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Home My WebLink About08-7299McNEES WALLACE & NURICK LLC By: Debra Denison Cantor I.D. No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantorCaD-mwn.com Attorneys for Plaintiff KATIE G. REED, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08. 7d49 al%j,t( (erm ROBERT S. REED, JR., 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 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 at the Cumberland County, 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 BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 McNEES WALLACE & NURICK LLC By dWk1JZL Debra Denison Cantor I.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: December 11, 2008 McNEES WALLACE & NURICK LLC By: Debra Denison Cantor I.D. No. 66378 100 Pine Street Harrisburg, PA 17108-1166 (717) 232-8000 (717) 237-5300 facsimile dcantor -mwn.com Attorneys for Plaintiff KATIE G. REED, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT S. REED, JR., Defendant NO. 9 9 e4w%"l 7--e- IN DIVORCE COMPLAINT IN DIVORCE Divorce Under 3301(c) or 3301(d) of the Divorce Code And now comes Plaintiff, Katie G. Reed, by and through her counsel, McNees Wallace & Nurick LLC, and files the following Complaint in Divorce. COUNTI Divorce Under 3301(c) or 3301(d) of the Divorce Code 1. Plaintiff is Katie G. Reed, who currently resides at 1119 Wansford Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Robert S. Reed, Jr., who currently resides at 1119 Wansford Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 31, 1996 in Camp Hill, Pennsylvania. 5. Plaintiff and Defendant are the parents of one minor child, Samantha M. Reed, born December 2, 1998. 6. There has been no prior action of divorce between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. Plaintiff hereby waives her right to such counseling. 9. After 90 days have elapsed from the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 10. In the alternative, Plaintiff will file a 3301(d) Affidavit and provide the appropriate notices two years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce under Section 3301(c) or (d) of the Divorce Code. COUNT II EQUITABLE DISTRIBUTION 11. Plaintiff incorporates by reference paragraphs 1 through 10 of this Complaint. 12. Plaintiff and Defendant possess various items of personal marital property, as well as marital debts, which are subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties, as well as all marital debts. McNEES WALLACE & NURICK LLC By (??'? `'1/? Debra Denison Cantor I.D. No. 66378 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 232-8000 Attorneys for Plaintiff Dated: December 11, 2008 VERIFICATION Subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities, I hereby certify that the facts set forth in the foregoing document are true and correct to the best of my information and belief. Katie G. Reed Dated: 141 ? 1C)q ?'?Nt C-) C> C-5 c.J 0 { ter ? Fn A .L T , ? LU -o r? MCNEES WALLACE & NURICK LLC By: Debra Denison Cantor, Esquire Attorney I.D. No. 66378 100 Pine Street Harrisburg, PA 17101 Telephone: (717) 237-5297 Facsimile: (717) 260-1667 dcantor(aD-mwn.com Attorneys for Plaintiff KATIE G. REED, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2008-7299 ROBERT S. REED, JR., IN DIVORCE Defendant AFFIDAVIT OF ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in the above Dated: /2' Jr. f,.,? ^:7 ,?? ?? ??? ` 1 r -.?;? A ?- ? . ?'R;k °° ; .?, , (David1D. Bueff 1n`rothonotary lqrkS. Sohonage, Solicitor office of the Nothonotary knee X Simpson 1' Deputy 1Trothonotary Irene E. 9Korrow 2"d Deputy 1?rothonotary County, Pennsylvania 69 - 14IZ99 CIVILTERM AND NOW INTENTION CASE IS HER[ R.C.P 230.2 ORDER OF TERMINATION OF COURT CASES IS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF PROCEED AND RECEIVING NO RESPONSE -THE ABOVE TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 9 Su4e 100 • Carlisle, PX 17013 • (717 240-6195 • FaX (717 240-6573