The URL can be used to link to this page

Home My WebLink About04-0483MELINDA A. LEESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION -LAW NO. 0? L63 CIVIL TERM MARC A. LEESE, 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 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 the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 SAIDIS, SHUFF, FLOWER & LINDSAY Attorneys for Plaintiff SAIDIS SHUFF, FLOWER By: l ((?/P mdsay, Esl & LINDSAY CafOJ63ig ATTORMYS.AT•LAW I )# 426 W. High S treet 6 Carlisle, PA 2 W h Street Carlisle, PA 17013 (717) 243-6222 MELINDA A. LEESE, Plaintiff VS. MARC A. LEESE II, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. og - y J-3 CIVIL TERM IN DIVORCE COMPLAINT MELINDA A. LEESE, Plaintiff, by her attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is MELINDA A. LEESE, who currently resides at 318 Walnut Lane, Carlisle, Cumberland County, Pennsylvania, where she has resided since August of 2002. 2. The Defendant is MARC A. LEESE II, who currently resides at 318 Walnut Lane, Carlisle, Cumberland County, Pennsylvania, where he has resided since August of 2002. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 30, 2002 in Carlisle, SAIDIS Pennsylvania. SHUFF, FLOWER & LINDSAY 5. That there have been no prior actions of divorce or for annulment between ArrORNEYS•AT•LAW 26 W. High Street the parties in this or in any other jurisdiction. Carlisle, PA 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff By: SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT•LAW 26 W. High Street Carlisle, PA # 4403 j 26 Wes Stree Carlisle, PA 17013 Date: ire (717) 243-6222 VERIFICATION I, the undersigned, hereby verify that the statements made herein are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. t?Q? ??? MELIND . L€AS?- Date: O? SAIDIS SHUFB FLOWER & LINDSAY ATTORAM-AT•LAW 26 W. High Street Carlisle, PA y? n CA. n L_. _i na w !^r t C? Cil w 0 -rr c? Q i -aO vn ;i MELINDA A. LEESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-483 CIVIL TERM MARC. A. LEESE, Defendant IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Divorce Complaint in the above captioned case. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Carlisle, PA 17013 (717) 243-6222 MELINDA A. LEESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION -LAW NO. 04 -483 CIVIL TERM MARC A. LEESE, Defendant IN DIVORCE CERTIFICATE OF SERVICE AND now, this 2nd day of March, 2004, I, CAROL J. LINDSAY, Esquire, of the law firm of SAIDIS, SHUFF, FLOWER & LINDSAY, Attorneys, hereby certify that I served the Defendant, MARC A. LEESE, on March 2"d, 2004, with the Complaint in Divorce by Certified Mail, Restricted Deliver, Addressee Only, Return Receipt Requested, addressed to: Marc A. Leese 826 North College Street Carlisle, PA 17013 and proof thereof, the signed Return Receipt Card, is attached hereto. SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintift< SAIDIS SHUFF, FLOWER & LINDSAY ATNRNBy$•AT•fAW 26 W. High Street Carlisle, PA 26 West High Street Carlisle, PA 17013 (717) 243-6222 MELINDA A. LEESE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA MARC A. LEESE, VS. : CIVIL ACTION - LAW ' : NO. 04 -483 CIVIL TERM Defendant : IN DIVORCE PROOF OF SERVICE ¦ Complete Items 1, 2, and 3.Aiso complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: lPal-c ?. k ee-st 312& /)01-411 &I/eye Sf CO'- /K 1014 170,3 A. Signature ? Agent 2Stt ? Addressee B. Received by (Printed Name) C.-Cate of Delivery D. Is delivery address diflererlt from hem 1? ? Yw If YES, enter delivery address below: ? No 3. Service Type B'Eertilled Mail ? Express Mail l'Reglahemd lia1laturn Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? f&tre Fee) Or& 2. Article Number (Transfer from service fabel) 7 O 99 ?/ Q O 06 11 ,5 S000 71 PS Form 3811, August 2001 Domestic Return Receipt 102595-01-M-0391 4 SAIDIS SHUFF, FLOWER & LINDSAY AT wmY$•AT•LAW 26 W. High Street Carlisle, PA (1 no C? ? rr', ? rn_n cr -< ?,. 'ern ? Ln .1 TRAVIS HOLLIDAY, Plaintiff V. BILLIE JO HOLLIDAY Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-•823 CIVIL TERM CIVIL ACTION - CUSTODY CUSTODY STIPULATION AND NOW, this ? day of ?QC 2004, it is hereby stipulated and agreed between the parties as follows: 1. HAYDEN CHARLES JAMES HOLLIDAY, born July 11, 2000 is the natural child of TRAVIS HOLLIDAY and BILLIE JO HOLL.IDAY. 2. Shared legal custody of the child as contemplated by the Act of t 30, 1985, P.L. 264, 23 P.S. §5301, et seq., will be in both of the parties, as the parents. 3. Primary physical custody of the child shall be in the mother subject to t following periods of partial custody with the father: a. Every other weekend from Friday at 5:00 p.m. through Sunday 7:00 p.m. b. One full week during each of the months of June, July and August. C. Alternating holidays from 8:00 a.m. to 7:00 p.m. The holidays shat be New Year's Day, Memorial Day, 4th of July, Labor Day, Easter, Halloweer and Thanksgiving Day, with the father having custody on Memorial Day, 2004. d. The parties shall alternate the Christmas holiday. The father shal have custody of the child from 6:00 p.m. Christmas Eve until 3:00 p.m. Christmas Day in odd numbered years and the mother shall have this period in ever numbered years. The mother shall have custody of the child from 3:00 p.m Christmas Day until 6:00 p.m. December 26th in odd numbered years and the father shall have this period in even numbered years. e. Mother shall have physical custody from 8:00 a.m. until 7:00 p.m, on Mother's Day and Father shall have physical custody from 8:00 a.m. until 7:00 p.m. on Father's Day. f. The party receiving custody shall provide transportation from custodial parent's residence. g. Both parties have agreed to exchanging custody at the point between the two residences. h. The custodial parent shall inform the non-custodial immediately of all medical appointments and problems pertaining to the child. L Neither parent shall do or say anything which may estrange child from the other parent, injure the opinion of the child as to the other parent hamper the free and natural development of the child's love and respect for t other parent. Both parents shall have liberal and reasonable telephone with the child when the child is in the custody of the other parent. 4. The custodial parent shall provide copies of the child's report card and other reasonable papers affecting the child's education, medical condition, or welfare. s W04 Da S?lllU? Date TRAVIS HOLLIDA' ?1? V'A I LLI BILLIE JO IOL DAY 6 11 J > _ Ul Renee K. Simpson Deputy Prothonotary Curtis R. Long Prothonotary t e protbonotarr fl office of c2umberlanb countr John E. Slike solicitor yea--- CIVIL TERM ORDER OF TERMINATION OF COURT CASES VEMBER 2007 AFTER MAILIN HE NOTICE F AND NOW THIS 5 DAY OF NO CE ?TITH PA ROCEED AND RECEIVING NOI RESACCORDAN INTENTION TO P IS TERMINATED WITH PREJUD CASE HEREBY R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY e Pennsylvania 17013 (717) 240-6195 • Fax (717) 240-6573 n"'.- Courthouse Square Carhsl,