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Home My WebLink About07-5435STEVEN L. LEIBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. N0.07- S°y~ CIVIL TERM SHANNON L. LEIBY, Defendant : 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 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 TIC RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 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 17013 Telephone: 717-249-3166 u ~ Wayne F hade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243 -0220 Attorney for Plaintiff WAYNE F. SxAnE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 STEVEN L. LEIBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. N0.07- S y3~ CIVIL TERM SHANNON L. LEIBY, Defendant : IN DIVORCE COMPLAINT 1. Plaintiff in this Action in Divorce is STEVEN L. LEIBY, an adult individual who resides at 183 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is SHANNON L. LEIBY, an adult individual and citizen of the United States of America who resides at 2 Bill Dugan Drive, Etters, York County, Pennsylvania 17319. 3. Plaintiff has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. WAYNE F. SHADE Attorney at Iaw 53 West Pomfret Strut Carlisle, Penncytvania 17013 Plaintiff and Defendant were lawfully joined in marriage on June 14, 2003, in Carlisle, Cumberland County, Pennsylvania. 5. The parties have been living separate and apart since on or about May 19, 2007. 6. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which this action is based that Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff intolerable and the life of Plaintiff burdensome. In the further alternative, Plaintiff avers as the grounds on which this action is based that Defendant has committed willful and malicious desertion, absence from the habitation of the injured and innocent spouse, without reasonable cause, since May 19, 2007. 7. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 8. This Action in Divorce is not collusive. 9. Both parties to this Action in Divorce are legally capable of managing their. own WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 concerns. -2- 10. Defendant herein is not a member of the armed forces of the United States of America. 11. There were two children born to the parties, namely, Jessica Lynn Leiby, born February 2, 1995, and Brandon Allen Leiby, born March 25, 2001. 12. 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. WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. Wayne F. hade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff WAYNE F. SHADE Attorney at Law 53 West Pomfret Stmt Cazlisle, Pennsylvania 17013 -3- I verify that the statements made in this pleading 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: September 11, 2007 r Steven L. Leiby WAYNE F. SHADE Attorney at Law 33 West Pomfret Street Carlisle, Pennsylvania 17013 W o~ ~ `~ w ~ v rr•, y ~ ~,. ".' ~r`~i ~. -... ~~ ~ ` STEVEN L. LEIBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO.07-5435 CIVIL TERM SHANNON L. LEIBY, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE WAYNE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff STEVEN WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 L. LEIBY in the above-captioned matter, that he did, on September 13, 2007, serve the Complaint in Divorce in the above-captioned matter upon Defendant by certified United States mail, postage prepaid, return receipt requested, addressee only, and that the same was received by Defendant on September 14, 2007, as evidenced by the return receipt card attached hereto bearing Certified No. 7001 2510 0006 5864 2335. It is understood that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating tQ unsworn falsification to authorities. Date: September 17, 2007 Wayne F. Shade . !~ l~ `~` t~rr ` ~ .~{ : - m , --- m ;, ; -. ~ - ru ~~ ~ i Postage .. ~,, ~ C:L, , .. ' ~ ~ h ~ } ~ ~iJ7 J ~ Certified Fee ~ [ / i _ ~ - ~ ~ Return Receipt Fee ~~.~.1 ~~~`~ '"°°d ± ~ _ „ O (Endorsement Required) ' `~ ~t O Restricted Delivery Fee (Endorsement Required) ~ ~~, ~f] ~ ~',~~ J~ L,'""~ t ~ Total Postage & Fees ~-_ ~Y~ ~1~~~ t tJ7 - ~ sear ro Shannon L. Leiby------------------------------------- a Street, Apt. No.; O or POBOxNo. 2 Bill Dugan-_-Drive____________________ - -- -- -- -- -- ----- - - --- ~ ciy,'stere,ziP+a--Etters, PA 17319 ^ Corr~lsts items 1, 2, and 3. ass corrlplste item 4 iF Rued Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. • Attain this card to the beck of the mailpiece, tx on the front if space pem>rts. X ~/, o 1. Artlcls Addressed to: Shannon L. Leiby 2 Bill Dugan Drive Etters, PA 17319 B. Rec~hred by (P-r-aed t4errre) N D. Is delhrory addroas dllMrent ircm Neat 1? Yes M YE3, error detlvery eddrese below: ^ No 3. tierVbe'type ~D CertMed Mafl D F-> Mefl ^ Reg~tered D Return Rer~fpt for Merchandise O Ir>,sured Mall O C.O.D. z. ArtldeNumber 7Q01 2510 0006 5864 2335 P3 Forrrr 3811, Fet)rwry 2004 Dotnestlc Retwrr Rstrsipt ,oedYe~aa-Aatseo STEVEN L. LEIBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO.07-5435 CIVIL TERM SHANNON L. LEIBY, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF YORK ) 1. A Complaint in Divorce under §3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on September 13, 2007, and served on September 14, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. ~ .... ,.. t7 r~ -~~`- c°a C3 FT7~- f~ -' Ta. r ~~~ `~ 4 " TTj ' ~~;., .~ " ~. ..:: ~~ 1 ~ ~'f ....r ~..y 1~e. ,~ . L.~_ ~ _~ , • ~y C, t . ~~' '~ STEVEN L. LEIBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. N0.07-5435 CIVIL TERM SHANNON L. LEIBY, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) 1. A Complaint in Divorce under §3301(c) of the Divorce Code with Notice of Availability of Counseling was filed on September 13, 2007, and served on September 14, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) w 53 Ca WAYNE F. SHADE Attorney at t.aw 53 West Pomfret Street Carlisle, Pennsylvania 17013 days have elapsed from the date of filing and service of the Complaint. _ ..~. ~ fl r,; ; , H :~~-'~" ~ i r' ` ~ i7'i ~ , Cr 5 ~~. t `r~ ~.~. N ..~ \ ~ y 1. r . .~ ~ '~ '-C STEVEN L. LEIBY, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW v. NO. 07-5435 CIVIL TERM SHANNON L. LEIBY, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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) of the Divorce Code. 2. The date and manner of service of the Complaint were September 14, 2007, by certified United States mail, return receipt requested, addressee only. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention WAYNE F. SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvantia 17013 to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code by Plaintiff was December 27, 2007, and by Defendant was December 27, 2007. 4. Related claims pending: None. Date: December 31, 2007 ~ ~fc~~~ Wayne F~ Shade Attorney for Plaintiff cry ~ ~ ~ , ~ ~ -~-s .... 1.. Tama _~~ y~~-~ . ~ ^;. I N THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY STATE OF ~~ PENNA. ~ - _;~~~- n _ - . _ STEVEN L. LEIBY, „ 'laintiff N O. 07-5435 CIVIL TERM VERSUS SHANNON L. LEIBY, Defendant DECREE IN DIVORCE AND NOW, ~>>`7 is %-' `~ L~ ~~~-'~' IT IS ORDERED AND DECREED THAT AND SHAN1`:ON L. LEIBY 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 BY THE COURT: !~ ,~ ~ f ~` ~` r ' ~~ ~/~ , ATT T: -1 ,,~ ~ _ .~ ~ _ /', PROTHONOTARY w STEVEN L. LEIBY PLAINTIFF, ~. .A, 1 1 1-- I J 7-, ~ X~ Y , _3,