HomeMy WebLinkAbout05-4806
II
DANIEL S. REARICK,
Plaintiff
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
EVAN S. REARICK,
Defendant
CIVIL ACTION - LAW
NO. 05- l../ ~ ({,CIVIL TERM
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 Court House
1 Courthouse Square
Carlisle, Pennsylvania 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
I
II
DANIEL S. REARICK, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 05- yf{)f.. CIVIL TERM
EVAN S. REARICK, )
Defendant ) 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.
2
II
DANIEL S. REARICK, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVIL ACTION - LAW
)
) NO. 05- lfftJl.. CIVIL TERM
EVAN S. REARICK, )
Defendant ) IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, DANIEL S. REARICK, by his attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is DANIEL S. REARICK, an adult individual who currently resides at
403 Cascade Road, Mechanicsburg, Cumberland County, Pennsylvania.
2. The Defendant is EVAN S. REARICK, an adult individual who currently resides at
245 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide residents of the Common-
wealth of Pennsylvania for at least six months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on 1 November 2003 in Mechanicsburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. This 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.
3
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8. The Plaintiff requests this Court to enter a Decree of Divorce.
WHEREFORE, Plaintiff requests this Court to enter a decree in divorce pursuant to the
Divorce Code of Pennsylvania.
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Sauel L. Andes
Attorney for Plaintiff
Supreme Court ID 17225
525 North 12th Street
Lemoyne, PA 17043
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: CJJ1 /;3/;20(/)1)
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
DANIEL S. REARICK,
PLAINTIFF
CIVIL ACTION - LAW
NO. 05-4806 CIVIL TERM
EVAN S. REARICK,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
Please enter my appearance on behalf of the Defendant EVAN S. REARICK in the
above matter. I hereby accept service of the Complaint on her behalf.
Date: S~/I'1~/ /1 Z&t?5'
Andrew C. Sheely, Esquir
Attorney for Defen nt
Supreme Court ID # 62 LJ (, f
127 South Market Street
P.O. Box 95
Mechanicsburg, PA 17055
(717) 697-7050
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DANIEL S. REARICK,
Plaintiff
vs.
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IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-4806 CIVIL TERM
EVAN S. REARICK,
Defendant
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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceotance of Service filed by Plaintiff's
counsel indicatinq service on or about 19 Seotember 2005.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of
the Divorce Code: By Plaintiff: 27 Januarv 2006 By Defendant: 20 January 2006
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
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 in Section 3301 (c) Divorce was filed with
the Prothonotary: Dated 27 January 2006 and filed contemooraneously herewith.
Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 20 January 2006 and filed contemooraneously herewith.
Date: 27 January 2006
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Attorney for Plaintiff
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II
DANIEL S. REARICK,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
CIVIL ACTION - LAW
NO. 05-4806 CIVIL TERM
EVAN S. REARICK,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
15 September 2005 and served upon the Defendant on 19 September 2005.
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 Ie) 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.
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Dated: .
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DANIEL S. REA
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II
DANIEL S. REARICK,
Plaintiff
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vs.
EV AN S. REARICK,
Defendant
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 05-4806 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 15
September 2005 and served upon the Defendant on 19 September 2005.
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 REOUEST 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 Fa. e.S. Section 4904
relating to unsworn falsification to authorities.
11d-D IO(i?
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Dated:
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
DANIEL S. REARICK,
No.
2005-4806
PI.-;nt;ff
VERSUS
EVAN S. REARICK,
Defendant
DECREE IN
DIVORCE
AND NOW,
rc6",. -.,
DANIEL S. REARICK
z-z- -P
2006
., IT IS ORDERED AND
DECREED THAT
, PLAINTIFF,
AND
EVAN S. REARICK
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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++++++++'1'+'1''4'+'4'++++++'++'++'++++?
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;
NONE
PR
HONOTARY
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