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Home My WebLink About04-1780 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, : Plaintiff : : No. O'/-/Tgo CIVIL TERM . THOMAS J. FLYNN, : CIVIL ACTION- LAW 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 arc warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may bc 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 at the Cumberland County Courthouse, Cumberland, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, : Plaintiff : : No. CIVIL TERM : THOMAS J. FLYNN, : CIVIL ACTION- LAW Defendant : IN DIVORCE : AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariancia escrita o en persona o pot abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notifcacion y pot cualquier queja o alivio que es pedido en la petition de demanda. Usted puede perder dinero o propiedad u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERICIO, VAYA EN PERSONA O LLAMA POR TELEFONO A LA OFICINA CUYA DIRECION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, : Plaintiff : : No. o ~/- / 7ga CIVIL TERM THOMAS J. FLYNN, : CIVIL ACTION- LAW Defendant : IN DIVORCE : COMPLAINT IN DIVORCE AND NOW comes Dyan Regan/Flynn, by and through her counsel, Killian & Gephart, LLP, who represents as follows: 1. Plaintiff, DYAN REGAN/FLYNN, is an adult individual, who currently resides at 244 North Lewisberry Road, Mechanicsburg, York County, Pennsylvania, 17055. 2. Defendant, THOMAS & FLYNN, is an adult individual who currently resides at 1833 Red Spruce Lane, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff avers that she has been a bonafide resident in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 17, 2000 in Camp Hill, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of 18. 6. A prior action in divorce was initiated in Cumberland County as Docket No. 2003-3352, which has since been discontinued. 7. Plaintiffhas been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff f~om the bonds of matrimony heretofore existing between Plaintiff and Defendant. Respectfully submitted, & GEPHART (717) 232-1851 Dated: ~/~ 10~ Attorney I.D. #53148 Attorneys for Plaintiff VERIFICATION I hereby verify that the statements of fact made in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the penalties contained in 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. CERTIFICATE OF SERVICE I do certify that I served a tree and correct copy of the within document upon the following by depositing a copy of same in the United States mail, postage prepaid, addressed as follows: Jack Howett, Esquire 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Christy Sunch¥ch,/lecretary o J. PAUL HEL~/-.~SQUIRE Killian & Gephart 218 Pine Street P.O. Box 886 Harrisburg, PA 17108-0886 (717) 232-1851 Dated: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, : Plaintiff : : No. 2004..1780 CIVIL TERM : THOMAS J. FLYNN, : CIVIL ACTION- LAW Defendant : IN DIVORCE : AFFIDAVIT OF ACCEPTANCE OF SERVICE I, i~oh~ ~, ~4'o~aO~g'e', Esquire do hereby swear and affirm that I accepted service of a tmc and correct copy of the Complaint in Divorce on /q ?t'l~ ~ ~ , 2004 on behalf of my client, -1-~0¢~.e~ S"~, ~]t4 flv5, iDefendant herein. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, ) Plaintiff ) ) v. ) NO. 2004-1780 CIVIL TERM ) THOMAS J. FLYNN, ) C1VIL ACTION - LAW Defendant ) IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 23, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301(¢} OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI 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 above 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)~Dy ~lyrm,~l tif~f ~~--'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN KEGAN/FLYNN, ) Plaintiff ) ) v. ) NO. 2004-1780 CIVIL TERM ) THOMAS J. FLYNN, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 23, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER §3301{¢) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI 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 above 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: July 28, 2004 ~ Th~"J~r lynn, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, ) Plaintiff ) ) v. ) NO. 2004-1780 CIVIL TERM ) THOMAS J. FLYNN, ) CIVIL ACTION - LAW Defendant ) 1N DIVORCE DIVORCE INFORMATION SHEET Pursuant to Act 2001-82, Vital Statistics Forms are not required effective January 1, 2002. However, the Prothonotary is required to provide the following information, in lieu of the Vital Statistics Form. Please complete the appropriate information and file with the Prothonotary. Plaintiff's Name: Dyan Regan/Flyrm Plaintiff's Social Security Number: 191 - 52 - 1870 Defendant's Name: Thomas J. Flynn Defendant's Social Security Number: 209 - 46 - 0498 Date of Marriage: March 17, 2000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, ) Plaintiff ) ) v. ) NO. 2004-1780 CIVIL TERM THOMAS J. FLYNN. ) ) CIVIL ACTION - LAW Defendant ) IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) ofthe Divorce Code was filed on April 23, 2004. 2. The marriage of Plaintiffand Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in divorce aider service of notice of intention to request entry oftbe decree. WAIVER OF NOTICE OF INTENTION TO REOUE~r ENTRY OF A DIVORCE DECREE UNDER ~3301(¢~ OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ill 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 af[er it is filed with the prothonotary. I veri~ that the statements made above 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: ~////~ ~'/~ ~,z ..,~g,/x~ ~/~F,~ _ _~a/.fl ~,,..~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, ) Plaintiff ) ) v. ) NO. 2004-1780 CIVIL TERM ) THOMAS J. FLYNN, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE OEFENDANT'$ AFFIDAVIT OF CONSENi' I. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 23.2004. 2. The marriage of Plalntiffand Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry ora final decree in divorce after service of notice of intention to request entry oftbe decree. WAIVER OF NOTICE OF INTENTION TO REOUE$1- ENTRY OF A DIVORCE DECREE UNDEr, ~t3301(el OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifl 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 veri~ that the statements made above 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: July 28, 2004 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DYAN REGAN/FLYNN, ) Plaintiff ) ) v. ) NO. 2004-1780 CIVIL TERM THOMAS J. FLYNN, ) CIVIL ACTION - LAW Defendant ) IN DIVORCE PRAECIPE TO TRANSMIT RECORB TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce de~ree: 1. Ground for divoree: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Service accepted by John C. Howett, Jr., Esquire on April 28, 2004; Affidavit of Acceptance of Service filed on-dmm__215.~2i}I~. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff, ~; by defendant July 28, 2004. 4. Related claims pending: No related claims pending. 5. Date plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the prothonotary: contemporaneously herewith; date defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: contem~usly herewi~th.~ . ~[IL/.~AN & GEPHAR~'"" l~,Pine Street P.O. Box 886 Harrisburg, PA 1710g Telephone: (717) 232-1851 Counsel for Plaintiff Dyan Regan/Flyrm iNTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. NO. 200/+-1780 Civ:[1 Terz Plaintiff VERSUS Thomas J. Flynn Defendant DECREE IN DIVORCE AND NOW, i;~.*.-~" ~' ,,~OO*"/, IT IS ORDERED AND DECREED THAT Dvan 'R~_e.~'n~Fl_vt-tn _, PLAINTIFF, AND Thomas J. Flynn __, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED Of RECORD iN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURT: ~ ~ R~OT~I~J~ OTA R y IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY. PENNSYLVANIA v. ) ) ) ) ) ) ) NO. 2004-1780 CIVIL TERM DYAN REGAN FLYNN. Plaintiff THOMAS J. FLYNN. Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR ENTRYIWITHDRAWAL OF APPEARANCE TO: THE PROTHONOTARY OF SAID COURT Please withdraw my appearance on behalf of the Plaintiff, DYAN REGAN FLYNN. in the above-captioned action. I (~o 10 ,- Dated ~/' J. a I elvy, Esqui Me ees Wallace urick LLC 100 Pine Street, P.O. Box 1166 Harrisburg, PA 17108-1166 (717) 237-5343 Atiy.I.D.#53148 Please enter my appearance on behalf of the Plaintiff, DY AN REGAN FLYNN, in the above-captioned action. III <6/tJS Oat I rr--- ("', ._,] r. :"~, CD