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HomeMy WebLinkAbout07-0125STEPHANIE A. REEDER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.2007- RICLON T. LINDSEY : CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO PLEAD You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 32 South Bedford Street Carlisle, Pennsylvania 717-249-3166 1 46 STEPHANIE A. REEDER : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2007- AW Cca:! T RICLON T. LINDSEY : CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT Plaintiff, Stephanie A. Reeder, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, Stephanie A. Reeder, is an adult individual residing at 171 West North Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Riclon T. Lindsey, is an adult individual residing at 51 Leeds Road, Newville, Cumberland County, Pennsylvania. 3 Plaintiff and Defendant were married in Cumberland County, Pennsylvania on April 29, 2006. 4 Both Plaintiff and Defendant have resided continuously in the Commonwealth of Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of this action. 5 There have been no prior actions of divorce or for annulment between the parties. 6 The marriage is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing her from the Defendant. BROUJOS & GILROY, P.C. By Hubert X. Gi oy, Esquire Attorney for Plaintiff Broujos & Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 717-243-4574 VERIFICATION I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. 4 [fit 1w, a &L-",, Steph ie Reeder Cr I v `moo r © q l 7? r ?, C? C? , T? f(--i F:\FUM\DATAFa&\GenermACurmnt\12593\12593.I.consent atBdAM Created: 9/20/04 0:06PM RevLxd: 5/4/07 3:17PM Hubert X. Gilroy, Esquire I.D. No. 29943 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff STEPHANIE A. REEDER, Plaintiff, V. RICLON T. LINDSEY, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007-125 CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on January 8, 2007. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about January 17, 2007. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: U U " l? G Steph ni A. Reeder/Plaintiff i i ,1 i RECEIVED MAY % w 2007 A 0 A n-I. -'r'Nn1 .? F.\FILES\E)ATAFILE\Gcncral\Current\12593\12593.Lcustodystiputation Created: 9120/01 0? 05 PM + Revised: 5407 2:39PM Hubert X. Gilroy, Esquire I.D. No. 29943 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff STEPHANIE A. REEDER, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-125 CIVIL ACTION - LAW RICLON T. LINDSEY, Defendant IN DIVORCE CUSTODY STIPULATION The parties to the above-captioned action hereby agree and stipulate that the Court may enter an Order on the custody issues in this case as set forth in the Court Order attached hereto. L?' ka" Riclon T. Lindsey Step a A. Re er 111-04 Date Date c- C ?;!. -a r.' i ,?:?- ? f _- ?` ; t a? ..-? xC". ?* ?p,• 44+ k..i ?} ?. r•? --? + F..f1LES\C1ierus\12593 S Reeder\12593.1. custody order Created: 9/20/04 0:06PM Revised. 1/25/08 1:01 PM Hubert X. Gilroy, Esquire I.D. No. 29943 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff AN s12008 ? STEPHANIE A. REEDER, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007-125 CIVIL ACTION - LAW RICLON T. LINDSEY, Defendant IN DIVORCE COURT ORDER AND NOW this 1`76- day of E , 2008, upon consideration of the attached Stipulation which has been signed by the parties, it is ordered and directed as follows: 1. The father, Riclon T. Lindsey, and the mother, Stephanie A. Reeder, shall enjoy shared legal custody of Brayden T. Lindsey, born March 11, 2005. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child pursuant to a schedule as worked out between the parties. 4. In the event the father at any time becomes dissatisfied with the amount of visitation afforded to him or if the father otherwise wants to modify this Custody Order, the father may petition the Court to have the case scheduled with a Custody Conciliator for a conference. cc: /tibert X. Gilroy, Esquire Riclon T. Lindsey \ BY THE COURT: J. VlNtffi,?hSNP43d ' " ., ; `fly 0 S =& WV ' 88OZ I0rj AbYlON H-Odd 3Hi q0 nl?C&CMI4 F:\FILES\Clients\12593 S Reeder\12593.1.Affidav.ser divorcr.wpd Created: 9/20/04 0:06PM Revised: 2/13/08 2:58PM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff STEPHANIE A. REEDER, Plaintiff V. RICLON T. LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA NO. 2007-125 CIVIL ACTION - LA IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter as served on Defendant Riclon T. Lindsey, by certified mail on January 18, 2007. A copy of t je. Ce rtified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked E bit A. DATE Sworn and subscribed before me this R Hu ' ilroy, Esquire Attorney for Plaintiff Martson Deardorff Williams Otto 10 East High Street Carlisle, PA 17013 (717) 243-3341 COMMONWEALTH OF PENNSYLVANIA Nota: ial Seal Shelly Brooks, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 5, 2009 Member, Pennsylvania Association of Notaries & Faller ru - - -- Ln 1. 4 C? Co O M Y 6 M m ?' PI-Cs Cr 51 heeds Road ._J C3 ?Newville, PA 17241 UNITED STATES POSTAL SERVICE First-Class :Ma 08 USPS 9e $ Permit No. '10 • Sender: Please print your name, address, and ZIP+ 4 in this box • Hubert X. Gilroy, Esquire BroujOs & Gilroy, pC 4 N. Hanover Street Carlisle, PA 17013 Reeder .1 r ,. ¦ Complete Items 1, 2, and 3. Also complete item 4 if 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 mailpiece, or an the front if space permits. 1. Article Addressed to: Mr. Riclon T. Lindsey 51 Leeds Road Newville, PA 17241 A. Signature r ? Agent X ? Addressee Di?e of,Delivery B. ed by (Pri ted N lt? D. Is delivery address dfflerent iron item l? ? Yes If YES, enter delivery address below: ? No 3. Serv ce Type Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) es 2. Article Number Certified No. 7099 3400 0018 5046 2666 (Transfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 EXHIBIT D s ' ` rv -TI ? '3 Hubert X. Gilroy, Esquire I.D. No. 29943 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff STEPHANIE A. REEDER, Plaintiff, V. RICLON T. LINDSEY, Defendant. : IN THE COURT OF : CUMBERLAND COI : NO. 2007-125 : CIVIL ACTION - LA? IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTRY OF A DIVORCE DECREE Ur 1. 2. 3. 4. A Complaint in divorce under Section 3301(C) of the January 8, 2007. MON PLEAS OF , PENNSYLVANIA Code was filed on Defendant acknowledges receipt and accepts service of the ''Complaint on or about January 17, 2007. The marriage of the Plaintiff and Defendant is irretrievably ?roken and ninety days have elapsed from the date of the filing of the Complaint. I consent to the entry of a final decree of divorce without 5. I understand that I may lose rights concerning alimony, divisi?n of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. 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 I,after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counselin and understand that I may request that the Court require counseling. I do not reque that the Court require counseling. I verify that the statements made in this affidavit are true an 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: w? c^ Riclon T. Lindsey/Dlefendant _ ..sue . v F:\F1LES\CHents\12593 S Reeder\12593.1.Praecipe.div.wpd Created: 9/20/04 0:06PM Revised: 2/13/08 2:41PM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff STEPHANIE A. REEDER, Plaintiff V. RICLON T. LINDSEY, Defendant IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA NO. 2007-125 CIVIL ACTION - LAVA IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the decree: 1. Ground for Divorce: Irretrievable breakdown under S ()3301(d)(1) of the Divorce Code. (Check applicable 2. Date and manner of service of the Complaint: January 18, Receipt Requested . 3. Complete either paragraph (a) or (b). for entry of a divorce (X)3301(c) 1.) by Certified Mail, return (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff. May 7, 2007; by Defendant: April 4, 2008. (b) (1) Date of execution of the Plaintiffs affidavit required Divorce Code: _2) Date of service of the Plaintiffs affidavit upon the 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file a copy of which is attached: Section 3301() of the pe to transmit record, 2008. (b) Date Plaintiffs Waiver of Notice was filed with the (b) Date Defendant's Waiver of Notice was filed with the Hufert X. Gilroy, F Attorney for Plai Martson Deardo f Carlisle, PA 1 13 717-243-334 May 7, 2007. : February 14, Otto Gilroy & Faller c? ?,, ?..? ? "'-f ' !"7 f?'? '? +,??J ?7.' ? ,Z ? . r.'?-?'wy? .:_ . C .i .. ?' ,,, ? F' ? .. `?- "'? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STEPHANIE A. REEDER, 2007-125 NO. VERSUS Defendant DECREE IN DIVORCE AND NOW, yc ed4r`y 1O , 1?0 , IT IS ORDERED AND DECREED THAT STFPHANTF A RFFnFR , PLAINTIFF, AND RICLON T. LINDSEY 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: PROTHONOTARY 1,2 -