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HomeMy WebLinkAbout09-7668MOLLY E. REESE, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09 - -Y& 0 0;.; JEREMY ADAM REESE, 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 foregoing 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 in 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 at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 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 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 Telephone: (717) 249-3166 MOLLY E. REESE, Plaintiff VS. JEREMY ADAM REESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. MOLLY E. REESE, Plaintiff VS. JEREMY ADAM REESE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, MOLLY E. REESE, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is MOLLY E. REESE, an adult individual who currently resides at 101 n. 2ND Street in Wormleysburg, Cumberland County, Pennsylvania. 2. The Defendant is JEREMY ADAM REESE, an adult individual who currently resides at 1001 Rupley Road, Apt. 204 in Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 16 June 2008 in New Cumberland, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - COUNSEL FEES AND EXPENSES 9. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 10. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 11. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 121` Street Lemoyne, Pa 17043 (717) 761-5361 I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ` I 12-009 ?Mu?? E E-,,, MOLLY E. REE FILED ?. ,:ARY 2099 NOV -b FN 1:26 ClUiY tJi ?23e.S-O o-K--v 7517 / Qw- It CU - 2''?` ?- 33 t 0? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MOLLY E. REESE, Plaintiff ) VS. ) FILE NO. 2009-7668 JEREMY ADAM REESE, ) Defendant ) NOTICE TO RESUME PRIOR SURNAME NOTICE IS HEREBY GIVEN THAT MOLLY ELLEN REESE, Plaintiff in the above matter I select one by marking "x" I : _xx_ prior to the entry of a Final Decree in Divorce, after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of (3), and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: 11. U& COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND -mcgi, ? W, zu-'? MOLLY ELL REESE 4NA?s" ?? &KL?e ' Signature o e being resumed MOLLY ELLEN KELLY ( SS.. On the l?h day of dalw?? , 2009, before me, the undersigned officer, personally appeared MOLLY ELLEN REESE, known to me (or satisfactorily proven) to be the person whose name is signed to the within Notice to Resume Prior Surname and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMM N TH OF PCH GYLVANIA , N41ARX SEAlb 1AA AMY M. HARIK!NS, Not elNA-4 I ` Lemoyne Borfl , t::,trt! otary P ic. My Commission Expiruv t:e013 FILED--0i"FICE OF THE' RRO T HPNOTARY 2009 NOV 23 PM 12: 06 )UNTY PENNSYLVANA ca C,k 1s:? r MOLLY E. REESE, ) PLAINTIFF ) vs. ) JEREMY ADAM REESE, ) DEFENDANT ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2009-7668 IN DIVORCE ACCEPTANCE OF SERVICE I, JEREMY ADAM REESE, hereby accept service of the original Complaint in Divorce and acknowledge receipt of a copy of the Complaint. Date: ~ l ~ ~~ ~ ~-~ ~~ -•'_ ~ JEREMY ADAM REESE ~'. 1001 Rupley Road, Apt. 204 Camp Hill, PA 17011 _ ~- Zu~~ GEC - f,s~3 i f ~ 2 C3 Ti-A E i {ri P -3 Ate.'?r ; j?SS a w '????_`! ?'??t 171 ? {.. MOLLY E. REESE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JEREMY ADAM REESE, Defendant PRAECIPE TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 2009-7668 IN DIVORCE Please withdraw all economic claims previously filed on behalf of the Plaintiff Molly E. Reese, now Molly E. Kelly, in the above matter. 17 February 2011 Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, Pa 17043 (717) 761-5361 r= €IED-OFF IC,"' 1 . I'll MOLLY E. REESE, Plaintiff vs. ='t11Ar3 1Er04-. 1r11w ?J l - ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-7668 JEREMY ADAM REESE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 6 November 2009 and served upon the Defendant on 20 November 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I 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. 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 in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: MOLLY E. KE formerly MOLLY E. ESE a e i °"" ? rx n " MOLLY E. REESE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. JEREMY ADAM REESE, Defendant CIVIL ACTION - LAW NO. 2009-7668 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 6 November 2009 and served upon the Defendant on 20 November 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I 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. 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 in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: ` REIGIY ADAM REESE C, MOLLY E. REESE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. JEREMY ADAM REESE, CIVIL DIVISION . NO. 2009-7668 CIVIL n ?PRAECIPE TO TRANSMIT RECORD J)' r- To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce ?a decree: 1. Ground for divorce: Irretrievable breakdown under § (3301(c)) and § (3301(d)(1)) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: Acceptance of Service filed on 1 December 2009 indicating service on Defendant on 20 November 2009. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintiff 1 March 2011 ;by defendant 1 March 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: Dated 1 March 2011 and filed contemporaneously herewith Date defendant's Waiver of Notice was filed with the Prothonotary: Dated 1 March 2011 and filed contemporaneously herewith ittorney o ainti efen t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MOLLY E. REESE, V. JEREMY ADAM REESE, DIVORCE DECREE AND NOW, D , it is ordered and decreed that MOLLY E. REESE, , plaintiff, and JEREMY ADAM 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. A AM. Y) A~ 1JA LO D.BLtEL?? rothonotary : No. 2009-7668 3t 8 U - Cart. tna; wd -b auq Ands