Loading...
HomeMy WebLinkAbout99-05219-w;? -?;. ,?. ;?. ,. ?,< >;;,? f S? -'' """I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF y; r PENNA. nriANF r r Fnn r-- p7 ATNTiFF No. 9q_c 71 q cyjj.TL E M VERSUS -MA17TTUA T T Ppin DEFENDANT DECREE IN DIVORCE AND NOW,_ 2001 IT IS ORDERED AND DECREED THAT nriA NF i TFRn PLAINTIFF, AND MARTINA L. LEBO ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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 T ATTEST: J PROTHONOTARY yap el ?0?- ., ? Z ah4_ HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 1701 (717) 243-6090 ATTORNEY FOR PLAINTIFF DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - 5219 CIVIL TERM Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: decree: Transmit the record, together with the following information, to the court for entry of a divorce Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about September 2, 1999, defendant was served with a copy of the divorce complaint via certified mail, "restricted delivery", addressed to the defendant at 4544 Duffield Road, Chambersburg, PA 17201, with return receipt number Z 339 062 125. 3. Complete either paragraph (a) or (b) (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: AfYeiL 10 , 2001. By the defendant: Ap,QA(--mac, 2001. (b)(1) Date of execution of the attidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: NIA. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file preecipe to transmit record, a copy of which is attached: NIA (b) Date plaintiffs Waiver of Notrice in Section 3301(c) divorce was filed with the Prothonotary: Aofitrc 3, 2001. Date defendant's Waiver of Notice in Section 3301© Divorce was filed with the Prothonotary: 4oA+L 1.g_, 2001. ??L 23 ,2001 HAROLD S. IRWIN, III Attorney for Plainti. r wn 1_) L. J , LL U co C7 N .G 7 t7 U HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 25820 35 EAST HIGH STREET CARLISLE PA 17013 (717) 2434050 ATTORNEY FOR PLAINTIFF DUANE L. LEDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - sa is CIVIL TERM Defendant : IN DIVORCE 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 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - .5.2 / 9 CIVIL TERM Defendant : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, Duane L. Lebo, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce, against the defendant, Martina L. Lebo, representing as follows: 1. The plaintiff is Duane L. Lebo, an adult individual residing at 661 West Old York Road, Cumberland County, Pennsylvania 17013. 2. The defendant is Martina L. Lebo, an adult individual residing at 4544 Duffield Road, Chambersburg, Franklin County, Pennsylvania 17201. 3. Both parties have been residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this action in divorce. 4. The parties were married on November 5, 1991, in Virginia. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers that the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. 7. There has been no prior action for divorce or annulment between the parties. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. August 25, 1999 , o,,-? DUANE L. LEBO Plaintiff HAROLD S. IRWIN, Attorney for Plainti DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. . : CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - S- 9 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. August25, 1999 aa?e-,'Zz ?„ DUANE L. LEBO Plaintiff t-? H 'tA Z E F w .r n o M 41 m Z ti O V I > U .,.I k r N T 5? W 2 R¢ po U O UO 4 U ?Q H? o&i H w ti1 O > a > 0 ? k i ?N M? tou A O W 2 =Z N N c?pp M a Q ? n4 y+WA b? ? aN I a ? W W j UV a a ?7 Q C h y { V E It O Q W z z ~ o M DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99.5219 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 26, 1999 and served upon defendant on or about September 2, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. APoea( 2001 i/?live6? .?V.rJ? DUANE L. LEBO u _ Q r.?ti 0 o U DUANE L. LEDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99-5219 CIVIL TERM Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. 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. Section 4904 relating to unsworn falsification to authorities. )SAR-1 1-. 20 , 2001 & /-r DUANE L. LEBO L ?. N Z 2 rpaa. O O DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99.5219 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 1 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. 8. 1 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. Section 4904 relating to unsworn falsification to authorities. /?JPti t L , 2001 DUANE L. LEBO L u;.. N j ` z _ L4 c-. p U DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - 5219 CIVIL TERM Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 26, 1999 and served upon defendant on September 2, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Af t[ c, f&, 2001 eCl n I ()ir,TC9-- MARTINA L. LEBO } w r? _i 4 . C _ . . ., CZ) v 3 CL ,fW aj a t-' o U DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - 5219 CIVIL TERM Defendant : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. O,2001 \, 1bn,. cy. 3,a C MARTINA . LEBO 'l OZ C) ; L J4 t l ?.. Cl) G N LZ J O V DUANE L. LEDO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - 5219 CIVIL TERM Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DE REE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. Section 4904 relating to unsworn falsification to authorities. /7Pi?t 2001 MC\t1-jGmO.. Ra r)n MARTIN L. LEBO i O C C : u7] n. ga ? U HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 28820 35 EAST NIGH STREET CARLISLE PA 17013 (717) 243-8080 ATTORNEY FOR PLAINTIFF DUANE L. LEBO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW MARTINA L. LEBO, : NO. 99 - 5219 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about September 2, 1999, by certified mail "restricted delivery", addressed to her at 4544 Duffield Road, Chambersburg, PA 17201, certified mail, return receipt No. Z 339 062 125. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. AMI(, 7_0, 2001 Harold S. Irwin, III Attorney for plaintiff SE . Canp«. n m., .near 2,or adauorw le,waa. C o mpf.te n.ms s 4¦ and 4b I also wlah to receive the ? ? re , , , Paid bpur sme W address pre tM,weerss of Ws form so that we oan return ItYa following services (Mr an extra fee): 'pqMatraa0c,h felt n form to the sow of IM mei OCO. Of M tM bark it eWM 'A ' lef space doe" net 1. ? Addressee's Address a alum Receipt Raeuesred an the mWpleos below the article number. e1M Rot= Receipt will Now to whom ma article was delivered end the due KID Restricted Delivery delverod' ConeUlt Ix161fila9tef for tae. 3. Article Addressed to: 4a. Article Number i88 TIN Z 125 CCC E A L L1180 4 DUFFIE 4b. Sefvice Type LD RD r ? Registered }g Certifi HAMBERSBURG PA 17201 ? Express Mail ? Insured ? Rehm Receipt for Merchandise ? COD 7. Date of Delivery 5. R W By: (Print Neme) 8. Addressee's Address (Only If nested • and fee Aa pald) g 8. Slgnatur . A ressee orAgent) PS Form 3911, d kember 1894 102595.978-0179 Dnmastic RR111m Rart•Int l' to -0 'gyp i Ln Cj v Ln w : r- 1` a I d .01 1 M 1J d l U r Al N N ~"m''u5 9N aL u MQZC r ? e • i _ a w ? r 0 ? LL r 2 ? p g O m 'e m ?y3 SI b q '$ A p ? .a a o u c2? c` ?y 0 Jf L ¢ X.p b 1! ? &$ ? ` Eg i ? $ d J ?- ? a r mow.. v UUVb-, " I ? Cl) a O U