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HomeMy WebLinkAbout08-1655o/ JEFFREY R. LEES, Plaintiff VS. CHRISTA J. LEES., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 68-, (tor, Civil Tern+ CIVIL ACTION - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend yourself 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 for any claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request counseling. A list of marriage counselors is available in the office of the Court Administrator, Fourth Floor, Cumberland County Courthouse, Carlisle, PA. 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 A 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 COURT ADMINISTRATOR'S OFFICE Fourth Floor, Cumberland County Courthouse One Courthouse Square Carlisle, PA. 17013 (717) 240-6200 JEFFREY R. LEES, Plaintiff V. CHRISTA J. LEES , Defendant IN THE COURT of COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-. -72o.,, CIVIL ACTION - LAW IN DIVORCE Complaint in Divorce b . K AND NOW this - day of March, 2008 comes Plaintiff JEFFREY R. LEES, by and through his attorney, John M. Glace, Esquire, and seeks to obtain a Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff JEFFREY R. LEES is adult individual who resided and continues to receive his mail at 160 East Cumberland Road, Enola, Cumberland County, Pennsylvania 17025.. 2. The Defendant CHRISTA J. LEES, is an adult individual who resides at 160 East Cumberland Road, Cumberland County, Pennsylvania 17025.. 3. Plaintiff and Defendant were married on January 17, 2004 at Churchill Halls, Enola, Cumberland County, Pennsylvania. 4. Both Defendant and Plaintiff have been continuous residents of the Commonwealth Pennsylvania for more than six (6) months. 5. There have been no prior actions for Divorce or Annulment between parties in Pennsylvania or any other jurisdiction. 6. The parties are the biological parents of three (3) twin children born in wedlock. The minor children, Angelina Jane Lees (dob: 6/11/04), Lennon Michael Lees ( dob: 9/21/06) and Christian Alexander Lees ( dob: 9/21/06) reside with the Defendant. pursuant to agreement between parties. r 7. Neither party is a member of the United States Armed Forces nor of any of its allies. 8. Defendant has been advised of the availability of counseling and his right to request that this Honorable Court require both parties to participate in counseling. 9. Plaintiff avers that the marriage is irretrievably broken to Section 3301 (c) of the Pennsylvania Divorce Code, Act 206 of 1990. WHEREFORE Plaintiff JEFFREY R. LEES respectfully prays this Honorable Court enter a Decree from the bonds of matrimony RESPECTFULLY SUBMITTED. THE LAW OFFICE o OHN M. GLACE Ike, e, Esquire The Law ohn M. Glace 132-t Street Harrisb 7101-1612 (Supreme Court ID4 23933 (7) a C 2 ;:u r c1 0 lc? C j m a JEFFREY R. LEES, Plaintiff V. CHRISTA J. LEES, Defendant IN THE COURT of COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA, No. 2099-- 1?_. CIVIL ACTION - LAW DIVORCE Acceptance of Service I, CHRISTA J. LEES, Defendant above named, accept service of the Complaint in Divorce, as to above docketed and certify that I am competent and authorized to do so. Date of Service R - CHRISTA J. L S Witness CERTIFICATE OF SERVICE I HEREBY CERTIFY that this I7 ? day of March, 2008 I have served a true and correct copy of the foregoing Acceptance of Service, by first class mail, postage pre- paid, upon: Christa J. Lees 160 East Cumberland Road Enola, PA 17025 Glace, Esquire Ct. ID: 23933 132-134 Walnut Street Harrisburg, PA 171101-1612 (717) 238-5515 Counsel for Plaintiff .r fil - ? l s r-r ; - i t E -1 ?. ? ?Y O W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY R. LEES, ) Plaintiff ) vs. ) CHRISTA J. LEES, ) Defendant ) FILE NO. 08-1655 CIVIL TERM IN DIVORCE NOTICE TO RESUME PRIOR SURNAME NOTICE IS HEREBY GIVEN that CHRISTA J. LEES, Defendant in the above matter, [select one by marking "x"]: prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of CHRISTA JANE W ILLIAMS, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. Date: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } ( SS.: On the Z9-01 day of 00-06,ek , 2006, before me, the undersigned officer, personally appeared CHRISTA J. LEES, known to me (or satisfactorily proven) to be the person whose name is signed to the within Notice to Resume Prior Surname and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ?N Notary F?ublic MYdO?Q, ??C - n - 6 ?. }r ? cps IN THE COURT of COMMON PLEAS of CUMBERLAND COUNT m C-) :G JEFFREY R. LEES,- Plaintiff i No. 2008-1655 CIVIL TE rv r, V. , rv CHRISTA J. LEES, CIVIL ACTION - DIVORCE Defendant : STATEMENT of INTENT to PROCEED AND NOW this day of October, 2011 pursuant to PaRCP 230.2, undersigned counsel for above Plaintiff hereby states and notifies all parties of Plaintiffs intent to proceed with above captioned action Respectfully submitted, The Law Office of John M. Glace ;e, Esquire ID: 23933 132-134 Walnut Street Harrisburg, PA 17101 717.238.5515 Counsel for Plaintiff Distribution by Plaintiff: Samuel L. Andes, Esquire, 525 North 12th Street, Lemoyne, PA 17043 CERTIFICATE OF SERVICE Irl I HEREBY CERTIFY that this "day of October, 20111 have served a true and correct copy of the foregoing Statement of intent to Proceed by first class mail, postage pre-paid, upon: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 17043 The Law Office of John M. Glace M. Glace, Esquire eme Ct. ID: 23933 134 Walnut Street isburQ, PA 17101 (717) 238-5515 L) f (S MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT is entered into this a,9 day of 3;Q 04;,,,,,ike , , 2013, by and between JEFFREY R. LEES and CHRISTA J. LEES. RECITALS Wife's Birthday and Social Security Number: April 1, 1984 199-64-8937 Husband's Birthday and Social Security Number: May 16, 1980 M q 6 g qo Date of Marriage: January 17, 2004 r-: Place of Marriage: Enola, Pennsylvania Last Marital Residence: Enola, PA =S Date of Separation: February, 2008 C7 :e. Children: ANGELINA JANE LEES, LENNON MICHAEL LEIi'nd== ` r;• CHRISTIAN ALEXANDER LEES. '' - . Pending Court Proceedings: None Wi4.7 7 Divorce Court of Common Pleas No. 2008- of Cumberland County, Pennsylvania WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation: the ownership and equitable distribution of marital property; the past, present and future support, and/or maintenance of Wife by Husband; and, in general, any and all claims and possible claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any contact, restraint, interference or authority, direct or indirect, by the other provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the existing circumstances. VOLUNTARY EXECUTION Each party understands the terms and conditions of this Agreement and acknowledges that the Agreement is fair and equitable. The parties have reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or improper or illegal agreements. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. Notwithstanding this provision, under applicable Pennsylvania law, the parties understand that any provision of this Agreement relating to child support or to custody shall be subject to modification by the Court upon a showing of changed circumstances. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. AGREEMENT BINDING ON HEIRS Except as may otherwise be provided, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. ADDITIONAL INSTRUMENTS Wife and Husband covenant and agree that they will forthwith (and within at most ten (10) days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict 4 performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision hereof be construed as a waiver of strict performance of any other obligations herein. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS The parties agree that each separate obligation contained in this Agreement shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of any conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. MANNER OF GIVING NOTICE Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return receipt requested, to Susan Kay Candiello, Esquire, at 710 Gladstone Court, Mechanicsburg, Pennsylvania, 17055, or such other address as Wife from time to time may designate in writing. Any notice required by this Agreement to be sent to Husband shall be sent by certified mail, return receipt requested, to Jeffrey R. Lees, 5220 Carlisle Road, Wellsville, Pennsylvania, 17365, or such other address as Husband from time to time may designate in writing. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. BANKRUPTCY OR REORGANIZATION PROCEEDINGS In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under state or federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby assigns, transfers and conveys to the creditor-spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorneys' fees and costs incurred in the enforcement of this Paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, 5 regardless of federal or state law to the contrary, and each party waives any and all right to assert that any obligation hereunder is discharged or dischargeable. EFFECT OF RECONCILIATION OR RECONCILIATION ATTEMPT This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as husband and wife, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shall be no modification or waiver of any of the terms hereof unless the parties, in writing, signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. EXISTING AND FUTURE PERSONAL OBLIGATIONS Further, Wife and Husband each covenant, warrant, represent and agree that neither has heretofore contracted for any debt, liability or obligation for which the other or the estate of the other may be responsible or liable except as specifically disclosed and provided for by the terms of this Agreement. The parties further covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and indemnify the other and the estate of the other from all debts, charges and liabilities incurred after the execution date hereof, except as may be otherwise specifically provided herein, as well as from all debts, liabilities or obligations of every kind which have been incurred heretofore by either party, including those for necessities, except for obligations arising out of this Agreement. ENFORCEMENT The parties intend that this Agreement shall be subject to enforcement under the Pennsylvania Divorce Code of 1980, as amended, and that, notwithstanding any language herein that may be construed to the contrary, this Agreement is not subject to modification except under such terms as the parties have specifically provided for in this Agreement. REMEDIES AND SANCTIONS In addition to such other remedies and sanctions available under applicable law, the parties may utilize any remedy or sanction set forth in the Pennsylvania Divorce Code, as amended, to enforce any term of this Agreement as though it had been an order of the Court. ATTORNEY'S FEES FOR ENFORCEMENT In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay all attorney's fees incurred by the other party in enforcing the Agreement, provided that the enforcing party is successful in establishing that a breach has occurred. 6 • L Xlaadoad aql Has of paaaau anug sailand o iI 'SZOLI `eTUnnpcsuuad `uloug `puo'j puulaagtun3.lsug 091 In palnool Xiiadoid n paunno AIluiof aJim puu pungsnll anievaauapisag Ie;!JIy% DDMIUISDDI 'S 'aounansul tlllnall unno natll.roj algisuodsaa aq tloea of aaagu aJ1m pue pu gsnll 13AKVUf1SNII H1 IV1H 't •alep uotlnoaxa uo gduafeand sup Jo suotslnoad all alenloaJJa of 1ianss0001.1 sluaumoop 1cuu alnoaxa IITnn /Cap lull 00a2u satland oq •atuuu ,sasnods 20410 aql ul pallll slun000u 3Iunq at1101 loadsaa rhino anetl Aetu aagpa tloltlnn `slum° Aue uopungn a3n310J pun aounouaa `asualaa `anIum iflleoijioads Agaaaq op sailred oq •papil sI lun000u alp atuuu asot4M ui asnods 042 Jo Xltadoid alnandas pun Nos 4042 aq Bugs slun000n 3luuq asoq `souznu ,sap Jed alp ur papll slun000n Auu of loadsaa ullm SIMf1OIXW MMVII '£ •alup uoilnoaxa uo olaaatl lunnsand awes anraoaa 02 palll1ua kl.xud all 02 paaanllap aq Hugs sluatunoop plus 04 'algissod Jl stsuq 001J-xnl u uo saouWJcanuoo icuu alum 02 £tnssaoau su suanlall xu,l asn pun sales aloitlaA 2utpnloui 'pang alup uoilnoaxa all uo ticluB and S!41 Jo suolslnoad 041 alunloaJJa 01 Aa1SSa0311 sluautnoop Aun alnoaxa 01 aaau satltnd au •lgap aul anlosaa 01 ldufal1e 01`aolnaas Inlounug alp 01 Tel !pm a3m .X4i1g1suodsaa/fun Jo Jlasuulq 2utnaTlaa `Jio1dnniuuq pap puugsnll 'passassodaa aq 11201 puugsnpl •aplm puu puugsnll /Cq paunno lnq `puugsnll Aq uanUap aloltlan aolotu all 02 loadsaa 41IM Sf'IDIH3A 110.LOI4i •Z •a0Tllo aul Jo Alaadoad antsnloxa pun alos all aq aaljuaaatl Hurls go!gm `suzalt anoqu 041 01 loadsaa rhino aim{ kern aatllta 40uFsn `surtulo Aug uopuuqu a0n0a0J puu aounouaa `asualaa `anrenn Xlluolpoads Xgaaatl op sound oq •aJim Jo ifpadoad aluandas puu Nos atll aq Huns aJim Jo uoissassod atll ul 1padoid am Jo Hu lap saaaau puugsnll puu :puugsnll Jo i(padoad alnandas pun alos alp aq hugs puegsnll Jo uotssassod 042 u1 Xlaadoad 041 Jo Hu Imp saaaau aJtm aa1uaaaq pun `Alaadoad Inuosaad aatllo puu lzn Jo s)laonn `wog `saanlotd `saouutlddu puu luatudinba plotlasnotl `sladauo `s2na `s2244sruafJ `aanlivanJ `satllolo `kiiannaf `uotlnittutl 1notp!m lnq `&tpnloul Iuuosaad algOunl 4042 papintp Aisnornaad anutl 1catl1 imp a2palnnouOIou Agaaaq op aJim put puugsnll A ULIdO Id 'IVAIOS2Idd 'I uoiingDhlSIa TIEIVI 9OI 8 • pun sooj ,sAauronu Suipnioui `asuadxa JO lsoo qpjiquii Arm uiog ssaituaug Jogio aqo nog pun Ajiumopui of sooltrerenS AgoJoq sallied age jo goug :sasuadxx o; sv uo v uurapuj •0 •soi ud Jo ifiiud pzig1 u 41i"'Jo-41020i JO/ciinnpinipu!.iagpagm `A1.zud Jagmia cq paumo siso ioi ui ssauisnq Arm apnioui Jotp.mJ iris uuai aq j •oloJoq sagred alp Jo ouo Jo uoissassod oios 041 ur ApuasoJd si golgm Jassu papi4un Arm sapnioui osiu uua1 oqd, •saiiiud .io Aired p.gtii u pull oloiaq sowed alp Jo ouo grim Apuiof JO °Jaiag Apud u Jo °mull aios NT ui Jar mia 13a99 Xpuasaid Si tioi4M (o gi5umui .io aigi2uul `paxitu JO iuuos.iad `ivaa Jog otim) pupt Atm Jo Jossu /iuu Suguaisap su ivauiaa.r2V situ Jo sasodind .ioj paugap Si „jossu aiuiudas„ uuol ora :not.iufaa •3 •pasoiosIp uooq Jou anuq gorgm `s2assu ui annq AEU!aqs Jo oq goigm `uiiuio Auu asuaiaJ of jooiaq uognoaxa 041 spualui AiJ d JormON •1uouloo V sigh ui Jo pasodsip JO pauiuu Xiiuotpoads oq Jou poou siossu 'tons Onoqmu `Aped Jag10 pasoiosip siossu asogi of su "quo anpo0JJa aq Hugs 1!Imp osinoid NT 01 pot-cps si asuaiai anoqu a41 :pasopostQ sJassV o; uol;v/nu17•g •03a3112=MO anisnioxa puu aios iossu olu.indas u 3o uoissassod JO 01 ailp 2uinug Aarnd ag2 Joljuaiag 2ug2 sa2paimotniou puu `uiaiagl urreio ire puu Aire suopuuqu Jana.IOJ puu sagsinbugai `sasuojoi `sanpum AgaJaq 1assn amiudas Juinogied /uu Jo uoissassod JO 01 Opp Sul/yeti Jou Apud ati1 `uiaiaq paugap si uum reg2 su `spassu orendas .ziagm Jo tiara su aaaau Aga.iaq sogiud ag,i, :asvapaj •y SZ2SSV 11VIIVdIS '8 •pa.unoui sum uogeSggo JO Nap orp aureu asogm ui Aired NJ Jo Amigisuodsaz aios age are `spmo 1ipazo Buipnioui puu `uoge.rudas ,saipud aq1 zagu JO oJOJaq paunoui aag1agm 'mum iunpinipui Jog JO Sit' ui Alrud Jagm° iq pa.unoui suogeaqqo ice\ •sauieu 11.1101u! 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AFTER-ACQUIRED PROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are acquired by him or her after execution of this Agreement, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 10. WAIVER OF SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE Husband and Wife do hereby waive, release and give up any rights arising from the continuing existence of their marital relationship which either may have against the other for spousal support, alimony pendente lite, or other maintenance of any kind, except as otherwise specifically provided herein. 11. COUNSEL FEES AND EXPENSES The parties agree each shall be fully responsible for their own individual counsel fees and expenses incurred in obtaining this divorce. Each of the parties has carefully read and fully considered this Agreement and all of the statements, terms, conditions and provisions thereof prior to signing below. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their hands and seals the day and year first written above. I .. .dee_XSZD 11°' C\U-C,4111—/ WI 1ESS CHRISTA J. LEES, ALA' AIN TNESS JEFFREY R. LEES, HUSBAND 9 COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND On this, the OU day of tpiJ:iA 'L , 2013, before me, a Notary Public, the undersigned officer, personally a ersonall ppp SUSAN KAY CANDIELLO, known to me (or satisfactorily proven) to be a member of the bar of the highest court of said State and a subscribing witness to the within instrument, and certified that she was personally present when JEFFREY R. LEES and CHRISTA J. WILLIAMS, whose names are subscribed to the within Marital Property Settlement Agreement, executed the same, and that said person acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official Seal. Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Lori Ann Dively,Notary Public Lower Allen Twp.,Cumberland County My Commission Expires Sept.13,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES 10 JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 2008 -2494 CHRISTA J. LEES, : CIVIL ACTION - LAW DEFENDANT : ACTION FOR DIVORCE WAIVER OF RIGHT TO COUNSEL FOR MARITAL PROPERTY SETTLEMENT AGREEMENT I,JEFFREY R. LEES, do hereby acknowledge that I am the Husband in this divorce action. I have agreed to and executed the attached Marital Property Settlement Agreement voluntarily. I am not under any duress, nor were there any threats or promises made to me to coerce my execution of this Agreement. I fully understand my property rights as Husband in this divorce action are determined by this Marital Property Settlement Agreement. I agree to fulfill my responsibilities and obligations under this Marital Property Settlement Agreement. I have been advised of and do hereby waive my rights to an atto 1- to represent me on the issue of the Marital Property Settlement Agreement. . --'_ > , _ —".__ _rte' �� Date: S,.p LAO I 1 2013 — ...... JEFFRE ' '.'EE COMMONWEALTH OF PENNSYLVANIA . SS: COUNTY OF CUMBERLAND .• 30-1 ' S.ef3+eVn bev- On this, the 29 day of , 2013, before me, a Notary Public, the undersigned officer, personally appeared SUSAN KAY CANDIELLO,known to me (or satisfactorily proven)to be a member of the bar of the highest court of said State and a subscribing witness to the within instrument, and certified that she was personally present when JEFFREY R.LEES,whose name is subscribed to the within Waiver of Right to Counsel, executed the same, and that said person acknowledged that he executed the same for the purposes therein contained. w IN WITNESS WHEREOF, I hereunto set my hand and official Seal. Ct l'(.) (abr 4,.._ ,c. l LOMMONWEALrH OF PENNSYLVANIA I<lo ary Public Notarial Seal Lori Ann Dively,Notary Public n-i+urr4WEALTH OF PENNSYLVANIA Lower Allen Twp.,Cumberland County _ Notarial Seal My Commission Expires Sept.13,2015 EXHIBIT "A" Lon Ann Dively,Notary Public MEMBER;PENNSYLVANIA ASSOCIATION OF NOTARIES Lower Men Twp.,Cumberland County Mp Commission Expires Sept.13,2015 ,.,;ii.(- :F NNSYLVANIA ASSOCIATION OF NOTARIES JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, c- : PENNSYLVANIA vs. NO. 2008 - 1655 -70 —1 -i;ry.; r— I CHRISTA J. LEES, : CIVIL ACTION - LAW DEFENDANT : ACTION FOR DIVORCE 3>c--) 2 -a. CZ) z_ < c 4. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2008. The Defendant was served the Complaint on March 13, 2008. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce, after the service of notice of intention to request entry of the decree. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce,the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. I verify that the Statements 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. -lid PO 9 / Zi (l 3 DATE EFF O JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA `�' vs. NO 2008 - jCD CHRISTA J. LEES, : CIVIL ACTION - LAW Q DEFENDANT : ACTION FOR DIVORCE =c) -8 cart. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A: `" DIVORCE DECREE UNDER SECTION 3301(c) OF 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. Section 4904 relating to unsworn falsification to authorities. j 7.5 4gllprarallbo DAT C� JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO 2008 - 1655 m_Crl CD r-- CHRISTA J. LEES, : CIVIL ACTION - LAW , c, DEFENDANT : ACTION FOR DIVORCE :< AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 12, 2008. The Defendant was served the Complaint on March 13, 2008. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce, after the service of notice of intention to request entry of the decree. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. I verify that the Statements 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. J' 0 DA C'' TA J. LEES 0 JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA rn vs. . NO 2008 - CHRISTA J. LEES, : CIVIL ACTION - LAW c>-F DEFENDANT : ACTION FOR DIVORCE - o WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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. Section 4904 relating to unsworn falsification to authorities. CJ 6 O DATE CRISTA J. LEES C JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 2008 - 1655 ? CHRISTA J. LEES, : CIVIL ACTION - LAW , c'-) DEFENDANT : ACTION FOR DIVORCE -�r -7) DEFENDANT om <CD - ` PRAECIPE TO TRANSMIT RECORD ...( CFI 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Service upon the Defendant, Christa J. Lees, via Acceptance of Service on March 13, 2008. The Acceptance of Service was filed with the Cumberland County Prothonotary on March 19, 2008. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code by: Plaintiff: September 29th , 2013 Defendant: September 29th, 2013 (a) Related claims pending: None (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: All claims (d) Please see the Marital Property Settlement Agreement which is being filed simultaneously with this Praecipe to Transmit Record and is to be incorporated but not merged into the Divorce Decree. 4. I certify that the Waiver of Notice of Intention to Request Entry of a Divorce Decree i Under Section 3301(c) of Divorce Code, as required by Rule 1920.42(e)(1), was executed on September 29th , 2013 by the Plaintiff and on September 29th , 2013 by the Defendant, and that these documents are being filed simultaneously with this Praecipe to Transmit Record. I further certify that all other documents required by Rule 1920.42 are enclosed herewith. Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO Dated: October 2, 2013 ( ✓ . 6; Susan Kay Can.id s, i squire Counsel for Defendant PA I.D. # 64998 710 Gladstone Court Mechanicsburg PA 17055 (717) 724-2278 JEFFREY R. LEES, : IN THE COURT OF COMMON PLEAS PLAINTIFF : OF CUMBERLAND COUNTY, : PENNSYLVANIA vs. : NO. 2008 —2494 CIVIL TERM CHRISTA J. LEES, : CIVIL ACTION-LAW DEFENDANT : IN DIVORCE ' -0514"rri -71 --� — m PRAECIPE FOR WITHDRAWAL OF APPEARANCE —<> --I Etch Please withdraw my appearance on behalf of the Defendant, Christa J. Lees. = , r ter-' Respectfully submitted, - ' Dated: t )<4 2013 AM a.""muel L. Andes, squire Counsel for Defendant PA I.D. # 525 North Twelfth Street P.O. Box 168 Lemoyne, PA 17013 (717) 761-5361 PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Christa J. Lees. Respectfully submitted, A Ai r _ Dated: c� , 2013 f �� Susan Kay an:iello, Esquire Counsel for De "ndant PA I.D. # 649.8 710 Gladstone Court Mechanicsburg, PA 17055 (717) 724-2278 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey R. Lees V. • Christa J. Lees : NO. 2008-1655 DIVORCE DECREE AND NOW, 0 ,s,■ 7! , • 07,3 , it is ordered and decreed that Jeffrey R. Lees , plaintiff, and Christa J. Lees , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, Attest: J. 1244e;=(.11bI42.16Z_____ - " - Prothonotary c 080 Oopy rmai/ed 40 oIff Koffice♦( Yrna-ila DaL6f ploded rs misimemaa ro!