miller, Esquire, do hereby certify that I have served a true and correct copy of the foregoing document upon the persons indicated below by first class United States mail, postage paid in Carlisle, Pennsylvania 17013, on the date set forth below: WAYNE F. SHADE, ESQUIRE 53 WEST POMFRET STREET CARLISLE, PA 17013 Date: July 26, 2004 IRWIN & McKNIGHT )?- A41, - Dou la g . Miller, Esquire Supreme Court I.I). No. 83776 West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 1 70 1 3-3 222 (717) 249-2353 (? N _ Ol i f`J c, In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ADAM L. REITZ ) Docket Number 03-6546 CIVIL Plaintiff ) vs. ) PACSES Case Number 039106771 MAURA L. REITZ ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 16TH DAY OF MARCH, 2005 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other REQUEST FOR APL CONFERENCE filed on JULY 26, 2005 In the above captioned matter is dismissed without prejudice due to: THE DEMISE OF THE PETITIONER, ADAM L. REITZ, ON SEPTEMBER 11, 2004. O The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xC: defendant Wayne Shade, Esquire Doug Miller, Esquire Service Type M BY THE COURT: aw¦ir Edward E. JUDGE Form OE-506 Worker ID 21005 Curtis R. Long Prothonotary Office of the Protbonotarp Cumberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor D3 - G, Sqg CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY n„o r,n,rthmozP 4nuare - Carlisle, Pennsylvania 17013 - (717) 240-6195 - Fax (717) 240-6573