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Home My WebLink About05-5983 HEATHER REAGAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 05- 59~ '] CIVIL TERM WILLIAM REAGAN Defendant 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 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, 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 County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 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 Americans 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 hearing or business before the court. You must attend the scheduled conference or hearing. .. , - HEATHER REAGAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE WILLIAM REAGAN, Defendant : NO. 05- .5 '1 J:j CIVIL TERM DIVORCE COMPLAINT The plaintiff, Heather Reagan, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. ~~3301(c) AND 3301(d) OF THE DIVORCE CODE I. Plaintiff is Heather Reagan, who currently resides at 117 Conodoguinet Trailer Park, Newville, Cumberland County, P A 17241, since September 15, 2004. 2, Defendant is William Reagan, who currently resides at 224 B Street, Carlisle, Cumberland County, PA 17013, since September I, 1998. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing ofthis complaint. 4. Plaintiff and Defendant were married on April 6, 2000 at Mount Holly Springs, Cumberland County, P A. 5. Plaintiff and Defendant have lived separate and apart since September 15,2004. 6. There have been prior actions for divorce or for annulment between the parties. Docket # 04-4560: Plaintiff filed for divorce on September 14, 2004. On November 29, 2004, Plaintiff requested the that prothonotary dismiss this matter without prejudice. 7. The marriage is irretrievably broken. .. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. /1.,..",.- (.' j.~-< '--- Burgess Bradshaw Certified Legal Intern C~' Of}ki ~w~t - Rob . Rains Th as M. Place Anne MacDonald-Fox Lucy Johnston-Walsh Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 " -...... VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date ) l . \ ~ " 0 S/ Plaintiff ct-\ecd:hx r;j){(O.fXDc1.'''- Heather Reagan .' J ~ \:\ ~~ ~, ~ ~ '-'.J L"'- , \ "::-" ~, '''J ~-~~\ ..-; ~';"'- ~, ,. ------ HEATHER REAGAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 05- 59'63 CIVIL TERM WILLIAM REAGAN Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Heather 1. 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. Respectfully submitted, Date 11111{"'- I /<'~_~ {" /tc___ ...._ Burgess Bradshaw Certified Legal Intern J ~<< ROB THO S M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON- WALSH Supervising Attorneys -- aJ~ F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 1:-'1 ~I-=l :~-~ G} 1"<' -' HEATHER REAGAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 05- S'1S"\ CIVIL TERM WILLIAM REAGAN Defendant CERTIFICATE OF SERVICE I, Burgess Bradshaw, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on William G. Reagan, II, residing at 224 B Street, Carlisle, Pennsylvania 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by William G. Reagan, II, on the 26th day of November 2005 as evidenced by the attached green card. / /. /) .- ..J.-t--{~.'""^- l. //.!.-~~t- '"l..-.. Burgess C. Bradshaw Certified Legal Intern ,.. ,/)/d Anne aid-Fox, Supervising Attorney F AMIL Y LAW CLINIC 45 NOIih Pitt Street Carlisle, PA 17013 (717) 243-2968 SENDER corV1PLETE T/-1I'-. I, Tit 1\. . Complete items 1, 2, and 3. Also complete item 41f Restricted Delivery is desired. . Print your-name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece, or on the front if space permits. 1. Article:ft:tressed to: ';;jf- i h.LJ.L.<><'7'1 fi'ut1d fl J, ) if 13 ,Ji/~[l f',7/-l~ot; I pq I/DiS (^'j. ,1, fHI'-; (,f.rT'O~, ON DELIVERY A Signature ... 0 Agent X~ "Ul'/ 'I 0 Addressee B. Received by (Printed Name) C. r ta of ~e'y D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: :sa No 3. Service Type fir Certified Mail o Registered o Insured Mall o Express Mail '-Ef Return Receipt for Merchandise 00.0.0. 4. Restricted Delivery? (Extra Fee) ~Yes Receipt '1tC,n 102595-02-M-1540 ,) -:') -- Heather L. Reagan, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE William G. Reagan, II, Defendant : NO. 05-5983 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. 1 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. S4904 relating to unsworn falsification to authorities. Date 3 - d. fJ - () 0 1!-~~:+\ I Q r ~ IJltQ (Vc:t)U Ms. Heat er L. Reagan, Plaintiff ~\;j C) ';'1 ;"<.,) t,,:... Heather L. Reagan, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE William G. Reagan, II, Defendant : NO. 05-5983 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. r consent to the entry of a final decree of divorce without notice. 2. I understand that r 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. ~4904 relating to unsworn falsification to authorities. Date '5 -8 -00 oQ/4a?m...g ~ ~ WilFam G. Reagan, II, Defendant (") ';'11 :::-1 ; ,~! (.<J r'-.) \!:i Heather 1. Reagan, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW : IN DIVORCE William G. Reagan, II, Defendant : NO. 05-5983 CIVIL TERM AFFIDAVIT OF CONSENT I. A Complaint in Divorce under SS 3301(c) of the Divorce Code was filed on November 18,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 ofthe decree. 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. S4904, relating to unsworn falsification to authorities. 1t:~~plJ~~ 3~C3v' (jl ^ Date 'f (-) -'-n ::,::5 I,; : ,) :-',) c.'.' Heather 1. Reagan, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE William G. Reagan, II, Defendant : NO. 05-5983 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under SS 330i(c) of the Divorce Code was filed on November 18,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. Date j -8-0tR "2Y~..di{. ~7L William G. Reagan, II, Defendant ~ ') U;'} ..... >) :,'; -T~ ;...,') -,~ HEATHER L. REAGAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW : IN DIVORCE WILLIAM G. REAGAN, II, Defendant : No. 05-5983 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under S3301(c) ofthe Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Mr. William G. Reagan, II, on November 26,2005. 3. Date of execution of the affidavit of consent required by S3301 (c) of the Divorce Code: by plaintiff- March 20, 2006; by defendant- March 8, 2006. 4. Related claims pending: none 5. Date plaintiffs Waiver of Notice was filed with the Prothonotary: March 31, 2006. Date defendant's Waiver of Notice was filed with the Prothonotary: March 31, 2006. Date L(-2.I/o(; ~'U F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff :jl ..--1 .r \"",:- -' -..- HEATHER 1. REAGAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE WILLIAM G. REAGAN, II, Defendant : NO. 05 - 5983 CIVIL TERM CERTIFICATE OF SERVICE I, Jill Hammill, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit Record and Divorce Information Sheet on William G. Reagan, II, residing at, 224 B Street, Carlisle, P A 17013, by depositing a copy of the same in the United States mail, first class, postage prepaid, on April 21, 2006. (":U1'~~~ JU}Hammill Certified Legal Intern Anne Mac nald-Fox, Es Supervising Attorney F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 Fax: (717) 243-3639 ) ~. ~+~+~~+~++.+++~~+.+.+.~~++++.+++++.+.~+.++.++.~ . . . . . . . . . . . . . . . . . . . . . . . . + + . . . . . + . . . + . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . + . . . . . . . . . . + . . . + . . . . +. +. +. +. +. +. +. +. +. +. +. +. +. +. +:+ ?+.++++++. ++++++++.+++++++ . . . . . . . . . . . + . . . . . . . . . . . . . . . . . . . . . . . . + + . . . . . '. + '. . . . + . . . + . . + . . . + . + . . . . + . . . + . . . . . . . . . . . . . . . + . . . . . . . . . + + . . . . +.:-;: + + + +. +. + +. +. +. ++.+.~++ +.+:+:+.+.+++ IN THE COURT OF COMMON OFCUMBERLANDCOUNTY STATE OF PENNA. HEATHER L. REAGAN, No. 5983 Plaintiff VERSUS WILLIAM G. REAGAN , II DpfpnrL=lnt DECREE IN DIVORCE ~~'/ ..zc. .;lao " AND NOW, DECREED THAT HEATHER L. REAGAN WILLIAM G. AND REAGAN, II ARE DIVORCED FROM THE BONDS OF MATRiMONY. PLEAS 2005 IT is ORDERED AND , PLAiNTIFF, , DEFENDANT, THE COURT RETAiNS JURISDICTION OF THE FOLLOWING CLAiMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTiON FOR WHICH A FiNAL ORDER HAS NOT NONE f?u..~ + ++.++.++.;+++.+ +Of.'I'Of.'I':+:++ :+: Of. +.:+: +. +.:+: + + ++.++ +. +. + + Of. +. ++. + + +.:+: PROTHONOTARY J. . #7 .2 /'11' ,~- /~1~M., . 7 ~t qr-PHf' ~F;P . jJrJ' !,L' l~ .," L....\. - r/ ,?{/ 'I....f' /~