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HomeMy WebLinkAbout08-2981V F:\DOCS\FL\DIV\Reilly,Bonnie-NOtice.wpd Elizabeth B. Stone, Esquire Supreme Court ID #60251 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff BONNIE M. REILLY, Plaintiff v. MICHAEL K. REILLY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. OFr!" .1-~1 ~~ CIVIL 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 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 Cumberland County Courthouse, Carlisle, PA 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. PA 17013-3302 Telephone: (717) 249-3166 F:\DOCS\FL\DIV\Reilly,BOnnie-Div Complaint.wpd Elizabeth B. Stone, Esquire Supreme Court ID #60251 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff BONNIE M. REILLY, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 6 ~' ~ y ~~ CIVIL TERM MICHAEL K. REILLY, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is Bonnie M. Reilly, an adult individual, who currently resides at an undisclosed location situate in Cumberland County, Pennsylvania. 2. The Defendant in this action is Michael K. Reilly, an adult individual, who currently resides at 515 9th Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on August 6, 1977, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -1- 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that all children born of this marriage have attained the age of majority. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling and does not wish to engage in counseling at this time. 9. The Plaintiff requests the court to enter a decree of divorce. Date: STONE LaFAVER'& SHEKLETSKI ..~~ ,~'~ By E~:,,"~'ZABE B .,'STONE ~~'upre "°C urt ID #60251 414 rid e;"Street, P.0. Box E N Cum Eland, PA 17070 eleph r 717-774-7435 -2- Atto~~7leys for Plaintiff VERIFICATION Bonnie M. Reilly states that she is the Plaintiff named in the foregoing Complaint and that she is acquainted with the facts set forth in the foregoing Complaint; that the same are true and correct to the best of her knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to ' thor' ies. BONNIE M. REILLY Date: °~ ~f, ~.....;~ ~ ~' c LY? ~- ~ ~= £~^ ~. ~"~ '~ L. l'' o~ ~' ~~. rv c c~ -c N cr-, ~~ m ~F9 ;~ f'd'1 vs Case No. ©O To the Court: , STATEMENT OF INTENTION TO PROCEED • (Lel CP ,F) intends to proceed with the above . ptioned matter. Print Name p en+ (L sem_ Sign Name Date: `0 \ 241 I Lt Attorney f. ` IMPORTANT NOTE 3> ro W et In the event that this is a second or subsequent filing of a Statement of Intention to Proceed, this matter will be referred to the President Judge for the purpose of conducting a status conference . involving all counsel. The goal of the status conference will be to set the matter for trial or other final disposition within a time certain. Prior to the status conference, Counsel will be expected to submit to the court, in writing, a proposed schedule for the completion of discovery, the filing of dispositive motions and a report as to whether alternative dispute resolution has been used or discussed.