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HomeMy WebLinkAbout04-4560HEATHER L. REAGAN, Plaintiff WILLIAM G. REAGAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI/\ CIVIL ACTION- LAW IN DIVORCE, EQUITABLE DISTRIBUTION NO. 04- CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, lfyou 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 c~se 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 ~,he 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 COLrNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 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 American 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 hear/ng or business before the court. You must attend the scheduled conference or hearing. HEATHER L. REAGAN, Plaintiff WILLIAM G. REAGAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : DIVORCE, EQUITABLE DISTRIBUTION : NO. 04 -' "]~,,~ CIVIL ~i-ERM COMPLAINT UNDER 23 Pa.C.S..~ 3301(c) and 3301(d) OF THE DIVORCE CODE The plaintiff, Heather Reagan, by her attorneys, the Family Law Clinic, sets forth the following causes of action: COUNT I-DIVORCE 1. Plaintiffis Heather Reagan, who currently resides at 117 Conodoguinet Mobile Estates, Newville, Cumberland County, Pennsylvatfia 17241. 2. Defendant is William Reagan, who currently resides at 224 B Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiffand Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 27, 2000 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since March 18, 2004. 6. There have been no prior actions of divorce or for annulment between the parties. 7, The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the Court to enter a decree of divorce dissolving the marriage. COUNT II-EQUITABLE DISTRIBUTION 9. Plaintiff reasserts paragraphs 1 through 8, supra. 10. During the marriage, the parties have acquired marital property including, but not limited to, real estate located at 224 B Street, Carlisle, Pennsylvania. WHEREFORE, Plaimiffrequests the Court to enter a decree equitably distributing the marital property. Date: © ?/0. ~/0~' Rand~l~M~. Justice Certified Legal Intern THOMAS M. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. §4904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. HEATHER L. REAGAN, Plaintiff WILLIAM O. REAGAN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW :INDIVORCE x i NO. 04-/4~CiViL0 TERM 'PRAECIPE TO PROCEED IN FORMA PAUPERIS Kindly allow Heather L. Reagan, 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, ~tice Certified Legal Intern ROBERT E. RAINS ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH Supervising Attorneys FAMILY LAW CL1NIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 HEATHER L. REAGAN, Plaintiff WILLIAM G. REAGAN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW : IN DIVORCE, EQUITABLE DISTRIBUTION : NO. 04-4560 CIVIL TERM CERTIFICATE OF SERVICE I, Randall M. Justice, Certified Legal Intern, Family Law Clinic, hereby certify that I have served a true and correct copy of the Complaint for Divorce on Wiilliam G. Reagan, residing at 224 B Street, Carlisle, Cumberland County, Pennsylvania by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by William G. Reagan on the l 1th day of September, 2004, as evidenced by the attached green card. I understand that making any false statement would subject me to penalties under 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated:~ /O~-I Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243 -2968 UNITED STATES POSTAL SERVICE eirSt-C ass Mail ostage & Fees Paid[ SPS / rmit No. G-10 · Sender: Please print your name, address, and ZIP+4 in this box ' · Complete items 1, 2, and 3. Also comprete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we,t~return the card to you. · Attac~l~to the back of the mailpiece, 1 ~essed to: 7003 3110 0004 PS Form 381 1, July 1999 C. Signature ? []Yes below: rq No 3. Service Type ~ertified Mail [] Express Mail [] Registered ~:~eturn ReceJpt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) .~-'~es 5774 21[=7 Domestic Return Receipt 102595-99-M-1789 r-t ~e u,~ ~ec~ept r~ Certified Mail Provi : · A mailing receipt I~$ Imp°rt~t Rer~inders: · For an additional fee. a Return Receipt may be requeste fRe~c~pt,(PSF°rm3811)to he ...... P se complete a-~3-r~ '- p of a duphcate return re,-~, etu~r~neR~ece~pt R uest · e P~.stage to ~OVer the · For an a,d_dffJonal fee, delivery may be r IhIPORTANT: Save thia receipt and Present it I~hen makin an Internet access to delivery in.formation a nnt available e~n inquiry addressed to APOs and FPOs mail HEATHER L. REAGAN, Plaintiff Vo WILLIAM G. REAGAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION- LAW : IN DIVORCE, EQUITABLE DISTRIBUTION : NO. 04-4560 CIVIL TERM PRAECIPE TO THE PROTHONOTARY: The Family Law Clinic respectfully requests that the Prothonotary dismiss the Divorce Complaint filed in the above-captioned matter without prejudice. Rand[a/klM. Justice Certified Legal Intern THO'~. PLACE ROBERT E. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carli[sle, PA 17013 (717) 243-2968 HEATHER L. REAGAN, Plaintiff Vo WILLIAM G. REAGAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION- LAW : IN DIVORCE, EQUITABLE DISTRIBUTION : NO. 04-4560 CIVIL TERM CERTIFICATE OF SERVICE; I, Randall M. Justice, Certified Legal Intem, Family Law Clinic, hereby certify that I have served a true and correct copy of the Praceipe to Dismiss on William G. Reagan, residing at 224 B Street, Carlisle, Cumberland County, Pennsylvania by depositing a copy of the same in the United States mail on the 16th day of December, 2004. I understand that making any false statement would subject me to penalties under 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: R~~" "' ("/ Certifie&Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968