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Home My WebLink About01-04079IN THE COURT OF COMMON PLEAS RODGER L. LEACH, Plaintiff N O. 01-4079 Civil Term VERSUS LISA A. LEACH, Defendant DECREE IN DIVORCE AND NOW, V~~" ~' ~V', IT IS ORDERED AND DECREED THAT RODGER L. LEACH PLAINTIFF, AND LISA A. LEACH ,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; NONE p.~, , , ~x Rodger L. Leach, Plaintiff .~ .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D / - yv7 g CIVIL TERM vs. Lisa A. Leach, Defendant 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 in 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 Cqurthouse, High and Hanover Streets, 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 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, PA 17013 (717) 249-3166 _ ~ . .. Rodger L. Leach, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. vl-~Fo7y CIVIL TERM vs. Lisa A. Leach, Defendant CIVIL ACTION--LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Rodger L. Leach, who currently resides at 3780 Lot 4 A Spring Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Lisa A. Leach, who currently resides at 213 Pharis Street, Syracuse, New York. 3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on February 20, 1982 at Newport, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to require the parties to participate in wunseling. ' ~ r ~. 'c. 8. Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, Law Office of James K. Jones, Esquire Ja~as'K. Jones, Ewe Attorney for Plaintiff 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 I verify that the statements made in this Complaint are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Rodge~h ' ,..;., L ~ ` ~ ~ , ,. .. ti _ ~ S W Cn a N £S £a w ~ ~ ~ ~~; v ~~,~~~_ Rodger L. Leach, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY; PENNSYLVANIA v. NO. CIVIL TERM Dl- yogy ~~~ !~ CIVIL ACTION- -LAW Lisa A. Leach, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter,affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AE~DAVIT UNDER SECTION 3301 (dl OF THE DIVORCE CODS 1. The parties to this action separated in November, 1984 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 falsification to authorities. Date: bf ~~{~o( Rodger L. ach ~~~sJ~~ r :. c - -~ c . '~. ? ~ `' ._. ~ cif _~_ ;.- c" nJ Cb '~ 3 ~Q a RODGER L. LEACH, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. ~ CIVIL TERM . of-4o7q LISA A. LEACH Defendants : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ~V7/I day of ~GtGhS7 2001, comes James K. Jones, Esquire and certifies that he mailed a true and correct copy of the Complaint in Divorce, Affidavit Under Section 3301 (d) of the Divorce Code and Notice to Request Entry of Divorce Decree in the above-capfioned matter to the defendant by certified mail, restricted delivery. Said return receipt is attached hereto indicating service was made on July 3, 2001. ~, c~ Jame ones, Esquire Atto ey for Plaintiff ~ 7 Irvine Row Carlisle, PA 17013 (717) 240-0296 4 ^ Complete-items t, 2; arrd 3. Also complete item4'rf Restricted Delivery is-desired. ^ Print your name and atldress on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, err on the front if space permits. 1. Article Addressed. to;~ "- ~ i 3 P ha,iz^I s ~+ . S,~ 2~c,uge,, 7-b~, `~( . ,~ 13~-~~ ,s.- 2. Article Number (Copy horn service label) A. Received by ease vant ~reanyJ- n. a of uei C Signature ~- ~A ^ Agent 1 ~/i '~~H ,mil ^ Amara D. Is delivery address different from Item 1? ~ Yea If YES, entei delivery address below: ~ Nc 3. Service Type ^ Certifietl Mail ^ Express Mail ^ Registeretl ^ Return Receipt for Merchantlise ^ Insured Mail ^ C.O.D. 4. flestricted Delivery? (Extra Feel _ 1~yes IUIy 1999 DamaestlG fleturn Receipt 102595-00-M-0952 n c `r O "a ~- i =~ - ~ ~ ' ...- ~ < r .: U .,3 ~ i- r c_--~.- ~ C °=w t ,: yC cz' Oo v, O~~ IN THE COURT OF COMMON PLEAS RODGER L. LEACH VS. LISA A. LEACH CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. O1-4079 CIVIL TERM PRAECIPETOTRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under~~~ 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mail, restricted delivery, return receipt requested service on July 3- 2001 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 by defendant (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: June 28 , O 1 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on June 29 2001; served on July 3, 2001 4. Related claims pending: 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: served on July 3, 2001 by certified mail, restricted deliver: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Attorney for Plain' Beiendant- n ~ _, ~ ~,p ~~-, ~.~ . Wit _ ~~~ _a~ - ~~ -, ~ ~ ti ~ ~ ~~ cr' •.r~ a ~ ~ -~ Rodger L. Leach, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION- -LAW Lisa A, Leach, Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECRF_.E TO: Lisa A. Leach: You have been sued in an action for divorce. You have failed to answer the complaint or file acounter-affidavit to the §3301 (d) affidavit. Therefore, on or after July 23, 2001, the other party 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 acounter-affidavit by the above date, the court can enter a final decree in divorce. Acounter-affidavit whic}~ you may file with the prothonotary of the court is attached to this notice. 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 for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU CO NOT HAVE A LAWYER OF 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, PA 17013 (717) 249-3166. ,~_.. ~. ~~ 1!~ V1 4'Q A c' ~'J r-r m r: ~ ~ '_ T: ~. a =' --~' i_ = { _ G t2~ ~~5' stn ,. _w,•+r . ;:.,;._„ s -`+!*P'%A`-?eFb- .~ r(.::.;. 1:,,:s~^nri~.'. ~~~~~F~ mow,, IN THE COURT OF COMMON PLEAS RODGER L. LEACH CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL DIVISION LISA A, LEACH ~ CIVIL TERM NO. O1-4079 To the Prothonotary: PRAECIPETOTRANSMIT RECORD 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) 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified mailer restricted deliverv. return receipt requested service on July 3, 200T 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 by defendant (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: June 28 , O 1 (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on June 29, 2001; served on July 3,,2001 4. Related claims pending: none 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: served on July 3, 2001 by certified mail, restricted delivery. Defendant'sCounter-affidavit dated 8/19/01 and filed 8/21/01, (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in §3301 (c} Divorce was filed with the Prothonotary; Attorney for Plaintiff / 6efendant C:~ r_. - ~ ~ -~ ~. 'on rn r'r ~~ _ - ~~. ~~ :.~ - ~d.. _ - N :~,_, C N -= cr .~ 0 v ~S Rodger L. Leach, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA • Ol-'to~9 NO. CIVIL TERM v. CIVIL ACTION- -LAW Lisa A. Leach, Defendant IN DIVORCE COUNTER -AFFIDAVIT UNDER §3301 (~ OF THE DIVORCE CODE 1. Check either (a) or (b) (a) I do not oppose the entry of a divorce decree. _ (b) I oppose the entry of a divorce decree because (Check (i) , (ii) or both) (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b) (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, divisions of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 falsifications to authorities. Date: ~ -l (~ ~ y~X~V~~\:~~ :J~iV ~ Lisa A. Leach NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER - AFFIDAVIT. C~ ~; r~. ~Ti CI' ~~ 7 C,'. ~ ~l. N r_ ~" ,C. _ c° ~_ ~7 1 ~,. y ~_ '~ .~ ,,~ <<' _`, ~ ~ ~~ c~.J-' C ~3