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Home My WebLink About04-6092 WESLEY F. REOHR, Plaintiff vs. NELL REOHR, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. (j ~ -to 9 (). : CIVIL ACTION - LAW : 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 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, 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 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 WESLEY F. REOHR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. NELL REOHR, Defendant : CIVIL ACTION - LA W : DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE The Plaintiff, Wesley F. Reohr, by and through his attorney, Jeanne B. Costopoulos, Esquire, avers the following: 1. The Plaintiff, Wesley F. Reohr, is an adult individual who currently resides at 208 Senate Avenue, Apt. 505, Camp Hill, Cumberland County, Pennsylvania, 17011- 2354. 2. The Defendant, Nell Reohr, is an adult individual who currently resides at 638 S. 26th Street, Harrisburg, Dauphin County, Pennsylvania, 17111. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on or about June 1, 1992 in St. Petersburg, Florida. Count I - Divorce 5. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 6, There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the c:ooo require the parties to participate in counseling. 10. There are no dependent children from this marriage. 11. This action is not collusive. Count II -Spousal Support. Alimonv. Alimonv Pendente Lite. Counsel Fees and Costs 12. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 13. Plaintiff lacks sufficient funds to support himself and pay counsel fees and expenses related to this action. 14. Defedant is able to pay Plaintiff alimony pendente lite, counsel fees and expenses related to this action. 15. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite, alimony, counsel fees and costs. Count III - Equitable Distribution of Marital Property Pursuant to ~3502 of the Divorce Code 16. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 17. While no settlement has been reached as of the date of the filing of this Complaint, Plaintiff is and has always been \\illing to negotiate a fair and reasonable settlement of all matters -with Defendant to the extent that a written Settlement Agreement might be entered into between the parties prior to the time of hearing on this Divorce Complaint, Plaintiff desires that such written Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage between the parties. 18. Plaintiff and Defendant are the owners of various items of real and personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this court. 19. Plaintiff and Defendant are the owners of various motor vehicles, bank: accounts, investments, insurance policies and retirement benefits acquired during their marriage which are subject to equitable distribution by this court. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; B. Equitably distributing all property owned by the parties hereto; C. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of the hearing on this Complaint, Plaintiff respectfully requests that pursuant to the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; D. For such further relief as the Court may determine equitable and just. Dated: RESPECTFULLY SUBMITTED: / /2/'5/Cddf v Jeanne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 P A Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEYFORPLAINT~F WESLEYF. REOHR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. NELL REOHR, Defendant : CIVIL ACTION - LAW : DIVORCE VERIFICATION I, Wesley F. Reohr, hereby verify that the statements made in the foregoing Complaint in Divorce 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: i2/ ~y Signature: ~0.dut J1Xr-~ Wesley F. q{eohr 73~-a0 r)~ y . 0\ u;f 1+ D~ 0\ ~~j~ ~ W -. F~ ,..." C'"'.:;',) 0 ~.-,* c....:.:> -n " ...c- C) .-1 Pl T "7J C) 1"1: r-.~ 1 rq L,) C? ~-'! ) -!il ' , C' , ....'- C 1') 1 ~<::" J:- --., -< \.0 WESLEY F. REOHR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-6092 NELL REOHR, Defendant : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Divorce filed at the above-referenced term and docket on December 3, 2004. ------. Dated: lit 6! z (Jd5 J e B. Costopoulos, Esquire 5000 Ritter Road., Suite 202 Mechanicsburg~ Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR PLAINTIFF l::, . .< ; 1-. ::s .-. C) ;; ~~ ,~~~~I 'C, '::.J -.::.' ~) ,...,.;, => c~ CJ'1 k ~ o -q ::;:! ..../_- n1r2 17f'Tl :::10 :.~ (!:,; ;~:f: .~r~ ;~~! o :E -.:. f\.) ...-:- (..'1 .. WESLEY F. REOHR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 04-6092 NELL REOHR, Defendant : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Please mark the above-referenced divorce action discontinued and dismissed. BY: ~ --- Jeanne B. Costopoulos, Esquire ATTORNEY FOR PLAINTIFF 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 PA Supreme Ct. ID No. 68735 DATE Y/i /d, . J WESLEY F. REOHR, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 04-6092 NELL REOHR, Defendant : CIVIL ACTION - LAW : DIVORCE CERTIFICATE OF SERVICE I, Jeanne B. Costopoulos, Esquire, hereby certify that this day I served a copy of the foregoing document upon the person(s), and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Camp Hill, Pennsylvania, through first class mail, prepaid, and addressed as follows: Nichole M. Staley O'Gorman, Esquire PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102-2392 ~ BY: DATED: W#f anne B. Costopoulos, Esquire 3803 Gettysburg Road Camp Hill, PA 17011 Phone: (717) 920-2500 P A Supreme Ct. ID No. 68735 r"" _,oJ - ~,t ' -~'\ I::- co