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Home My WebLink About02-2230CHERYL LEE REARDON, Plaintiff EDWARD CHARLES REARDON, Defendant : IN THE COURT OF COMMON PLEAS OF : DAUPHIN COUNTY, PENNSYLVANIA : NO. ~. : : CIVIL ACTION - LAW : 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. 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 Dauphin County Courthouse, Harrisburg, PA 17101. 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. Dauphin County Lawyer Referral Service 213 North Front Street Harrisburq, PA 1710] Telephone: (717) 232-7536 CHERYL LEE REARDON, Plaintiff EDWARD CHARLES REARDON, Defendant IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. CIVIL ACTION LJtW IN DIVORCE COMPLAINT IN DIVORCE UNDER ~3301(c) OR }3301(d) OF THE DIVORCE CODE 1. The plaintiff in this action is CHERYL LEE REARDON, an adult individual, who currently resides at 295 Iroquois Trail, York Haven, York County, Pennsylvania, 17370. 2. The defendant in this action is EDWARD CHARLES REARDON, who currently resides at 49 West Emaus Street, Middletown, Dauphin County, Pennsylvania, 17057. 3. Both the plaintiff and the defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were lawfully joined in marriage on June 6, 1995, in Cumberland County, Pennsylvania. 5. There are no children of this marriage. 6. Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken and/or the parties have been separated for a period of two years, having been separated since February 1, 2000. -1- W~EREFORE, the plaintiff requests a decree in divorce pursuant to Section 3301(c) or 3301(d) of the Divorce Code. 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 P.C.S. §4904, relating to unsworn falsification to authorities. Date: ~ ~ ~Oo~ / ~ Cheil Lee Rearaon STONE La I ~'~zabe t h B/S t~ne, Esquire /Supreme CoUrteD #~025[ 414 B~ri_dg/ S~reet, P.O. Box E New Cumberland, PA 17070 Telep~e~17_774_7435 Atto~h~ for Plaintiff -2- fl\div\lmailsrv.aff CHERYL LEE REARDON, Plaintiff EDWARD CHARLES REARDON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-2230 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) ) SS: COUNTY OF CUMBERLAND ) I, Elizabeth B. Stone, of Stone LaFaver & Shekletski, attorneys for the plaintiff hereby certify that I served the Complaint in Divorce in the above captioned matter on the defendant, Edward Charles Reardon, at 49 West Emaus Street, Middletown, PA 17057, by United States Certified Mail, postage prepaid, restricted delivery, on May / 10 2002, as evidenced by the attached Certifie~?Mail return receipts. ' / SWORN TO AND SUBSC.R~BED ELIZA~f~ ~/ STO/E Att~f~9~, ~ La~ NOTARIAL. KAYE R. LIJ(~Y, NOI~ Ful~ postage Cmtlfled Fee Return Receipt Fee {Edorsement Required) $ ~.57 fl\div\lconsentaffidavit CHERYL LEE REARDON, Plaintiff Vo EDWARD CHARLES REARDON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2230 CIVIL TERM : : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on May 6, 2002, and served May 10, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. 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 falsifica- tion to authorities. Date C~ERYL~E REARDON, Plaintiff CHERYL LEE REARDON, Plaintiff V. EDWARD CHARLES REARDON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2230 CIVIL TERM : CIVIL ACTION - LAW IN DIVORCE W]%IVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without 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 falsifica- tion to authorities. Date fl\div\lconsentaffidavit CHERYL LEE REARDON, Plaintiff V. EDWARD CHARLES REARDON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2002-2230 CIVIL TERM : CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on May 6, 2002, and served May 10, 2002. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint 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. 4. 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. 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 falsifica- tion to authorities. Date EDWARD CHARLES REARDON, Defendant CHERYL LEE REARDON, Plaintiff V. EDWARD CHARLES REARDON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-2230 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE notice. 2. I consent to the entry of a final decree of divorce without 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 falsifica- tion to authorities. Date ARD CHARLES REARDON, Defendant fl\div\ltransmitpraecipe\7-97 CHERYL LEE REARDON, Plaintiff Vo EDWARD CHARLES REARDON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-2230 CIVIL TERM : : 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. (Strike out inapplicable section). 2. Date and manner of service of the complaint: May 10. Z002. US Certified Mail, Eeturn Receipt Requested, Restricted Delivery, postage prepaid . 3. Complete either paragraph (a) or (b) . (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff 9-20-02 ; by Defendant 9-20-02 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: ; (2) A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: EOCLAIMSEAIS£D 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 the Prothonotary: ~,~Jj~(o.~)'~_~ ~ 3301(c) Divorce was filed with Date Defendant's_Waiver of Notice in ~ 3301(c~/~ivorce was filed with the Prothonotary: ~- ~L~.O7 . . / ~-~--~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Plaintiff VERSUS Defena~nt PENNA. No. 2002-2230 DECREE IN AND NOW, DIVORCE , IT I$ ORDERED AND DECREED THAT , PLAINTIFF, AND ., 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; PROTHONOTARY