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Home My WebLink About06-0674 . . Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JAMES P. REED, v. : CIVIL ACTION - LAW Defendant :NO.06- 07/f : IN DIVORCE CIVIL TERM ST ARLENE A. REED, NOTICE 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 at the Cumberland County Court House, High and Hanover Streets, Carlige. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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, P A 17013 Phone: (717) 249-3166 . JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 06- l7<f : IN DIVORCE CIVIL TERM ST ARLENE A. REED, COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is James P. Reed, who currently resides at 119 Petersburg Rd., Carlisle, South Middleton Township, Cumberland County, Pennsylvania, 17013. 2. Defendant is Starlene A. Reed, who currently resides at 315 Chestnut Street, Mt. Holly Springs, Cumberland County, Pennsylvania, 17065. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on September 26, 1987 in Panama, New York. 5. Plaintiff and Defendant separated on or about September 1,2005. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. . 9. Neither party is now serving in the United Armed Forces, but Plaintiff served in the United States Armed Forces from 1981 until 1985. 10. Plaintiff requests the Court to enter a Decree in Divorce. Paul Bradford Orr, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, P A 17013 (717) 258-8558 Supreme Court ID # 71786 By: . VERIFICATION I 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. S 4904, relating to unsworn falsification to authorities. DATE: 2- /- c:/c'" y e (') ~~ 7J w c c~ (") 'vt ~'.> c:; (.;,;r~ ~'" 1tF. '\t ~ -,., ::;1 T"'>J Co i::,;'l::D , _ r- '8. _f!.fT"1 ~ ',\> -')T v-.) :5: Y"."'<> .J';, , 0<;> , " -0 v -.>0 )?l; ...."., ~ ,~ - 0 '0 - , ~ 1'1 .' -, '0 i,,. CO .~/J -~ .~ , JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW : NO. 06- ~ ~ ~ CIVIL TERM : IN DIVORCE v. ST ARLENE A. REED, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 2ND day of February, 2006, Robin l. Starner served a true certified copy of the Divorce Complaint, executed by the Plaintiff in the roove-captioned matter, upon Starlene A. Reed by hand delivery on February 2, 2006, in the Law Office of Paul B. Orr at \ '. \ z... pm, Dated: Dated: 011';) loCo C? ~kv..~--< Starlene A. Reed [t~~ o ~; <. -o~j~ :T~r: ~_. ,-: D.::-._; "", C:::3 = cr- o '"1' ..., rt1 o;J I W v -".." r:-? Ul l...,I;J JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ST ARLENE A. REED, : NO. 06-674 Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) & (d) of the Divorce Code was filed on February 2,2006. 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: S- 2/- aCe ~-I t:~j / James P. Reed () ~ -of'" r"n r' ~.>' I'..;) = = CT" C- c= ..... o ." :r n~-n 'F -om ~p? ':J,f-') .':-~ f 1 ,~~ :!" ''''-(') ~'5m :::::.\ ~ .< -v ...,.~ N C) 0" JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW ST ARLENE A. REED, : NO. 06-674 Defendant : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) & (d) OF THE DIVORCE CODE 1. I consent to the 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 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 - Z / - 0 Ce (") ~ -0('. ",6,. "".'" . ...::-. --' 2~ I (j) -<" r-:> c::::> = c:T" '- c: :.c --. v ~ ~-n rT'lF': :t"p:1 g"-( l.J r' -\~:..-:,' (:'7 -t~'l ~J. (") am :;;; .;0 -< ~ o 0'''' JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LA W STARLENE A. REED, : NO. 06-674 Defendant : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) & (d) of the Divorce Code was filed on February 2,2006. 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: q.:?sj()(P J~J (j.I?ud_ Starlene A. Reed -, (") (; ~ -0""=' mY' ;;,' ' (j) r"-:; ~.~;~ :~ r-.) = = c;T" '- c:: z -(:) ....".. ~ Q. ~~ -om :.tje? {~, , ~~(~; t/G :;:-I ~ r:-? (::) 0" JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW STARLENE A. REED, : NO. 06-674 Defendant : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) & (d) OF THE DIVORCE CODE 1. I consent to the 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 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: \S/ a.3/()(p " ' xffuh<< I . {L f!ad. . - Starlene A. Reed r-..:l = c;;:> cr <-.:: c_ -.,,.... ....... - o -n ~-n rnr=: -cl\;!\ .,on "-r~ \l!.~~; ;;~q 9,' 55 ..('. -0 > rv ., o cJ" JAMES P. REED, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. STARLENE A. REED, : NO. 06-674 Defendant : IN DIVORCE 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: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) & (d) of the Divorce Code. 2. Date and manner of service of the complaint: February 2, 2006, by hand delivery, Affidavit of Service filed with the Courthouse on February 3,2006. 3. Date of execution of the affidavit of consent requ ired by Section 3301(c) & (d) of the Divorce Code: by the Plaintiff on May 21,2006; by Defendant on May 23,2006. 4. Related claims pending: NONE 5. Date Plaintiffs Waiver of Notice in ~3301 (c) & (d) Divorce was filed with the Prothonotary: June 1,2006. 6. Date Defendant's Waiver of Notice in ~3301(c) & (d) Divorce was filed with the Prothonotary: June 1, 2006. LAW Paul Bradford Orr, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 Dale:~( I/~ By: (") C =:';;. ~... wJ ~~.c /"-..) = (:;:;:) c:r- c_ C:c: ....,,-.-. o t1 :::;j Rill r- tB ~l :-_J :,:.'::....{,: ':4(-~ c:sm ;r-;~ S;J .< ;? ~') o en ;l;iIiili iIi ;I; Eli E1i;l;iIiili iliiliili~ ~~~iIi~ iIiiliiliili iIiili iIi iIiili iliiliiliiliif. iIi Eli ~EIiili IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY JAMES P. REED PENNA. STATE OF Plaintiff VERSUS No. 06-674 START.F.NF. A REED Defendant DECREE IN DIVORCE '1~ AND NOW, " 2..00," , IT IS ORDERED AND DECREED THAT James P. Reed , PLAI NTI FF, AND Starlene A. Reed , 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; ou;;J PROTHONOTARY iIi ~iliiliili~~iIi~iliili~iliiliili~~~iIi~~~~iIi~iIi~ iIiili iIiili iIi ~ ~~~ J. --Jr;~~~ ~P$~~'P'l '- . . . t " 'l' . .' ::" 1() "?/41 '9~' ,//- ~