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Home My WebLink About09-5128.9 COLLEEN G. REYNOLDS, Plaintiff V. NATHAN A. REYNOLDS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CR - 5I A8 : CIVIL ACTION -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 INDIGNI'T'IES 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, I COURTHOUSE SQUARE, CARLISLE, PA 17013. IF YOU DO NOT FILM; 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 PAVER 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 COLLEEN G. REYNOLDS, Plaintiff V. NATHAN A. REYNOLDS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. O G/ `" 3,0- ?/ G 41, / : CIVIL ACTION - DIVORCE COMPLAINT COUNT I - DIVORCE UNDER 43301(c) or J1301(d) OF THE DIVORCE CODE 1. Plaintiff is Colleen G. Reynolds, who currently resides at 205 Main Street, Wellsville, York County, Pennsylvania, 17365. 2. Defendant is Nathan A. Reynolds, who currently resides at 984 Park Place, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth ofPennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 16, 2006 in New Cumberland, Pennsylvania. 5. The parties have no minor children to the marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. Plaintiff has been advised that counseling is available and that she may have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued. 9. The cause of action and sections ofthe Divorce Code under which Plaintiffis proceeding are: (a) §3301(c). The marriage of the parties is irretrievably broken; and (b) §3301(d). The marriage of the parties is irretrievably broken and, at the appropriate time, Plaintiff will submit an affidavit stating that the parties have been living separate and apart for a period of at least two (2) years. 10. Plaintiff requests This Honorable Court enter a Decree of Divorce. WHEREFORE, Plaintiffrespectfully requests This Honorable Court enter an Order dissolving the marriage between Plaintiff and Defendant. Respectfully Submitted, COLGAN MARZZ.A000, LLC Timothy J. t+tgMjfAgylre Attorney ID #77944 130 West Church Street Suite 100 Dillsburg, PA 17019 Tel: (717) 502-5000 Fax: (717) 502-5050 Dated: ? " 1 q -v COLLEEN G. REYNOLDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. NATHAN A. REYNOLDS, , Defendant CIVIL ACTION - DIVORCE VERIFICATION I, Colleen G. Reynolds, verify that the statements made in this Complaint are trite and correct to the best of my knowledge, information, and belief I understand that false statements herein are trade subject to the penalties of 18 Pa. CS. §4904, relating to unworn falsification to authorities. Date: 7 - Z t9 - o `? Iq 1?1 tA COLLEEN &IqalDS Plaintiff MtA 2 JUIL 28 r 1112: 5, L 4338.5o 4>0 AIW C'x,7c9a5'7 RS* x.537 COLLEEN G. REYNOLDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CA - SI B Vi l ex 1% NATHAN A. REYNOLDS, Defendant CIVIL, ACTION - DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter intends to resume and hereafter use the previous name of Colleen Gayle Fisher and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. Section 704(a) as amended which permits a party in a divorce action at any time prior to or subsequent to the entry of the divorce decree to resume any prior surname used by that person Date: Aolleen aby4 e hold 1 y TO BE KNOWN AS: Colleen Gayle fisher COMMONWEALTH OF PENNSYLVANIA COUNTY OF '\?)v SS On this, th day of 2009, before personally appeared Collcen Gayle Rey known tome or sat sf} the undersigned officer, ( provyto be the per-so whose name is subscribed to the within instrument, and acknowledged that lsh she executed the sane for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. MY COMMISSION EXPIRES: 'In (D 1g6 S G 6 OT R U L 6C ?S L) Co"WEALTH OF PENNSYLVANIA Notarial Seal De* N• Robinson, No Fairview Twp, F...' Comm , York Count lio 'ember. Pen ftiort n ?? liAeY 8, 2013 mania Association of Notaries F THE F-?? j Y 2009 J,.;, 2 6 P f 112: 5 ail' .j 11•oo Pt) AT H 0,0 aasq 12.T* aassa7 COLLEEN G. REYNOLDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-5128 CIVIL TERM NATHAN A. REYNOLDS, Defendant CIVIL ACTION -DIVORCE AFFIDAVIT OF SERVICE I, Jeanette L. Roberts, being duly sworn, deposes and says that she is an adult and that she served the within Divorce Complaint on the Defendant, at the Defendant's last known address as follows: 984 Park Place, Mechanicsburg, PA 17055, by certified mail, restricted delivery, return receipt requested on the 4t" day of August, 2009. The Certified Mail Receipt and PS Form 38111 is attached hereto, marked Exhibit "A" and made a part hereof by reference thereto. Date: August 17, 2009 COLGAN & MARZZACCO, LLC By A` f_o?d? Je ette L. Roberts COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF YORK On this, the l 7t" day of August, 2009, before me, a notary public, personally appeared Jeanette L. Roberts known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and acknowledged that she executed the same for the purposes therein contained. WITNESS, my hand and notarial seal the day and year aforesaid. NOTARY P My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Timothy J. Colgan, Notary Public Dillsburg Boro, York County My Commission Exoires Oct. 3, 2010 Member, Pennn;w 3 ?= -?niation of Notaries ¦ Complete Items 1, 2, and 3. Also complete Item 4 N Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiipieoe, or on the front If space permits. 1. Article Addressed to: Na lian A. R« P. Ads 984 Park Place Mechanicsburg. "4 17055 eiS A. Signature Agent x/' -? OO Addre B. br n ? r , ?rfbr? Jd dMvery address dlfl mt from item i7 'ONe, If YES, enter delivery address below: O No 3. SPI'vice Typo W-Mrtilled Mail ? Opess Mau O Registered O Return Receipt for Merchandise O Insured Mail ? C.O.D. 4. Assr' ' I' m (Fobs Fee) 2. Article Number Mrransrer from service bbeo 7007 0220,0003 3,2a8 0718 _ PS Form 3811, February 2004 Domestio Rehm Reoeipt- _VWMWC2 11540 EXHIBIT "A" Or THE PROT;_ , ,z{DTAFY 2009 AUG 18 PM 2- 08 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLLEEN G. REYNOLDS V. NATHAN A. REYNOLDS DIVORCE DECREE AND NOW, ~ c; ~ ~ ( L~~ , it is ordered and decreed that COLLEEN G. REYNOLDS plaintiff, and NATHAN A. REYNOLDS ,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.") However, the provisions of the Agreement entered into by the parties on June 23, 2010, shall be incorporated by reference, but shall not merged into this decree in divorce. NO. 09-5128 By the Court, ~•9• to l~c~~ c'l~.a~ le.cf -1w A~ C.n~~ r~ct, ~ec1 -~a G,~:,da t~ ~