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HomeMy WebLinkAbout08-7164 DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW KEVIN REESE, NO. 08 - 71uq 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. Your 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, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIV RCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS P ER 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 T HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAM ION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS T A REDUCED FEE OR NO FEE. Cumbe land County Bar Association 32 South Bedford Street Carlisle! PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of (Cumberland County, Pennsylvania, 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 ' ndividuals 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. i 0- DEBORAH REESE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEVIN REESE, NO. 08 - 7f 4 y CIVIL TERM Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Debrorah Reese, an adult individual, who resides at 310 Cranes Gap Rd., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Kevin Reese, an adult individual, who resides at 3811 Market Street., Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have both 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 April 27, 1998 in Newville, 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. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. R WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, BAYLEY &31[ANGX ? Date: / J Mark F. Bayley, F 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff DEBORAH REESE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEVIN REESE, NO. 08 - CIVIL TERM Defendant IN DIVORCE VERIFICATION 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: fL---- D orah Reese, Plaintiff - o ?? ?t t? rri x' c t ?, rn o 'A? DEBORAH REESE, Plaintiff VS. KEVIN REESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08- 7 16 y CIVIL TERM IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff, Deborah Reese, by and through her attorney, Mark F. Bayley, and in support of the within petition avers as follows: No judge has been previously assigned to this matter. 2. The parties were married on April 27, 1998. 3. In or shortly after 1998, the parties purchased and moved into a home located at 310 Cranes Gap Road, Carlisle, (hereafter "marital residence"); the deed was transferred into Defendant's name solely. 4. The parties initially separated when Defendant moved out of the marital residence in October of 2006; at that time Plaintiff remained in the marital residence with the parties' child, Kirsti Reese (15 years old at the time), and Defendant relocated to a residence at 40 Melron Court, Carlisle. 5. Defendant briefly moved back into the marital residence on or around October 13, 2008 and the parties attempted to reconcile. 6. Said attempt to reconcile failed around the end of October 2008 and Defendant again moved out of the marital residence to 40 Melron Court, Carlisle. 7. Plaintiff continues to reside in the marital residence with the parties' child (now 17 years old). 8. Since October of 2008, Defendant has made repeated threats to kick Plaintiff out of the marital residence; he recently threatened to remove her if she is not out by December 10, 2008. 9. Despite not being On the deed, Plaintiff has an economic interest in the marital residence per the Divorce 'I Code. 10. While Plaintiff does not necessarily wish to remain in the marital residence indefinitely, she is in no position to relocate at this moment with the parties' child. 11. Plaintiff wishes to remain in the marital residence at this time without threats of unlawful eviction and wishes to maintain her privacy from Defendant. 12. Defendant operates his own business, Reese Builders, and is perfectly capable of residing outside of the marital residence for the time being (as he has done for the vast majority of the past two years). 13. Defendant is in possession of his clothes and other day to day items of personal property. 14. Plaintiff is filing a divorce complaint on the same date as the within petition and now wishes to resolve the parties' economic ties and to obtain a divorce. 15. To Plaintiffs knowledge, Defendant is currently pro se and is presumably opposed to the within petition. WHEREFORE, Plaintiff respectfully requests the Court to grant her temporary exclusive possession of the marital residence pending further agreement by the parties or further Order of Court. Z' ,C) Respectfull itted, ark F. Bayley, Esq ' e 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court #87663 DEBORAH REESE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEVIN REESE, NO. 08 - CIVIL TERM Defendant IN DIVORCE VERIFICATION 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 unworn falsification to authorities. Date: p, 3 of, Debq6h Reese, Plaintiff DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW NO. 08- CIVIL TERM KEVIN REESE, : IN DIVORCE Defendant CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kevin Reese 40 Melron Court Carlisle, PA 17013 Plaintiff will additionally attempt service by professional process server. Mark F. Bayley Esqu e L11 %AO DEC 10 2M6 LA DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW NO. o8- 7/0 q CIVIL TERM KEVIN REESE, : IN DIVORCE Defendant ORDER OF COURT AND NOW, this /X9 - day of , 2008, a hearing is set regarding Plaintiffs Petition for Special Relief for the %31A-t- day of Lt. Q/I , 2.-t-, in courtroom number- of the Cumberland County Courthouse, Carlisle S %<Y ark F. Bayley, Esquire vin Reese J BY THE COURT, ?+, lF1tt r.in?l? ko cis JV _ U DEBORAH REESE, Plaintiff VS. KEVIN REESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08- "'ll It, CIVIL TERM IN DIVORCE 11 PLAINTIFF'S MOTION TO WITHDRAW PETITION FOR SPECIAL RELIEF AND NOW, comes Plaintiff, Deborah Reese, by and through her attorney, Mark F. Bayley, and in support of the within petition avers as follows: 1. The Honorable Kevin A. Hess was previously assigned to this matter. 2. Plaintiff filed a petition for special relief on December 8, 2008 in which she requested to be granted exclusive possession of the marital residence. 3. A hearing on the matter was set for December 31, 2008. 4. Plaintiff has since moved out of the marital residence and in with family; therefore, her petition is now moot. 5. Defendant, pro se, is presumably not opposed to the within motion. WHEREFORE, Plaintiff respectfully requests for her petition to be dismissed. g--- Respectfully fitted, Mark F. Bayley, quire L'A? --- 17 West South Street Carlisle, PA 17013 (717) 241-2446 Supreme Court #87663 DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. 08- CIVIL TERM KEVIN REESE, : IN DIVORCE Defendant VERIFICATION Mark F. Bayley, Esquire, states that he is the attorney for Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: I Z ,? ? ?O z Mark F. Bayley, Esquire DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW KEVIN REESE, NO. 08- CIVIL TERM : IN DIVORCE Defendant CERTIFICATE OF SERVICE I, Mark F. Bayley, Esquire, attorney for Plaintiff do hereby certify that I this day served a copy of the foregoing document upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kevin Reese 40 Melron Court Carlisle, PA 17013 lZ-Z . -o'?'- Mark F. Bayley Esquire DEC 302 136 DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW NO. 08- I'/`r CIVIL TERM KEVIN REESE, : IN DIVORCE Defendant ORDER OF COURT AND NOW, this day of 71- + , 2008, upon motion by Plaintiff, Plaintiffs Petition for Special Relief filed December 8, 2008 is hereby dismissed. The hearing previously scheduled for December 31, 2008 is cancelled. BY THE COURT, J. Kevin Reese Cop I'F S rrizi t lr,.,L l k F. Bayley, Esquire :- - C D ts.? _= c DEBORAH REESE, : IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. KEVIN REESE, NO. 2008-07164 DEFENDANT PRAECIPE Please withdraw my appearance previously entered on behalf of the above-named Plaintiff, Deborah Reese. Respectfully submitted, DATE: MBay KE r e Bayley & Mangan 17 W. South Street Carlisle, PA 17013 Please enter my appearance on behalf of the above named Plaintiff, Deborah Reese. submitted, DATE: q -) q - zoo 1 Office of Sheri D. Coover 44 S. Hanover Street Carlisle, PA 17013 DEBORAH REESE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. KEVIN REESE, Case No. 2008-07164 Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 2& day of September, 2009, I caused the foregoing PRAECIPE to be served upon counsel for the Defendant by U.S. First class mail addressed as follows: Hannah Herman-Snyder 200 North Hanover Street Carlisle, PA 17013 submitted, Coover, Esquire ID 93285 44 S. Hanover Street Carlisle, PA 17013 r '" DEBORAH REESE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA (7 V. r7 ? rn?' J Case No.. 08-7164 T? KEVIN REESE, -?- Defendant = = = F PETITION FOR ALIMONY PENDENTE LITE w 1. Petitioner is Plaintiff Deborah Reese is a competent adult individual who has a mailing address of P.O. Box 1202, Carlisle, Pennsylvania. 2. Petitioner's social security number is 183-54-9335. 3. Respondent is Defendant Kevin Reese who is a competent adult individual who resides at 310 Cranes Gap Road, Carlisle, Pennsylvania. 4. Respondent's social security number is 190-66-8386. 5. A divorce complaint was filed in this case on or around December 8, 2008. A count for Alimony and Alimony Pendente Lite was filed under the above- captioned docket number on February 17, 2010. A true and correct copy of the Count for Alimony and Alimony Pendente Lite is attached to this petition. WHEREFORE, Petitioner requests that this Court Order Alimony Pendente Lite. submitted, a-I?dQi(? Date Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 DEBORAH REESE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. KEVIN REESE, Defendant : Case No.. 08-7164 CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 17'h day of February 2010 I caused a copy of the foregoing document to be served upon counsel for the Defendant by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania addressed as follows: Hannah Herman-Snyder 200 North Hanover Street Carlisle, PA 17013 submitted, S eri D. Coover, Esquire 'Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 DEBORAH REESE, Plaintiff V. KEVIN REESE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Case No.. 08-7164 COUNT FOR ALIMONY AND ALIMONY PENDENTE LITE IN DIVORCE AND NOW, comes Plaintiff Deborah Reese, by and through her attorney, Sheri D. Coover, Esquire and files the following claim for alimony and alimony pendente lite and in support thereof avers as follows: 1. On or around December 8, 2008, Plaintiff initiated this action by filing a complaint in divorce under section 3301(c ) of the divorce code (A true and correct copy of the complaint is hereby attached). 2. Plaintiff would like to add a count for a claim of Alimony and Alimony Pendente Lite. 3. Plaintiff lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living the parties established during the marriage. 4. Plaintiff has insufficient assets and income to pay counsel fees and costs regarding litigation in relation to the within matter. 5. Defendant enjoys a respectable income from which he is able to contribute to the support and maintenance of Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff requests an Order to be entered awarding Plaintiff alimony pendent elite and permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff with regard to litigation expenses and so that she may remain in the station of life to which she had been accustomed during the marriage. a- q -zoo jo Date ShEri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 DEBORAH REESE, Plaintiff V. KEVIN REESE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA Case No.. 08-7164 CERTIFICATE OF SERVICE r I, Sheri D. Coover, Esquire hereby certify that on this 17' day of February 2010 I caused a copy of the foregoing document to be served upon counsel for the Defendant by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania addressed as follows: Hannah Herman-Snyder 200 North Hanover Street Carlisle, PA 17013 submitted, heri D. Coover, Esquire ttorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 ti t -o - (D N Zym DEBORAH REESE, IN THE COURT OF COMMON P ASaF Plaintiff CUMBERLAND COUNTY, PE LfANIA V. CIVIL ACTION - LAW KEVIN REESE, NO... 08 - 7(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 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, 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 INFORAMTION 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, 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. f DEBORAH REESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. - CIVIL ACTION -.LAW- - KEVIN REESE,NO. '08 - CIVIL TERIC!t. Defendant IN DIVORCE - COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Debrorah Reese, an adult individual, who resides at 310 Cranes Gap Rd., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Kevin Reese, an adult individual, who resides at 3811 Market Street., Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have both 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 April 27, 1998 in Newville, 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. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. i WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, BAYLEY & GAN . Date: Mark F. Bayley, E quire 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff n. r. t fi,S R14y?, Fr ;f. Y *1*? .,pk, ?;?ti r?.r r-Yf a } u r.ti '•r',i'F°..:yX yf? sl S ;s?(;? f'"n{'Fr+F ?w?M?? ti ?ic "". ? •c ?`-r. ? ? ?K.??? st w ; _ ? ? ••7' ? ?? i }',? .F, .Y - . °.y? ^. a? t y ?. ti ? k x K ? { 1 * ? r .k 7 1 t ! ? / .,y xv . DEBORAH REESE, Plaintiff V. KEVIN REESE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - CIVIL TERM IN DIVORCE VERIFICATION • 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 unworn falsification to authorities. Date: '-? I b l C- f?- D orate Reese, Plaintiff DEBORAH REESE, V. KEVIN REESE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA 0 4 : Case No.. 08-7164 Defendant IN DIVORCE ' W ?a c_; - C AND NOW, comes Plaintiff Deborah Reese, by and through her attorney, Sheri D. Coover, Esquire and files the following claim for alimony and alimony pendente lite and in support thereof avers as follows: 1. On or around December 8, 2008, Plaintiff initiated this action by filing a complaint in divorce under section 3301(c ) of the divorce code (A true and correct copy of the complaint is hereby attached). 2. Plaintiff would like to add a count for a claim of Alimony and Alimony Pendente Lite. 3. Plaintiff lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living the parties established during the marriage. 4. Plaintiff has insufficient assets and income to pay counsel fees and costs regarding litigation in relation to the within matter. 5. Defendant enjoys a respectable income from which he is able to contribute to the support and maintenance of Plaintiff as well as alimony in accordance with the Divorce Code. -?7 Fri :°a L ca C) X39. ro ?C(- 4! CK+k 'Y21 / JR-A .2 .3 1'72 A, WHEREFORE, Plaintiff requests an Order to be entered awarding Plaintiff alimony pendent elite and permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff with regard to litigation expenses and so that she may remain in the station of life to which she had been accustomed during the marriage. submitted, a- i1 -m " Sri D. Coover, Esquire Date Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 DEBORAH REESE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, : PENNSYLVANIA V. Case No.. 08-7164 KEVIN REESE, Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 17th day of February 2010 I caused a copy of the foregoing document to be served upon counsel for the Defendant by depositing the same in the United States mail, postage prepaid, at Carlisle, Pennsylvania addressed as follows: Hannah Herman-Snyder 200 North Hanover Street Carlisle, PA 17013 submitted, heri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 V. CIVIL ACTION - LAW KEVIN REESE, NO.._ 08 - 7(l? ?( 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 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, 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 INFORAMTION 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County, Pennsylvania, 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. DEBORAH REESE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ' KEVIN REESE,`' NO. '08 - CIVID'TE'R.M ; Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Debrorah Reese, an adult individual, who resides at 310 Cranes Gap Rd., Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Kevin Reese, an adult individual, who resides at 3811 Market Street., Camp Hill, Cumberland County, Pennsylvania, 17011. 3. Plaintiff and Defendant have both 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 April 27, 1998 in Newville, 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. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, BAYLEY &31ANGAN Date: J Mark F. Bayley, E quire 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 8766-' Attorney for Plaintiff , Y ` v ., 4 S _ ?y rf? S?i?Yy?? ??'tf -: of ? 1 '?W i t!. f * 'x€ ??X 1? ? i" w?•i ??'" t± ?? 1+4?3?'a...`'n,'r.7! t `+, ? ? ` x" e4 ' R ?r -?' T r• . c? 'f. ?,`. -t't?'y , ,i ? ? ,.# 7-?yp?" ?i?'+ i.(??lY ?'Ln "}? h, F ' µ "? ! ?? ? a ,y f ( ? 4 ' ?, . . e Fi , ?J"j ..$ ?j??,'? ?k?'''•r' .?K'?' yl'. f fcx _f;N? ;"k' ? ?R' ? ? ,l? f +? 'r? ,?` f' n ? ? ,,? ? ?? _ ? A.• ? 7"?1R ',l ? i.??p?1 ?. '. ?/R? h DEBORAH REESE, V. KEVIN REESE, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - CIVIL TERM IN DIVORCE VERIFICATION 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: D orah Reese, Plaintiff DEBORAH REESE, Plaintiff/Petitioner VS. THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 08-7164 CIVIL TERM KEVIN REESE, IN DIVORCE Defendant/Respondent : PACSES NO: 390111430 ORDER OF COURT Ca r`J C?n Cj M- -iz co i'T) a> AND NOW, this 19th day of February, 2010, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on March 15, 2010 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Copies mailed to: Petitioner Respondent Sherri D. Coover, Esq. Hannah Herman Snyder, Esq. Date of Order: a C C' BY THE COURT, YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 DEBORAH REESE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. Case No.. 08-7164 n KEVIN REESE, Defendant ; w MOTION FOR APPOINTMENT OF MASTER Plaintiff moves this Court to appoint a Master with respect to the following claithk ? Divorce ? Distribution of Property ? Annulment ? Support ? Alimony ? Counsel fees ? Alimony Pendente Lite ? Costs and Expenses And in support of the motion states: 1. Discovery is complete as to the claims for which the appointment of a Master is requested. 2. Defendant has appeared in this action by his attorney, Hannah Herman- Snyder. 3. The statutory ground for divorce is irretrievable breakdown after more than two years of marital separation. 4. Miscellaneous: None. 5. The action does not involve complex issues of law or fact. The hearing is expected to take less than one day. submitted, ?heri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Attorney for Plaintiff DEBORAH REESE, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. Case No.. 08-7164 KEVIN REESE, Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 16th day of March, 2010, I caused the foregoing MOTION FOR APPOINTMENT OF MASTER to be served upon Defendant's counsel via United States certified mail addressed as follows: Hannah Herman-Snyder 200 North Hanover Street Carlisle, PA 17013 submitted, ?heri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 Attorney for Plaintiff DEBORAH K. REESE, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 08-7164 CIVIL TERM KEVIN A. REESE, IN DIVORCE Defendant/Respondent PACSES CASE: 390111430 ORDER OFCOURT 71 AND NOW to wit, this 15th day of March, 2010, it is hereby Ordered that tThd Peti49n for Alimony Pendente Lite filed on February 17, 2010, is dismissed, without prejudice, di.1 ? to ? no income available for Alimony Pendente Lite pursuant to the parties' incomes and the Pennsylvania support guideline calculations. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary's Office for a hearing de novo before the Court. DRO: R.J. Shadday xc: Petitioner Respondent Sheri D. Coover, Esq. Hannah Herman-Snyder, Esq. Form OE-001 Service Type: M Worker: 21005 BY THE COURT: MAR 7 8 2010 4;1 DEBORAH REESE, Plaintiff V. KEVIN REESE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Case No.. 08-7164 ORDER APPOINTING MASTER AND NOW, ^z z , 2010, E. Robert Elicker, II Esquire is appointed Master with respect to the foregoing claims. BY THE COURT: "Sheri D. Coover Esquire (Counsel for Plaintiff) 444SS. Hanover Street, Carlisle, PA 17013 ,iHannah Herman-Snyder (Counsel for Defendant) 200 North Hanover Street, Carlisle, PA 17013 V C-A rhi, rN C- E}-1 DEBORAH REESE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 08-7164 KEVIN REESE Defendant IN DIVORCE , . c x? . PRAECIPE 1 C._ TO THE PROTHONOTARY: WITHDRAWAL OF APPEARANCE Pease withdraw my appearance on behalf of the Defendant in the above-captioned matter. Respectfully submitted, Date: J " 11 - i O Hannah Herman-Snyder, Esquire 9 Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 ENTRY OF APPEARANCE Please enter my appearance as Pro Se in the above-captioned matter. Respectfully submitted, Date: evin A. Reese 310 Cranes Gap Road Carlisle, PA 17013 DEBORAH REESE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. KEVIN RE:ESE NO 08-7164 2008 Defendant MOTION FOR APPOINTMENT OF MASTER Plaintiff moves the court to appoint a master with respe4lo the following claims: C ?X Divorce ?X Distribution of Property -dry ? Annulment ? Support ? X Alimony ? Counsel Fees !.'-. ? Alimony Pendente Lite ? Costs and Expenses -, . r?_. and in support of the motion states: I . Discovery is complete as to the claims (s) for which the appointment of a master is requested,- G 2. The defendant has appeared in the action (personally) (by his attorney, Hannah Herman-Snyder (her services have been terminated) Esquire}. 3. The statutory ground (s) for divorce is 3301(c) 4. Delete the inapplicable paragraph (s): A ?X B © C ? a. The action is not contested. b. An agreement has been reached with resnect to the following claims: C. The action is contested with respect to the following claims: Distribution of marital assets. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 3 hours 7. Additional information, if any, relevant to the motion: Date: q/"4 i zero _ -? Alto e for Plaintiff COCA/ Cam' Print Name ORDER APPOINTING MASTER AND NOW 20 _ Esquire, is appointed master with respect to the following claims: By the Court, CF! -? -mod - rnQ X ? t W SEP 15 2010 DEBORAH REESE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. KEVIN REESE NO. 08-7164 2008 Defendant MOTION FOR APPOINTMENT OF MASTER P?ainti£e , moves the court to appoint a master with respect G n the following claims: ' CJ9 ::;3 q ?X Divorce ® Distribution of Property t ? support l ? A nnu men []X Alimony ? Counsel Fees t - ? Alimony Pendente Lite ? Costs and Expenses and in support of the motion states: YE`` uestE r is re f t t i hi h h y t . q a mas e o ntmen e appo c t 1. Discovery is complete as to the claims (s) for w Li ??? 2. The defendant has appeared in the action (personally) (by his attorney,_ G y r Hannah Herman-Snyder (her services have been terminated) , Esquire A W 3. The staturory ground (s) for divorce is 3301 H 4. Delete the inapplicable paragraph (s): A ® B ® C ? a. The action is not contested. b. An aureement has been reached with resneet to the followine claims: c. The action is contested with respect to the following claims: Distribution of marital assets. 5. The action does not hwolve complex issues of law or fact. The hearing is expected to take 3 C-1 -- tc C, S Additional information, if any, relevant to the Date: g1Ia "zuo Print Name ORDER APPOINTING MASTER AND NOW SL&bdale l S 20 LV / 1-O?GG(lL? ?T _Esquire, inted master with respect to the following claims: 4A ?:' `rte 1.?0?? ES /Y?t 0 g?sfc? howl By the Court, -,a ZZ ,00'? W., - 'O-? J. 4 PILED-OFFICE C117 THE FROTHONOTA Y 2011 APR 12 P1 3: 24 CUMBERNNLSAND COUNTY DEBORAH REESE, Plaintiff vs. KEVIN A. REESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-7164 IN DIVORCE ORDER OF COURT AND RULE TO SHOW CAUSE AND NOW this ? z day of 2011, upon presentation and consideration of the within Petition to withdraw as counsel, a Rule is hereby issued upon the Respondent, Kevin A. Reese, to show cause, if any he has, as to why Petitioner should not be permitted to withdraw as counsel in this matter. Rule returnable 20 days after service by first class mail, postage prepaid upon Respondent, Kevin A. Reese. By the Court, Cc: Sheri D. Coover, Esquire Attorney for Plaintiff ,/ Kevin A .'Reece , de?+ Bradley L. Griffie, Esquire For Hannah Herman-Snyder, Esquire Attorney for Defendant led D? DEBORAH REESE IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA HE _? V. CIVIL ACTION AT LAW M(m C- .I F.:I-?rv CASE NO. 08-7164 =;;u ° M c _ KEVIN REESE, _ny F- Defendant IN DIVORCE -"' =7 C-1 w AFFIDAVIT OF SERVICE I Kevin Reese, hereby verify that I was served with a copy of the'divorce decree on or around December 8, 2008 by personal service. I hereby 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.§ 4903 relating to unsworn falsification to authorities. L- M-11 Date Defendant Kevin Reese DEBORAH REESE Plaintiff V. KEVIN REESE , Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA , CIVIL ACTION AT LAW CASE NO. 08-7164 C:) IN DIVORCE .; . e-. AFFIDAVIT OF CONSENT = 1. A complaint in divorce under §3301(c ) of the Divorce Code was filed on December 8, 2008. 2. Service of the complaint was made upon Defendant. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 G1? Date Plaintiff Deborah Reese DEBORAH REESE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION AT LAW -0:3: c_ n : CASE NO. 08-7164 KEVIN REESE, J) Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 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.§ 4903 relating to unsworn falsification to authorities. Date L A "-t? --a Plaintiff Deborah Reese DEBORAH REESE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY PENNSYLVANIA ? - , _ r r?1 r V. :CIVIL ACTION AT LAW cry =°-- t . , ? CASE NO. 08-7164 "- ?- ?. , _4 CD KEVIN REESE, t E3 -r i Defendant IN DIVORCE rr? AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c ) of the Divorce Code was filed on December 8, 2008. 2. Service of the complaint was made upon Defendant. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 Date Defendant Kevin Reese DEBORAH REESE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION AT LAW -°v -" cry ' CASE NO. 08-7164 r n c- , KEVIN REESE, ! y>- -y. Defendant IN DIVORCE t? c.. '0 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 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.§ 4903 relating to unsworn falsification to authorities. Date Defendant Kevin Reese DEBORAH REESE, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 08 - 7164 CIVIL KEVIN REESE, Defendant IN DIVORCE ORDER OF COURT AND NOW, this day of , 2011, the economic claims raised in the proceedings having been resolved in accordance with a settlement agreement dated June 9, 2011, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, Vtk- 44, _ Kevi . Hess, P.J. cc: v/Sheri D. Coover Attorney for Plaintiff Hannah Herman-Snyder Attorney for Defendant C, = co n _- ? z? x -o" CD =0 $p ?Z N C) ?m -4 -C r*4 ? DEBORAH REESE, Plaintiff VS. KEVIN REESE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 08-7164 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: C7 ?., 1. Ground for divorce: -?3 = --+ Irretrievable breakdown under § (3301(c))4md ?w C =-n cor- ' (Strike out inapplicable section.) -< > ire moo 2. Date and manner of service of the complaint: -- o December 8, 2008 by personal service z 3 -n 3. Complete either paragraph (a) or (b). l affidavit of consent required by § 3301(c) oft f th ti f e on o execu (a) Date o Divorce code: by plaintiffJune 10, 2011 ; by defendant June 10, 2011 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: None. 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: June 14, 2011 Date defendant's Waiver of Notice as filed with the Prothonotary: June 14, 2011 A omey for Plaintiff/Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH REESE V. KEVIN REESE NO. 08-7164 DIVORCE DECREE AND NOW, ywf3 T 20/1 , it is ordered and decreed that DEBORAH REESE , plaintiff, and KEVIN REESE , 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, Attest. J Prothonotary >00 Op, cer ?? ?f dP?f