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Home My WebLink About01-5210YVONNE K. REYNOLDS, Plaintiff VS. GEORGE M. REYNOLDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. o/-,5'~/o Civil Term ACTION 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 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 YVONNE K. REYNOLDS, Plaintiff VS. GEORGE M. REYNOLDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. O/- _6',2/D : ACTION 1N DIVORCE Civil Term COMPLAINT IN DIVORCE 1. Plaintiffis Yvonne K. Reynolds, a competent adult individual, who has resided at 15 N. East Street, Carlisle, Cumberland County, Pennsylvania, since 1976. 2. Defendant is George M. Reynolds, a competent adult individual, who has resided at 13 South Hanover Street, Carlisle, Cumberland County, Pennsylvania, since August 23,2001. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on March 20, 1982 in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint 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. ,-onne K. Re?nalds, P~aifrtT~ff Respectfully submitted, ! ~xNo. 79465 7 outh Hanover St. C r~'l'gle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF )RNEY ATLAW TH HANOVER STREET 18LE~ PA. 1701:3 17) 2~S;eSOs YVONNE K. REYNOLDS, Plaintiff GIX)RGE M. REYNOIA)S, Defendant IN THE COURT OF COMMON PI,EAS CUMBERLAND COUNI'Y, PI",NNSYI,VANIA No. 5210 Civill'crm 2001 ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPI,AINT. AND NOW, this September l 1, 2001,1, Jane Adams, Esquire, hereby certil~, thai on Scptcmbcr 7, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery., return receipt requcsied, addressed to: George M. Reynolds 1_: S. Hanove~ St. Carlisle. Pa. 17013 I)tWk;NI)ANT Rcspcctfully, ub~nlttcd: Janc Adams, Esquire I.D. No. 79465 ~17 South Hanover St. Carlislc, Pa. 17013 (717) 245-8508 ATI'ORN[~;Y FOR IN,AIN I'IFF YVONNE K. REYNOLDS, Plaintiff VS. GEORGE M. REYNOLDS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 5210 Civil Term 2001 : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 5, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. George M.~ffeynolds, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(ct OF THE DIVORCE CODF 1. I consent to entry of a final decree of 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 divome 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. §4904 relating to unsworn falsification to authorities. Date: George M~Reynolds, Defe~i~da'nt TRUDI L. PELCZYNSKI, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA STEVEN M. PELCZYNSKI, Defendant : CIVIL ACTION - LAW : NO. 01-4965 Civil : IN DIVORCE NOTICE TO RESUME PRIOR S[;RNAME Notice is hereby given that the Plaintiff in the above matter, haven been granted a Final Decree in Divorce on the 19t~ day of December, 2001, hereby elects to resume the prior surname of Balmer, and gives this written notice pursuant to the provisions of 54 P.S. § 704. DATE: Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND ) THIS, the ~ day of ~ ,2001, before me, the ON undersigned officer, personally appeared Tru$i L. Pelezynski (Baimer), known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. Notarial Seal Heather L. Smith, Notary Public Carlisle Boro, Cumberland County My Commission Expires Apr. 7, 2003 Member, Pennsyl 0n e A~sociat on ot NO ~ries IN WITNESS WHEREOF, I hereunto set my hand and official seal. (SEAL) YVONNE K. REYNOLDS, Plaintiff VS. GEORGE M. REYNOLDS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 5210 Civil Term 2001 : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on September 5, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I vedfy that the statements made in this affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. ~K, onne K. Reynolds, Plaintiff / WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c~ OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I vedfy that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.$. §4904 relating to unsworn falsification to authorities. Date: I-- Yvonne K. Reynolds, Plaihtiff 5° 5 C~ YVONNE K. REYNOLDS, Plaintiff VS. GEORGE M. REYNOLDS, Defendant IN THE COURT OF COMMON PLEA, · CUMBERLAND COUNTY, PENNSYLVANIA No. 5210 Civil Term 2001 · ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, delivered on: September 7, 2001. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: January 3, 2002. By Defendant: January 4, 2002. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 4, 2002. §3301(c) Divorce was filed with the Date Plaintiff's Waiver of Notice in Prothonotary: January 8, 2002. Date: Respectfully Submitted: (... - %,, ,,) -. .,...A"" '\ , k ...... ' · /'.J *t ,' ",t.-.J,: _- , - . ,, ' J~TCe Adams, Esquire (' ,,LO. No. 79465 " ....117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .~. PENNA. Yvonne K. Reynolds, Plaintiff VERSUS Geerge M. Rey~olds~ Defen~am~ NO. 5210 Civil Term 2001 Decree iN DIVORCE AND NOW, .~_P_~/u2,~l 17 I DECREED That Yvonne X. Reynolds, , ZO~, IT iS ORDERED AND , PLAINTIFF, AND Geer~e M. Reynolds, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDiCTiON OF THE FOLLOWING CLAIMS WHICH haVE BEEN RAISED Of RECORD IN THIS ACTION FOr WHICh A FINAL ORDEr HAS NOT YEt BEEN ENTERED; BY THE COURT: //7 /7 f ~ .... ~ PROTHONOTARY