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HomeMy WebLinkAbout07-3310IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. C) - 33? ?tu c LI-Ts Plaintiff VS. MICHAEL A. LEIB, . Defendant ACTION 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 1 Courthouse Square, 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 ENTERED, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMAION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 717.249.3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, Plaintiff VS. MICHAEL A. LEIB, Defendant No. 0'T- ?31d ACTION IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, this 1 st day of June, 2007, comes Kelly M. Leib, Plaintiff, by her attorneys, Ann Marie Rotz, Esquire and Beauchat & Beauchat, LLC, and states the following Complaint: 1. Plaintiff is Kelly M. Leib, a sui juris female, with a residence of 1282 Fourth Avenue, Chambersburg, Franklin County, Pennsylvania 17201, since May 5, 2007. 2. Defendant is Michael A. Leib, a sui juris male, with a residence of 134 Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257, since. 3. Neither Plaintiff, nor Defendant is a minor or incompetent. 4. Plaintiff and Defendant have been a bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. The parties were married on April 1, 1995 in Waynesboro, Franklin County, Pennsylvania. 6. There have been no prior actions for divorce or annulment in this matter. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling, and that she may have the right to request that the Court require the parties to participate in counseling. may have the right to request that the Court require the parties to participate in counseling. 9. Neither party is an active member of the armed forces of the United States of America. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Respectfully Submitted, BEAUCHAT & BEAUCHAT I-iA Ann are Rotz, Esq. 63 West High Street Gettysburg, PA 17325 717.334.4515 ID 201480 Attorney for Plaintiff VERIFICATION 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 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: C, A , 2007 Id A lly i W r-, O ?- ' w C3 rn y t cr, uz IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07 __?31o (21'U"L ` E Plaintiff , VS. MICHAEL A. LEIB, , Defendant CUSTODY ACTION COMPLAINT FOR CUSTODY AND NOW, this 1 st day of June, 2007, comes Kelly M. Leib, Plaintiff, by her attorney, Ann Marie Rotz, Esquire, and states the following: 1. Plaintiff is Kelly M. Leib ("Mother"), residing at 1282 Fourth Avenue, Chambersburg, Franklin County, Pennsylvania 17201, Franklin County. 2. Defendant is Michael A. Leib ("Father"), residing at 134 Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257, Cumberland County. 3. Plaintiff seeks shared legal custody and primary physical custody of the following child: Name Address Age Taylor Michael Leib 1282 Fourth Avenue 4 Chambersburg, PA 17201 The child was not born out of wedlock. The child is presently in the custody of Plaintiff Kelly M. Leib, who resides at 1282 Fourth Avenue, Chambersburg, Pennsylvania 17201. During the past 5 years, the child has resided with the following persons and at the following addresses: Persons Address Dates Plaintiff and Defendant Plaintiff, Kara M. Alosi (Plaintiff's sister) and Andrew Alosi (Plaintiff's brother-in-law) 134 Orange Street Shippensburg, PA 17257 1282 Fourth Avenue Chambersburg, PA 17201 Birth - 05/05/07 05/05/07 - present The mother of the child is Plaintiff Kelly M. Leib, currently residing at 1282 Fourth Avenue, Chambersburg, Pennsylvania 17201. She is married. The father of the child is Defendant Michael A. Leib, currently residing at 134 Orange Street, Shippensburg, Pennsylvania 17257. He is married. 4. The relationship of Plaintiff to the child is that of natural mother. Plaintiff currently resides with the following persons: Name Relationship Kara M. Alosi Sister to Plaintiff Andrew Alosi Brother-in-law to Plaintiff 5. The relationship of Defendant to the child is that of natural father. Defendant currently resides alone. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of this child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or in any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) the parties are separated and in the process of divorcing; (b) since the child's birth, Plaintiff has been the primary caretaker of the child; (c) the parties have agreed to the relief requested by Plaintiff, as exhibited by the stipulation being filed concurrent herewith; and (d) the parties are already operating under the schedule requested by Plaintiff and agreed to by the parties in the stipulation. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical of the child have been named as parties to this action. No person other than the parties to this action have a claim to custody of the child, and no notice is required to be given to any other person. 9. Plaintiff wishes to share legal custody with Defendant and to exercise primary physical custody with Defendant exercising partial physical custody every other weekend from 10.00 am on Saturday to 6.00pm on Sunday and any other times that are mutually agreed upon. 11. Plaintiff and Defendant signed a custody stipulation setting forth the terms detailed above and the parties are already operating under said schedule. Said stipulation is being filed concurrent herewith. 12. Plaintiff wishes to have said Stipulation entered as a Custody Order. 13. The child does not yet attend school. Plaintiff has enrolled the child in kindergarten in the Shippensburg School District to start this fall and she intends to find a home in the school district prior to the start of school. WHEREFORE, Mother prays your Honorable Court to enter an Order without hearing or conciliation granting the parties shared legal custody, granting Mother primary physical custody and granting Father partial physical custody every other weekend from 10.00 am on Saturday to 6.00pm on Sunday and any other times that are mutually agreed upon. Date: Respectfully Submitted, BEAUCHAT & BEAUCHAT Ann arse Rotz, Esquire Attorney for Plaintiff 63 W. High Street Gettysburg, PA 17325 717.334.4515 ID 201480 VERIFICATION 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 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 92007 lly . L 7 Q = r rn cSi ~C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. - 33 /D d u : LcTi--4 Plaintiff VS. . MICHAEL A. LEIB, Defendant CUSTODY ACTION CUSTODY STIPULATION AND AGREEMENT This Custody Agreement is made this 0 day of May, 2007,by and between Kelly M. Leib currently of 1282 Fourth Avenue, Chambersburg, Franklin County, Pennsylvania (hereinafter referred to as "Mother"), and Michael A. Leib of 134 Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257 (hereinafter referred to as "Father"). WHEREAS, Mother and Father are the natural parents of Taylor Michael Leib (hereinafter referred to as "Taylor"), who was born on July 17, 2002 and is presently four years old; and WHEREAS, Mother and Father are in the process of divorcing; and WHEREAS, Mother and Father live separate and apart; and WHEREAS, Mother wishes to maintain her role as primary care taker of Taylor; and WHEREAS, Mother intends to file a custody complaint concurrent with this Stipulation; and WHEREAS, Mother is represented by Ann Marie Rotz, Esq.; and WHEREAS, Father is aware of his right to counsel and his ability to exercise that right at any time and Father chooses to proceed without counsel; NOW, THEREFORE, Mother and Father agree to the following: 1. Mother and Father shall share legal custody of Taylor. 2. Mother shall have primary physical custody of Taylor. 3. Father shall have partial physical custody of Taylor every other weekend from 10.00 am on Saturday to 6.00pm on Sunday as he is able based on his work schedule and any other times that are mutually agreed upon by Mother and Father. WITNESS: elly Lei Michael A. Leib cT' `? O C7) Vlfl 11-IN 0 6 2007 d'i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION L[ ? C. KELLY M. LEIB, No. 67-3316 Plaintiff I VS. j MICHAEL A. LEIB, . Defendant CUSTODY ACTION ORDER OF COURT AND NOW, y too 7, upon consideration of the attached complaint and stipulation filed of rec rd, IT IS HEREBY ORDERED that parties shall share legal custody of Taylor Michael Leib. IT IS FURTHER ORDERED that Plaintiff Kelly M. Leib shall have primary physical custody of Taylor Michael Leib. IT IS FURTHER ORDERED that Defendant Michael A. Leib shall have partial physical custody every other weekend from 10.00 am on Saturday to 6.00pm on Sunday and any other times that are mutually agreed upon by the parties. 13 V 9rLI V f VnT TD T VIA f?? ]O 4. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, Plaintiff VS. MICHAEL A. LEIB, Defendant No. !D i2ic.,,- G rw : CUSTODY ACTION CUSTODY STIPULATION AND AGREEMENT This Custody Agreement is made this -0 day of May, 2007,by and between Kelly M. Leib currently of 1282 Fourth Avenue, Chambersburg, Franklin County, Pennsylvania (hereinafter referred to as "Mother"), and Michael A. Leib of 134 Orange Street, Shippensburg, Cumberland County, Pennsylvania 17257 (hereinafter referred to as "Father"). WHEREAS, Mother and Father are the natural parents of Taylor Michael Leib (hereinafter referred to as "Taylor"), who was born on July 17, 2002 and is presently four years old; and WHEREAS, Mother and Father are in the process of divorcing; and WHEREAS, Mother and Father live separate and apart; and WHEREAS, Mother wishes to maintain her role as primary care taker of Taylor; and WHEREAS, Mother intends to file a custody complaint concurrent with this Stipulation; and WHEREAS, Mother is represented by Ann Marie Rotz, Esq.; and WHEREAS, Father is aware of his right to counsel and his ability to exercise that right at any time and Father chooses to proceed without counsel; NOW, THEREFORE, Mother and Father agree to the following: 1. Mother and Father shall share legal custody of Taylor. 2. Mother shall have primary physical custody of Taylor. II 3. Father shall have partial physical custody of Taylor every other weekend from 10.00 am on Saturday to 6.00pm on Sunday as he is able based on his work schedule and any other times that are mutually agreed upon by Mother and Father. WITNESS: elly M. Lei Michael A. Leib C r Vi 7 M cD 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07 - 3310 Plaintiff VS. MICHAEL A. LEIB, , Defendant CUSTODY ACTION CERTIFICATE OF SERVICE I, Ann Marie Rotz, Esq. of Beauchat & Beauchat, LLC, do hereby certify that I have served a copy of the Complaint for Custody and Custody Stipulation in the above-captioned matter on June 13, 2007, upon Defendant Michael A. Leib by mailing the original via certified mail, restricted delivery, and a copy via regular first class mail to Defendant's address: 134 Orange Street, Shippensburg, PA 17257. Date: June 13, 2007 BEAUCHAT & BEAUCHAT Ann Marie Rotz, Esq. 63 West High Street Gettysburg, PA 17325 717.334.4515 ID No. 201480 N T ? +d S FT l tiY ?Z (rS "r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, Plaintiff VS. MICHAEL A. LEIB, Defendant No. 07-3310 ACTION IN DIVORCE ACCEPTANCE OF SERVICE I, Michael A. Leib, do hereby certify that I accept service of the Complaint Under Section 3301(c) or 3301(d) of the Divorce Code in the above-captioned matter pursuant to Pa.R.C.P. 1930.4(d). Date: i-oll 61 Michael A. Leib 134 Orange Street Shippensburg, PA 17257 C7 ° 0 t m t rn c? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. MICHAEL A. LEIB, . Defendant CUSTODY ACTION ACCEPTANCE OF SERVICE I, Michael A. Leib, do hereby certify that I accept service of the Complaint for Custody filed on June 4, 2007 in the above-captioned matter. Date: 9'107 Michde1 A. Leib 134 Orange Street Shippensburg, PA 17257 o ,? f .x ate. . U G n r7l .Y _ C.0 C CD ko IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. : MICHAEL A. LEIB, : Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 4, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing 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. 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 unworn falsifications to authorities. Date: y 10 / AOX L M. I Plaintiff rtf v C.3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, Plaintiff No. 07-3310 VS. MICHAEL A. LEIB, Defendant : ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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 unworn falsifications to authorities. Date: 4A A la A/, X///W L M. L laintiff .. p ? "?7 ??? ? t? J .C" G3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff : VS. MICHAEL A. LEIB, : Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 4, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing 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. 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 falsifications to authorities. 10?oe OV Date: MICHAEL A. LEIB Defendant v GEi -aim ? W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, Plaintiff VS. MICHAEL A. LEIB, Defendant No. 07-3310 : ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1 2. I consent to the entry of a final decree of divorce without notice. 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 falsifications to authorities. Date: K ICHAEL A. LEIB Defendant CO 4 yr W 'K. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. MICHAEL A. LEIB, : Defendant 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of service signed by Defendant on June 16, 2007. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on September 4, 2007, by Defendant on September 4, 2007. 4. Related claims pending: None. 5. Date of filing of Waiver of Notice required by Section 3301(c) of the Divorce Code: by Plaintiff on simultaneous herewith; by Defendant on simultaneous herewith. Respectfully Submitted, BEAUCHAT & BEAUCHAT Ann Maria Rotz, Esq. 63 West High Street Gettysburg, PA 17325 717.334.4515 ID 201480 Attorney for Plaintiff r ?° t3 .C" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. MICHAEL A. LEIB, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 4, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing 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. 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 falsifications to authorities. Date: LY .L Plaintiff -n _ =r r ? - r . y.? f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, Plaintiff No. 07-3310 VS. MICHAEL A. LEIB, Defendant : ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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 falsifications to authorities. Date: K Y j.1L9fJd P1 intiff na min IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. MICHAEL A. LEIB, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 4, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing 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. 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 falsifications to authorities. Date: MICHAEL A. LEIB Defendant - cm °r7 M ills. {:: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. MICHAEL A. LEIB, Defendant ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 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 falsifications to authorities. Date: ICHA L A. E Defendant i ra C) t " l `? 3 3. 3 ?CCC q L• „ c-5 of ?-.S ^^C, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION KELLY M. LEIB, No. 07-3310 Plaintiff VS. MICHAEL A. LEIB, Defendant 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of service signed by Defendant on June 16, 2007. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on October 13, 2007, by Defendant on October 15, 2007. 4. Related claims pending: None. 5. Date of filing of Waiver of Notice required by Section 3301(c) of the Divorce Code: by Plaintiff on simultaneous herewith; by Defendant on simultaneous herewith. Respectfully Submitted, are o q 63 West High Street Gettysburg, PA 17325 717.334.4515 ID 201480 Attorney for Plaintiff BEAUC ,JykT & BEAUCHAT 14, Ann M R tz Es . -- ? . s. ?..' ;?.. _...,, ` ?'? f'31 ?..... ,_ ?. i f?? ???? -•r7' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Kellv M. Leib Plantiff No. 07-3310-Civil Term VERSUS Michael A. Leib Defendant DECREE IN DIVORCE AND NOW, 010%b" 2,S' , ZgOl , IT IS ORDERED AND DECREED THAT Kelly M. Leib , PLAINTIFF, AND Michael A. Leib 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 PROTHONOTARY . 'k f TYVO is ?!- pro-"" * (a- t - a/ o ?c °l • s