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Home My WebLink About95-03163 ~ .ct' Ci -; <.-- ",' ~ ,C:fJ ~ ~ / r i i 'l ~ ~ j (Y) -' _ i (Y) , __. REAGER & ADLER, PC AlTORNEYS AND COUNSElORS AT lAW ABA C US LDl.d') Ill! MARKlT SIRIIT CAMP HilL PI'lNSVLVANlA 17011,'601 111-761-1181 mirA)( 111,110,1166 THIODORE A ADLU'+ DAVID IV, RfAGIR DURA A. DINISON THOMAS 0, WILLIAMS SUSAN H. CONrAIR R1rLYTO: r,o, 80R 191 HARRISBURG, PA 111 08,0191 July 25, 1995 MONICA D. ZIRClHR ltCII AUIII.nt -Allo admiltfd 10 D.C. Ba, Mr. H. Ronald Reigel, Jr. 2640 North Third street Harrisburg, PA 17102 ReI Reigel v. Reigel No. 95-3163 I Cumberland county Dear Mr. Reigel: Attached please find Mrs. Reigel's Affidavit for a divorce, a Counter-Affidavit and the Notice of our intention to file for the finalization of divorce twenty days from the service of this lettet.. If you do not file the counter-Affidavit with the courthouse, we will proceed with the divorce. 'iours,truly, 2) J~,. ~ V \ , , Debta- A-:' Denison DAD/wlb Attachments CCI Mrs. Tamar Reiqel (w/o attachments) + Certified as a CI,'II Trill Specllllll by the Nltlona' SOlid 01 Trill Ad.oclcy, A Pennlyll'anla Supreme Court Accredlled A,.ncy REAGER , ADLER, PC BY' DEBRA A. DENISON, ESQUIRB Attorney I.D. No. 66378 2331 Market street camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff TAMAR REIGEL, I IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . . v. 95-3163 CIVIL TERM H. RONALD REIGEL, JR., Defendant IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TOI H. Ronald Reigel, Jr. You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiff's affidavit. Therefore, on or after August 16, 1995, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter- affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask fpr economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE IHTH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. yOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANIlOT AFFORD OIlE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIIlD OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor cumberland County Courthouse carlisle, PA 17013 (717) 240-6200 ~ r .EP ,) 3 09 fH '95 "I ! ~ lCf ;hUH I> 'II' I ~ ~ . REAGER . ADLER, PC ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011,.8.2 17171783,1383 t..,,_ .- ....,.....--~_.. '_.~.'''~ t' ',- REAOER . ADLER, PC BYI DEBRA A. DENISON, ESQUIRE Attorney 1.0. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff TAMAR REIGEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA "11 3' I ~,j { I.,'; (0 k-,,,-, v. H. RONALD REIGEL, JR., Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the olaims set forth in the following pages, you must take prompt aotion. You are warned that if you fail to do so, the oase may prooeed 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 olaim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, inclUding oustody or visitation of your ohildren. 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, Room 101, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER I S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE TilE RIGIIT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT IIAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL HELP. Court Administrator 4th Floor Cumberland County Courthouse CarliSle, PA 17013 (717) 240-6200 REAO!R , ADLER, PC BY: DBBRA A. DENISON, BSQUIRE Attorney 1.0. No. 66378 2331 Market street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff TAMAR REIGEL, I IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 'i 'J - 11 l,. :~ (( v ,~..' r;.. c.. -'0.-.. H. RONALD REIGEL, JR., Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Tamar Reigel, is an adult individual who may be contacted through Debra A. Denison, Esquire, 2331 Market street, camp Hill, Cumberland County, Pennsylvania, 17101, as P1aintiff's address is confidential due to an outstanding Protection from Abuse Order. 2. Defendant, H. Ronald Reigel, Jr., is an adult individual who currently resides 2640 North Third street, Harrisburg, Dauphin county, Pennsylvania, 17102. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately prior to the filing of this complaint. 4. Plaintiff and Defendant were lawfully married on November 24, 1978 at Middletown, Dauphin County, Pennsylvania, 17057. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United states or its allies within the provisions of the Soldiers' & sailors' civil Relief Act of the congress of 1940 and its amendments. 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 and declines that right. 9. After ninety (90) days have elapsed from the date of the filing of this complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 10. The parties have been separated since June 1991. 2 WHEREFORE, Plaintiff requests that this Honorable Court enter a decree of divorce pursuant to section 3301(c) or seotion 3301(d) of the Divorce Code. Respectfully submitted, RBAGBR , ADLBR, PC Date. June 11, 1..1 B8QUIRI 3 VERIFICATION I, Tamar Reigel, verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subjeot to the penalties of 18 Pa.C.S. section 4904, relating to unsworn falsification to authorities. ~ \ , \,~, J Q..,vJ" () J ~ 1 . k1Z.t ~l Tamar Reigel V Datel ~ I / I JUH 13 I 54 I'H '95 , ';'\:l vi -:ii ') (,IH. " , .'~" ," ' '.'hi "_' '_ l,t~.J i, ,j" ! I f1"~.. ,_ d. 1 .\ I ; by /)r "7.l' JI ,) J ,'I /L!. ~, I r{i .)1 (II. 1')7~ ) ) If j 13 l 'll f)' S r j 1:1 READER 110 ADLER, PC AlTORNEV5 AT LAW 2331 MARKET STREET CAMP HILL, PA 11011-4642 11111163,1383 .a.... .- ~.~~... '._'- . .... ..... \ \ , "Wi I;' lJ 2 110 fH '95 -', (~t' ,,\ "hI . I" READER 81 ADLEA, PC ATTORNEYS AT LAW 2331 MARKET8TREET CAMP Hill, PA 17011-4642 1ll71763'1363 ~ ;..----.'-:---"....,. , , - ~._~ \ \ p' . JUL ZG 3 21 rK '95 I-i- "'ji .J;"! ~f\) if REAGER . ADlER, PC ATTORNEVS AT LAW 2331 MARKET SIREET CAMP Hill, PA 1101 Hel2 11111783,1383 ,.-