HomeMy WebLinkAbout09-4015Stacey Reedy, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : CIVIL ACTION - LAW
IN DIVORCE
Thomas Reedy,
Defendant : NO. 09- CIVIL TERM
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, Cumberland County Courthouse, 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, 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 INFORMATION 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, Pennsylvania 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County 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. You must attend the scheduled conference or hearing.
STACEY REEDY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
THOMAS REEDY,
Defendant : NO.09-
'?O S CIVIL TERM
DIVORCE COMPLAINT
The plaintiff, Stacey Reedy, by her attorneys, the Family Law Clinic, sets forth the
following cause of action in divorce:
DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Stacey Reedy, who currently resides at 111 South Washington Street, 2nd
Floor, Mechanicsburg, Cumberland County, Pennsylvania, 17055, since October 23, 2008.
2. Defendant is Thomas Reedy, who currently resides at 56 Hunkey Hollow Road,
Duncannon, Perry County, Pennsylvania, since August 30, 2008.
3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth
for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on March 19, 2004, in Cumberland
County, Pennsylvania.
5. Plaintiff and Defendant have lived separate and apart since August 30, 2008.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
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.
9. The Defendant, Thomas Reedy, is not in the military.
WHEREFORE, Plaintiff requests the court to enter a decree of divorce dissolving the
marriage.
Sarah Rosko
Certified Legal Intern
MEG RIESMEYER 0
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in the foregoing complaint are true and correct, to the
best of my knowledge, information and belief. I understand making any false statement
would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to
authorities.
Date rp - /1-) - 6VOO? Plaintiff
Stacey Reed
OF?
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Stacey Reedy,
Plaintiff
V.
Thomas Reedy,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
: NO. 09- yQ/ S CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Stacey Reedy, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date
Respectfully submitted
Sarah Rosko
Certified Legal Intern
?0*x 6_'4x'f ®J.// ,
ROBERT E. RAINS 6
THOMAS M. PLACE
ANNE MACDONALD-FOX
MEGAN RIESMEYER
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
717-243-3639
F?LEL--i r t
OF The F OTAPY
2009 JUN 15 PM 3: 00
Stacey Reedy, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE
Thomas Reedy,
Defendant : NO. 09- 4015 CIVIL TERM
ACCEPTANCE OF SERVICE
I accept service of the Divorce Complaint in the above tioned matter.
Date
Mark Bayley, Esquire
Bayley & Mangan Law Offices
17 West South Street
Carlisle, PA 17013
"FTC" V
2009 JJr-Il GAF kill Ii: 1 ;.
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